SR 03-27-2018 8B
City Council
Report
City Council Meeting: March 27, 2018
Agenda Item: 8.B
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To: Mayor and City Council
From: Susan Cline, Director, Public Works, Architecture Services
David Martin, Director, Planning and Community Development
Subject: Resolution Certifying the California Environmental Quality Act (CEQA)
Environmental Impact Report (EIR) for the Airport Park Expansion Project
and Project Approval
Recommended Action
Staff recommends that the City Council adopt a resolution (Attachment A) certifying the
California Environmental Quality Act (CEQA) Environmental Impact Report (EIR) for the
Airport Park Expansion project, and a resolution (Attachment B) adopting the Statement
of Overriding Considerations and Mitigation Monitoring Program to approve the project.
Executive Summary
The Airport Park Expansion Project would convert approximately 12 acres of non-
aviation land at the Santa Monica Airport (SMO) into new park and recreational space
adjacent to the existing 8.3-acre Airport Park. The Airport Park Expansion Project would
construct two International Federation of Association Football (FIFA)-regulation-sized
synthetic turf sports fields, 95 community garden plots, a large natural turf multi-purpose
area, pickleball courts, recreational paths, fitness equipment, picnic areas and
structures containing restroom, concession and storage facilities.
In accordance with the California Environmental Quality Act (CEQA), an Environmental
Impact Report (EIR) was prepared for the project (Attachment C). The EIR determined
that the Airport Park Expansion Project would have a significant impact on the
environment with respect to construction noise and traffic. This report recommends the
City Council adopt the resolutions to certify the EIR and adopt a Statement of Overriding
Considerations and Mitigation Monitoring Program.
Background
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The City has long envisioned park and recreational uses on non-aviation land located
south of the runway. There are approximately 40 acres of Airport property designated
exclusively for non-aeronautical purposes. This area contains several buildings that are
leased to artists, commercial office tenants, a restaurant, and museum. Airport Park
and the Airport Park Expansion Project site are also within this area of the Airport.
The City has developed the area south of the runway to include commercial/office,
restaurant, event venues, and educational non-aviation uses, as well as the existing
Santa Monica Airport Park. In July 2002, the Final EIR for the Santa Monica Airport
Park Project was certified, allowing for the development of the existing 8.3-acre public
Airport Park within SMO property. Located in the northwest corner at the intersection of
Airport Avenue and Bundy Drive, the park site is designated “residual land” and the
development of non-aviation uses was permitted under the Airport Master Plan and the
Airport Layout Plan. In 2003, the Airport Park design was approved, construction began
in December of 2005 and the community has been enjoying the fields, dog park, tot lot,
picnic area and general purpose turf area since April of 2007. The existing Santa
Monica Airport Park project cost $7,052,330 to design and construct.
On March 24, 2015, the City Council heard a presentation by City Staff regarding SMO
and future options for SMO operations, as well as land occupied by SMO (Attachment
D). The City Council unanimously voted to direct City staff to develop recreational uses
on approximately 12 acres of non-aviation land adjacent to the existing Airport Park
within three years to address community requests for sports fields.
On June 18, 2016, a community event was held at the existing Airport Park, attended by
approximately 106 people, in which three park concept schemes were presented. The
three park concepts proposed included a Runway Concept (Option 1), a Landing Strips
Concept (Option 2), and a Flight Path Concept (Option 3). Option 1 involved three new
fields, one at FIFA-regulation size, with 192 net parking spaces and a new drop-
off/turnaround location at the south. Option 2 also involved three new fields, two at
FIFA-regulation size, with 160 net parking spaces and a new drop-off/turnaround
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location at the south. Option 3 involved two new fields, both at FIFA-regulation size, with
102 net parking spaces and a new drop-off/turnaround location at the north.
On July 21, 2016, the three park concepts were presented to the City Recreation and
Parks Commission along with the data collected from community members on their
preferences for park amenities. Concept Option 3 was unanimously chosen by the
Commission with additional recommendations, including: the addition of a “loop”
pathway to surround the combined park areas; provision of a pedestrian entry at Bundy
Avenue; placement of the Community Gardens away from the runway and within close
proximity to other new amenities; retention of the size of both the existing children's
playground and dog park; and that consideration be given to add concessions and
pickleball courts.
On July 25, 2016, the three park concept schemes were presented to the Santa Monica
Airport Commission along with the data collected from the community. Action was not
required and the Commissioners deferred to public input and the recommendations of
the Recreation and Parks Commission.
Based on the Council directive to maximize sports fields, community input, and the
recommendations of the Recreation and Parks Commission, the design team developed
a new hybrid concept balancing active recreation amenities with landscaped areas for
passive recreation and organized to facilitate further expansion of the park in the future.
On September 27, 2016 the City Council approved the conceptual direction of the new
hybrid concept and directed staff to proceed with design and construction documents
(Attachment E). The hybrid concept approved by Council is the project analyzed in the
EIR.
Discussion
In accordance with CEQA, an EIR was prepared to analyze the potential environmental
effects of the Airport Park Expansion Project, both individually and cumulatively.
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In accordance with Section 15082 of the CEQA Guidelines, a Notice of Preparation
(NOP) was published on March 8, 2017 for a 30-day comment period which indicated
the City’s intent to prepare an EIR for the project. The NOP was distributed to Federal,
State, Regional, and City agencies, neighborhood groups, and occupants and owners
within a 1,000-foot radius of the Project site and was published on the City’s Planning
and Community Development website. Additionally, a public scoping meeting was held
on March 21, 2017 to present the project and receive comments on the scope of the
EIR.
On October 27, 2017, a Notice of Completion and Public Availability of the Draft EIR
was published, commencing a 45-day comment period for the Draft EIR. The
environmental areas studied in detail in the Draft EIR include:
Air Quality
Construction Effects
Greenhouse Gas Emissions
Hazards and Hazardous Materials
Land Use and Planning
Neighborhood Effects
Noise
Transportation/Traffic
Other issue areas such as Agricultural/Forestry Resources, Biological Resources,
Aesthetics, Cultural Resources, Hydrology/Water Quality, Geology/Soils, Mineral
Resources, Neighborhood Effects, Population/Housing, Public Services, Tribal Cultural
Recourses, and Utilities were determined to be less than significant.
The Final EIR, which was published in January of 2018, contains all comments and
responses to comments received during the comment period as well as minor changes
to the Draft EIR.
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The EIR identified mitigation measures in the areas of Hazards and Hazardous
Materials, Noise (Construction), and Transportation/Traffic (Construction) to reduce
potential impacts to less than significant levels. To ensure these measures are properly
enacted, a mitigation monitoring program is necessary and will be enforced during the
construction and operation of the project, if approved. The mitigation measures are
provided in the Final EIR.
Significant and Unavoidable Impacts
The EIR determined the project would result in short-term significant and unavoidable
construction-related impacts from noise, and long term significant and unavoidable
impacts to transportation and traffic due to operation of the park. During construction,
even with the implementation of identified mitigation, the use of heavy-duty construction
equipment would exceed ambient noise levels at the residences across South Bundy
Drive by more than 5 dBA (decibels), thus exceeding the City of Los Angeles’
thresholds for construction noise. Project construction would not exceed the City of
Santa Monica thresholds for construction noise.
Operation of the park would increase the number of vehicle trips on the roadway
network, such that four nearby intersections would be significantly impacted under the
City’s currently adopted thresholds. These thresholds are based on quality of traffic
service categorized by traffic flow and utilizing level of service (LOS) quality ratings
ranging from A (best) to F (worst). The following intersections in the City were projected
to experience a significant impact during one or more analyzed peak hours:
Intersection LOS Quality Level
23rd Street & Dewey Street F during the P.M. peak hour
23rd Street & Airport Avenue D during the A.M. peak hour
Bundy Drive & Ocean Park Boulevard F during A.M. and P.M. peak hours
Centinela Avenue & Airport Avenue E during the P.M. peak hour
In addition, based on the City’s adopted thresholds for neighborhood street segments,
operation of the project would result in a significant impact on certain street segments.
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Specifically, the project would result in an increase in vehicle trips (i.e., more than one
vehicle trip) to two neighborhood street segments, 23rd Street north of Dewey Street
and Dewey Street west of 23rd Street. No significant impacts were identified at
intersections based on the City of Los Angeles’ thresholds. Currently there are no
feasible mitigation measures available to reduce these impacts, so the impacts would
remain significant and unavoidable. It should be noted that the State Office of Planning
and Research is in the process of revising the significance criteria for CEQA traffic
analysis from LOS to vehicles miles traveled (VMT) in accordance with SB743.
Although the project would result in a significant impact on intersection and street
segment LOS under existing adopted thresholds, the project would result in beneficial
impacts under the forthcoming VMT thresholds (i.e., no significant impacts).
Comments on the Draft EIR
The Draft EIR was available for a 45-day public review period, during which a total of
four comment letters were received. Two of the comment letters were from public
agencies and two were from members of the public. The commenting agencies included
Caltrans Division of Aeronautics and Southern California Edison. These comments
provided regulatory information regarding development of the project, and did not raise
any significant concerns regarding the environmental analysis. The commenting
members of the public requested additional information regarding the park’s features
and traffic/parking. Responses to all comments received are included in the Final EIR.
Alternatives Studied
The EIR studied five alternatives to the project, which are intended to reduce the
significant environmental impacts of the project.
Alternative 1 – No Project/No Build (Existing Conditions)
Alternative 2 – No Project/Reasonable Foreseeable Development (Non-
Recreational Use)
Alternative 3 – Airport Park Expansion without Fields
Alternative 4 – Reduced Project (East Paved Surface Area only)
Alternative 5 – Community Recreation Center
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Environmentally Superior Alternative
In general, the environmentally superior alternative as defined by CEQA should
minimize adverse impacts to the project site and its surrounding environment. Of the
alternatives considered, the "No Project/No Build Alternative” does not create any new
impacts; therefore, it is environmentally superior to a project, which proposes to change
existing conditions. However, the No Project/No Build Alternative does not meet any of
the project objectives. CEQA Guidelines section 15126.6 states that if the
environmentally superior alternative is the No Project/No Build Alternative, the EIR shall
also identify an environmentally superior alternative from among the other alternatives.
Of the alternatives considered, Alternative 3 (Airport Park Expansion without Fields)
reduces the project’s impacts the most; although significant and unavoidable short-term
construction noise impacts and long-term traffic impacts would remain, the long-term
traffic impacts would be measurably reduced. Therefore, Alternative 3 is considered to
be the environmentally superior alternative over other alternatives that may have fewer
impacts in other areas. However, by providing no new sports fields, Alternative 3 would
not meet the project’s objectives, particularly the objective to develop recreational uses
that would meet the highest priority needs of the community. In spite of being an
environmentally superior alternative, the City may reject this alternative on policy
grounds and may pursue the alternative that can attain most of the City’s overall project
objectives so long as findings are made that there are sufficient benefits to the
community (“overriding considerations”) to warrant project approval.
Statement of Overriding Considerations
Due to the significant and unavoidable impacts of the Airport Park Expansion Project,
approval of the project will require the City Council to adopt a Statement of Overriding
Considerations. The benefits of the project include expanding opportunities for public
wellbeing, recreation and community development for City residents consistent with
long-standing City objectives. Additionally, the project is consistent with the City’s Land
Use and Circulation Element, which encourages high-quality recreational facilities to be
developed through an offering of diverse amenities and activities intended to serve all
ages, physical abilities, and activity levels and suitable for individual, team or large
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group use. The amenities would include a community learning garden, individual garden
plots, team-based sports fields, paths for walking and running, stair steps, resistance
training, zones for pickleball and table tennis, multiple non-programmed park and fitness
areas and expansive open green space within Santa Monica’s urban setting. The
benefits of the project would be incorporated into the Council resolution adopting the
Statement of Overriding Considerations and Mitigation Monitoring Program should the
Council determine an override is appropriate.
Next Steps
Once the EIR is certified, design will conclude upon reaching completion of 100%
construction documents. Construction of the project is dependent on securing a permit
for construction and identification of construction funding.
Financial Impacts and Budget Actions
The CIP budget has appropriated $1.6 million in General Funds to fund the design
phase for the Santa Monica Airport Park Expansion Project. The unfunded construction
budget is currently estimated to be $39.3 million and would require alternative financing
given that the estimate is more than the General Fund CIP annual allocation would be
able to support.
There is no immediate financial impact or budget action necessary as a result of the
recommended actions.
Prepared By: Voneelya Simmons, Project Manager
Approved
Forwarded to Council
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Attachments:
A. Airport Park Expansion EIR Resolution
B. Airport Park Expansion SOC Resolution
C. Airport Park Final EIR
D. March 24, 2015 Staff Report
E. September 27, 2016 Staff Report
Proposed Airport Park Expansion Project
Final Environmental Impact Report
SCH# 2017031024
January 2018
Prepared for:
City of Santa Monica
Planning and Community Development Department
1685 Main Street
Santa Monica, CA 90401
Prepared by:
Amec Foster Wheeler Environment & Infrastructure, Inc.
104 West Anapamu Street, Suite 204A
Santa Barbara, CA 93101
Prepared for:
Public Final
ENVIRONMENTAL
IMPACT REPORT
FOR THE
Proposed Airport Park
Expansion Project
SCH # 2017031024
STATE CLEARINGHOUSE NO. 2000041062
January 2018
Airport Park Expansion Project ES-1
Final EIR – January 2018
EXECUTIVE SUMMARY
INTRODUCTION
This Environmental Impact Report (EIR) evaluates the potential environmental impacts of the
proposed Airport Park Expansion Project (Project) in the City of Santa Monica (City), California,
consistent with the California Environmental Quality Act (CEQA). The EIR was prepared by
Amec Foster Wheeler Environment & Infrastructure, Inc. (Amec Foster Wheeler) in cooperation
with City of Santa Monica staff.
The Project site lies on approximately 15.8 acres of non-aviation land at the southeast corner of
Santa Monica Airport (SMO) property. Approximately 12 acres of the Project site is currently
improved with two non-contiguous paved surface areas adjacent to either side of the existing
Airport Park, while the remaining 2.2 acres of the Project site consist of portions of the existing
8.3-acre Airport Park that would be renovated to accommodate the Project. The two paved surface
areas are approximately six acres in size each. The west parcel includes the aviation-related land
uses of 3025 Airport Avenue (i.e., small administration office buildings and airplane hangars,
48 aircraft tie-downs, aircraft storage, and the Proteus Air Service flight school); and Donald
Douglas Loop South. The east parcel previously supported approximately 78 airplane tie-down
spaces, which were removed in June 2017. Currently, the east parcel remains as a vacant paved
surface area, with public access for unprogrammed recreational use, including roller-blading and
bicycle training for families. The portions of existing Airport Park to be renovated include
approximately 1.5 acres of the lawn area adjacent to the south parking lot, of which 1.14 acres
would be reused as lawn and 0.36 acres would be converted to community garden plots. The
existing, 0.7-acre, 58 space north parking lot would be removed to accommodate various park
amenities. The remaining 1.6 acres is occupied by the existing alignment of Donald Douglas Loop
South.. The Project site comprises all or a portion of three parcels.
The Project proposes to expand the existing Airport Park by redeveloping the approximately
12 acres of paved surface area adjacent to the existing park into new recreational amenities. Two
new International Federation of Association Football (FIFA)-regulation-sized sports fields, a
natural-turf multi-purpose area, three pickleball courts, a continuous loop pathway, two restroom
and concession buildings, a 120-space parking lot, improved vehicle circulation, and a variety of
other recreational amenities would be added to Airport Park as part of the Project. Access to the
Project site would be provided via the existing Donald Douglas Loop South roadway, which would
be realigned to the western perimeter of the Project site to avoid bifurcation of the park and allow
continuous pedestrian access for visitors within the park. An acoustical berm would also be
constructed at the northeast corner of the Project site, adjacent to existing runways and Bundy
EXECUTIVE SUMMARY
ES-2 Airport Park Expansion Project
Final EIR – January 2018
Drive, to buffer the park from noise from airport operations and from park usage on nearby
residences. The Project would largely avoid changes to the existing Airport Park, except as noted
above. Portions of the existing park would remain open during construction.
PROJECT OBJECTIVES
Section 15124(b) of the CEQA Guidelines requires a project description to contain a statement of
a project’s objectives and Section 15124(b) requires that the statement of objectives includes the
underlying purpose of the project. The City has determined that the Project has 1110 major
objectives, as follows:
1) Provide a Broad Range of Safe Park Uses: Enhance and expand the City of Santa Monica
open space system by providing a broad range of safe, high-quality recreational amenities
for residents of all ages and abilities, with an emphasis on maximizing the total square
footage of sports fields available at Airport Park.
2) Accommodate Future Expansion of Airport Park: Ensure that the design of Airport
Park is compatible with the goal of a much larger and more varied mix of active and natural
park uses anticipated following the closure of the airport, to facilitate further expansion of
Airport Park in the future.
3) Community Needs: Develop recreational uses that meet the highest priority needs of the
community.
4) Compatible Interface with Adjacent Uses: Design a park and recreation facility that is
sensitive to, and compatible with surrounding land use and the environment.
5) General Plan Open Space Element: Implement Policy 2.1 of the Open Space Element to
revise portions of public lands, including the “conversion of non-aviation lands at the
Municipal Airport including streetscape improvements to Airport Avenue, sports fields,
picnic areas, and an off-leash dog area.”
6) Streetscape Improvements: Provide sidewalk, street and streetscape improvements along
the relocated portion of Donald Douglas Loop South and portions of Bundy Drive north of
the existing dog park to the project’s northerly boundary to enhance aesthetics of the
Airport, including Airport Park and its surrounding land uses.
7) Minimize Noise Impacts: Buffer potential noise impacts associated with airport
operations on Airport Park, and potential noise impacts associated with Airport Park on the
nearby residential and commercial uses.
EXECUTIVE SUMMARY
Airport Park Expansion Project ES-3
Final EIR – January 2018
8) Minimize Traffic Impacts: Develop high-quality recreational facilities in walking
distance to residents and with convenient access to public transit options.
9) Architectural Design: Ensure high-quality architectural design that enhances the park’s
surroundings, including by incorporating attractive architectural features, landscaping, and
lighting.
10) Sustainability: Build new and modern energy-efficient amenities and water saving
features that are sustainable and meet the latest building and energy codes.
PROJECT OVERVIEW
The Project would involve redevelopment of non-aviation land within the SMO property to
provide new recreational facilities. The Project would more than double the size of Airport Park,
with improvements including constructing approximately 12 acres of new recreational amenities
and renovating a 2.2-acre portion of the existing Airport Park. The development program may
experience minor revisions and refinements during final project design and approval; however, the
total park area would not exceed 20.3 acres. The Project would primarily serve Santa Monica’s
Sunset Park and Ocean Park neighborhoods, as well as Los Angeles’ Mar Vista neighborhood.
ENVIRONMENTAL IMPACT ANALYSIS
This EIR examines potential short- and long-term impacts of the Project. These impacts were
determined through a rigorous process mandated by CEQA in which existing conditions are
compared and contrasted with conditions that would exist once the project is implemented. For
each impact topic, thresholds for determining impact significance are identified based on City and
State CEQA Guidelines, along with descriptions of methodologies used for conducting the impact
analysis. For some topics, such as air quality, traffic, and noise, the analyses of impacts are more
quantitative in nature and involve the comparison of effects against a numerical threshold. For
other topics, such as land use and planning, the analyses of impacts are inherently more qualitative,
involving the consideration of a variety of factors, such as adopted City policies.
The EIR impact discussions classify impact significance levels as:
1. Significant and Unavoidable - a significant impact to the environment that remains
significant even after mitigation measures are applied;
2. Significant but Mitigable - a significant impact that can be avoided or reduced to a less
than significant level with mitigation;
EXECUTIVE SUMMARY
ES-4 Airport Park Expansion Project
Final EIR – January 2018
3. Less Than Significant - a potential impact that would not meet or exceed the identified
thresholds of significance for the resource area;
4. No Impact – no impact would occur for the resource area; and
5. Beneficial – a positive effect on the natural or human environment would occur.
Determinations of significance levels in the EIR are made based on impact significance criteria
and applicable CEQA Guidelines for each resource area.
NOTICE OF PREPARATION/SCOPING
As a first step in complying with the procedural requirements of CEQA, the City performed a
public scoping process consistent with Section 15082 of the CEQA Guidelines. The public was
provided an opportunity to comment on the scope of the EIR through a Notice of Preparation
(NOP) released on March 8, 2017, which was distributed to Federal, State, Regional, and City
agencies, neighborhood groups, and occupants and owners within a 1,000-foot radius of the Project
site. The NOP comment period ran from March 8, 2017 through April 8, 2017 (Appendix A). The
scoping process assisted the City in determining if any aspect of the Project may cause a significant
effect on the environment and, based on that determination, narrowing the focus (or scope) of the
subsequent environmental analysis. Comments received during the NOP comment period were
considered during EIR preparation and are included in Appendix A along with responses.
The Draft EIR wasis distributed to federal, state, regional, and City agencies, neighborhood
groups, occupants and owners within a 1,000-foot radius of the Project site, and NOP commenters
with a 45-day public comment period from October 27, 2017 to December 11, 2017. The Draft
EIR wasis also available for review online at the City’s Planning and Community Development
Department website at:
https://www.smgov.net/Departments/PCD/Plans-Projects/
Hardcopies of the Draft EIR wereare available for review at City Hall, as well as local libraries.
Comments received on the Draft EIR during the public review period arewill be addressed in thise
Final EIR (please see Section 8.0, Introduction to the Final EIR, Section 9.0, Response to Comments,
and Section 10.0, Corrections and Additions).
SUMMARY OF PROJECT IMPACTS
The significance of each impact resulting from implementation of the Project has been determined
based on impact significance criteria and applicable CEQA Guidelines for each resource area.
Table ES-1 presents a summary of the impacts, mitigation measures, and residual impacts from
EXECUTIVE SUMMARY
Airport Park Expansion Project ES-5
Final EIR – January 2018
implementation of the Project. In summary, the Project would result in potentially significant and
unavoidable impacts related to short-term noise impacts and long-term transportation and
circulation impacts.
SUMMARY OF CUMULATIVE IMPACTS
“Cumulative Impacts,” (Section 15130) describes impacts that could occur from the combined
effect of other past, present, and reasonably foreseeable future projects. For each significant adverse
impact identified, mitigation measures are presented where feasible to reduce the impacts to
acceptable levels. Cumulative impacts were determined to be less than significant for air quality,
greenhouse gas (GHG) emissions, hazards and hazardous materials, land use, and long-term
operational noise. Cumulative impacts were determined to be significant and unavoidable for
construction effects; short-term construction-related noise; and transportation and circulation.
SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL IMPACTS
The Project would result in significant and unavoidable short-term Project impacts to noise,
construction effects, and long-term Project impacts to transportation and traffic based on
intersection level of service.
ENVIRONMENTALLY SUPERIOR ALTERNATIVE
The EIR also includes four alternatives, including a No Project Alternative, in compliance with
CEQA. These alternatives include:
• Alternative 1 – No Project/No Build Alternative;
• Alternative 2 – No Project/Reasonable Foreseeable Development Alternative;
• Alternative 3 – Airport Park Expansion without Fields Alternative;
• Alternative 4 – Reduced Project Alternative (East Paved Surface Area Only); and
• Alternative 5 – Community Recreation Center Alternative.
The State CEQA Guidelines generally require that an EIR identify the environmentally superior
alternative. CEQA Guidelines Section 15126.6 states that if the environmentally superior
alternative is the No Project Alternative, the EIR shall also identify an environmentally superior
alternative from among the other alternatives. Of the alternatives considered, Alternative 3
(Airport Park Expansion without Fields) reduces Project impacts the most; although significant
and unavoidable short-term noise impacts and long-term traffic impacts would remain, the long-
term traffic impacts would be measurably reduced. Therefore, Alternative 3 is considered to be the
environmentally superior alternative over other alternatives that may have fewer impacts in other
EXECUTIVE SUMMARY
ES-6 Airport Park Expansion Project
Final EIR – January 2018
areas. However, by providing no new sports fields, Alternative 3 would not meet the Project’s
primary objective to develop the Project in a manner than maximizes the number of new sports
fields at Airport Park. See Section 5.0 for a full analysis of the alternatives.
EXECUTIVE SUMMARY
Airport Park Expansion Project ES-7
Final EIR – January 2018
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts
Impacts Mitigation Measures Residual Impacts
Air Quality
AQ-1 Construction and operation of the Project would generate
emissions that would contribute to Basin-wide air pollutant emissions.
However, since the Project would not increase the severity of or cause
existing air quality violations and would not generate population
growth such that the AQMP’s population forecast would be exceeded,
the Project would not conflict with the AQMP and this impact would
be less than significant.
No mitigation required Less Than Significant
AQ-2 Construction activity for the Project would generate air
pollutant emissions. Emissions of NOx, VOC, PM10, PM2.5, SOx, and
CO would not exceed SCAQMD regional thresholds; therefore, this
impact would be less than significant.
No mitigation required Less Than Significant
AQ-3 Operation of the Project would generate air pollutant
emissions that would be below SCAQMD mass daily thresholds;
therefore, this impact would be less than significant.
No mitigation required Less Than Significant
AQ-4 Onsite construction-related emissions would not exceed the
SCAQMD localized significance thresholds (LSTs), would not
generate substantial Toxic Air Contaminants (TACs), and would not
place sensitive receptors within buffer zones of potential TAC
emitters; therefore, this impact would be less than significant.
No mitigation required Less Than Significant
AQ-5 Project-generated traffic, together with other cumulative
traffic in the area, would incrementally increase carbon monoxide
(CO) levels in the vicinity of local intersections. However, state and
federal CO standards would not be exceeded with implementation of
the Project and this impact would be less than significant.
No mitigation required Less Than Significant
AQ-6 None of the land uses included in the Project would result in
objectionable odors that would affect a substantial number of people.
Therefore, this impact would be less than significant.
No mitigation required Less Than Significant
Construction Effects
CE-1 Implementation of the Project would have considerable
construction-period impacts due to the scope, or location of
construction activities. The implementation of identified mitigation
MM HAZ-1: Prior to the start of
construction, the contractor shall conduct a
comprehensive survey of lead based paint
Significant and Unavoidable
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-8 Airport Park Expansion Project
Final EIR – January 2018
measures would reduce all construction-related impacts to a less than
significant level, with the exception of short-term noise impacts,
which would remain significant and unavoidable when compared to
City of Los Angeles thresholds. When compared to City of Santa
Monica thresholds for construction noise, these impacts would be less
than significant.
(LBP) and asbestos containing materials
(ACM). If such hazardous materials are
found to be present, the contractor shall
follow all applicable local, state and federal
regulations, including compliance with
SCAQMD Rule 1403 as well as best
management practices related to the
treatment, handling, and disposal of LBP and
ACM.
MM HAZ-2: Prior to the start of
excavation or grading in areas of known soils
contamination, the construction contractor
shall submit a Soils Management Plan and a
Transportation Plan to the appropriate
cleanup agency (e.g., Los Angeles Regional
Water Quality Control Board [LARWQCB],
Department of Toxic Substances Control
[DTSC], Santa Monica Fire Department
[SMFD]) for review and approval. The Soils
Management Plan and Transportation Plan
shall include the following tasks.
Soils Management Plan
Affected soils shall be either directly loaded
into awaiting trucks for immediate offsite
disposal or temporarily stockpiled on plastic
sheeting prior to load-out and offsite disposal.
If temporarily stockpiled, soil removed from
the excavations shall be placed next to or as
close as possible to the excavation from which
it came.
Prior to load-out, the construction contractor
shall prepare waste profiles and example
waste manifests for approval by the receiving
facilities. Soil and material segregation,
stockpile handling, truck loading, and storm
water management practices shall be followed
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-9
Final EIR – January 2018
during the remedial action according to the
following.
Soil and Material Segregation
Overburden soils shall be screened with an
organic vapor analyzer (OVA) in accordance
with South Coast Air Quality Management
District (SCAQMD) Rule 1166. Any affected
soils shall be segregated and disposed of in
accordance with federal, state, and local
regulations.
Stockpile Management
Any stockpiled soils for load-out shall be
segregated by waste classification:
• Nonhazardous waste.
• Volatile Organic Compound (VOC)-
contaminated nonhazardous waste with
OVA readings greater than 50 parts per
million (ppm) but less than 1,000 ppm.
• VOC-contaminated nonhazardous waste
with OVA readings of 1,000 ppm or
greater. These soils shall be immediately
sprayed with water or suppressant and
placed in a sealed container (roll-off bin)
or directly loaded into a suitable transport
truck, moistened with water, and covered
with a tarp for offsite transportation to the
appropriate disposal facility, as specified
in the SCAQMD Rule 1166 Mitigation
Plan.
The temporary stockpiles containing affected
soils shall be managed as follows:
• The temporary stockpiles for non-VOC
contaminants shall be placed on plastic
sheeting and kept moist during working
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-10 Airport Park Expansion Project
Final EIR – January 2018
hours and covered with plastic sheeting at
the end of the day to control dust.
• The VOC-contaminated stockpiles shall
be placed on plastic sheeting and
immediately covered with plastic
sheeting. The edges of the plastic shall
have an overlap of at least 24 inches. The
plastic shall be secured at the base of the
stockpile and along the seams of
overlapping plastic sheeting with
sandbags or equivalent means. The
stockpiles shall remain covered until
load-out.
• Daily inspections of the stockpiles shall
be conducted to verify the integrity of the
stockpile covers. Any gaps, tears, or other
deficiencies shall be corrected
immediately. Daily records shall be kept
of stockpile inspections and any repairs
made.
• If necessary, commercial vapor
suppressants and sealants shall be
prepared and applied to VOC-
contaminated soil in accordance with the
manufacturer’s recommendations.
• During stockpile generation and removal,
only the working face of the stockpile
shall be uncovered.
Decontamination Methods and Procedures
Each piece of equipment used for the
excavation of affected soils shall have a clean-
out bucket or continuous edge across the
cutting face of its bucket. No excavation of
affected soil shall be permitted with
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-11
Final EIR – January 2018
equipment utilizing teeth across the cutting
edge of its bucket.
Entry to the contaminated areas (i.e., work
exclusion zones) shall be limited to avoid
unnecessary exposure and related transfer of
contaminants. In unavoidable circumstances,
any equipment or truck(s) that come into
direct contact with affected soil shall be
decontaminated to prevent the onsite and
offsite distribution of contaminated soil. The
decontamination shall be conducted within a
designated area by brushing off equipment
surfaces onto plastic sheeting. Trucks shall be
visually inspected before leaving the site, and
any dirt adhering to the exterior surfaces shall
be brushed off and collected on plastic
sheeting. The storage bins or beds of the
trucks shall be inspected to ensure the loads
are properly covered and secured. Excavation
equipment surfaces shall also be brushed off
prior to removing the equipment from
contaminated areas.
Movement of affected soils from the
excavation area to temporary stockpiles shall
be conducted using enclosed transfer trucks, if
possible. If affected soils must be moved
within an open receptacle (e.g., loader
bucket), the travel path for the loader shall be
scraped following this activity, with scraped
soils placed in the temporary stockpile for
load-out.
Sampling equipment that comes into direct
contact with potentially contaminated soil or
water shall be decontaminated to assure the
quality of samples collected and/or to avoid
cross-contamination. Disposable sampling
equipment intended for one-time use shall not
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-12 Airport Park Expansion Project
Final EIR – January 2018
be decontaminated, but shall be packaged for
appropriate offsite disposal. Decontamination
shall occur prior to and after each designated
use of a piece of sampling equipment, using
the following procedures:
• Nonphosphate detergent and tap-water
wash, using a brush if necessary.
• Tap-water rinse.
• Initial deionized/distilled water rinse.
• Final deionized/distilled water rinse.
Truck Loading
Trucks may be loaded directly from the
excavation or temporary stockpile based on
truck availability and excavation logistics.
Trucks shall be routed and stockpile areas
shall be located so as to avoid having trucks
pass through impacted areas. The truckloads
shall be wetted and tarped prior to exiting the
site. All soil hauled from the site shall comply
with the following:
• Materials shall be transported to a Class II
landfill in accordance with applicable
rules and regulations for the handling and
disposal of hazardous materials. If
contamination in the soils is at or above
regulatory levels, the Department of
Toxic Substances Control (DTSC) shall
be contacted and notified to determine
appropriate action.
• No excavated material shall extend above
the sides or rear of the truck/trailer.
• Trucks/trailers carrying affected soils
shall be completely tarped/covered to
prevent particulate emissions to the
atmosphere. Prior to covering/tarping, the
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-13
Final EIR – January 2018
surface of the loaded soil shall be
moistened.
• The exterior of the trucks/trailers shall be
cleaned off prior to leaving the site to
eliminate tracking of material offsite.
Storm Water Management
The good housekeeping practices prescribed
in the City’s Urban Runoff Mitigation Plan
(Municipal Code Section 7.10.060) shall be
implemented during soil excavation activities
to contain and control storm water runoff that
might convey contaminated or excessive
sediments. If rainfall is expected, the areas
around open excavations shall be graded and
bermed to prevent storm water from flowing
into the excavation. Any standing water that
collects in the bottom of the excavations
shall be removed and handled in accordance
with federal, state, and local regulations. The
water shall be sampled and analyzed either as
standing water in the excavation or following
containment in a temporary above-ground
storage tank. Depending on the volume of
water and the sampling results, options for
handling the standing water could include:
• Pumping the standing water into
temporary above-ground storage tanks for
reuse onsite for dust suppression.
• Pumping the standing water through
filters and a carbon adsorption filter (if
required based on analytical results) prior
to discharge to a storm drain, subject to
approval by the City of Santa Monica
Water Resources Protection Programs
Division.
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-14 Airport Park Expansion Project
Final EIR – January 2018
• Pumping the standing water into vacuum
trucks for transport and disposal at a
recycling facility.
Transportation Plan
All affected soils shall be transported offsite
for lawful management and disposal. Prior to
load-out, the construction contractor shall
prepare waste profiles for the receiving
facility using analytical data from the
previous environmental site assessment.
On-Site Soils Remediation Plan
If remediation for contaminated soils
remaining on site is required, all remediation
activities shall be accomplished in a manner
that reduces risk to below applicable
standards and shall be completed prior to
opening the park to the public. Closure report
or other reports regarding investigation and/or
remediation activities regarding contaminated
soil shall be submitted to DTSC for review
and approval. Approved reports that
document the successful completion of
required remediation activities for
contaminated soils shall be submitted to the
DTSC prior to opening the park to the public.
MM NOI-1: A Construction Noise
Management Plan shall be implemented
during Project construction. The Plan would
address noise and vibration impacts and
outline measures that would be used to
reduce impacts. Measures would include:
• To the extent that they exceed the
applicable construction noise limits,
excavation, foundation-laying, and
conditioning activities shall be restricted
to between the hours of 10:00 AM and
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-15
Final EIR – January 2018
3:00 PM, Monday through Friday, in
accordance with Section 4.12.110(d) of
the Santa Monica Municipal Code.
• The construction contracts shall require
implementation of the following
construction best management practices
(BMPs) by all construction contractors
and subcontractors working in or around
the Project site to reduce construction
noise levels:
o Contractors and subcontractors shall
ensure that construction equipment is
properly muffled according to
manufactures specifications or as
required by the City’s Department of
Building and Safety, whichever is the
more stringent.
o Contractors and subcontractors shall
place noise-generating construction
equipment and locate construction
staging areas away from sensitive
uses, where feasible, to the
satisfaction of the Department of
Building and Safety.
o Contractors and subcontractors shall
implement noise attenuation
measures which may include, but are
not limited to, noise barriers or noise
blankets to the satisfaction of the
City’s Department of Building and
Safety.
• Contracts with its construction
contractors and subcontractors shall
include the requirement that construction
staging areas, construction worker
parking and the operation of earthmoving
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-16 Airport Park Expansion Project
Final EIR – January 2018
equipment within the project site, are
located as far away from vibration- and
noise-sensitive sites as possible. Contract
provisions incorporating the above
requirements shall be included as part of
the project’s construction documents.
• Contract specifications shall instruct that
heavily loaded trucks used during
construction shall be routed away from
residential streets to the extent possible.
Contract specifications shall be included
in the Project’s construction documents.
MM T-1: The City shall prepare,
implement and maintain a Construction
Impact Mitigation Plan for review and
approval prior to issuance of a building
permit to address and manage traffic during
construction and shall be designed to:
• Prevent traffic impacts on the surrounding
street network
• Minimize parking impacts both to public
parking and access to private parking to
the greatest extent practicable
• Ensure safety for both those constructing
the Project and the surrounding
community
• Prevent substantial truck traffic through
residential neighborhoods
• Provide for coordination with adjacent or
nearby construction Projects
The Construction Impact Mitigation Plan
shall be subject to review and approval by
the following City departments: Public
Works, Fire, Planning and Community
Development, and Police to ensure that the
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-17
Final EIR – January 2018
Plan has been designed in accordance with
this mitigation measure and meets City
standards. This review shall occur prior to
issuance of grading or building permits. It
shall, at a minimum, include the following:
Ongoing Requirements throughout the
Duration of Construction
• A detailed Construction Impact
Mitigation Plan for work zones shall be
maintained. At a minimum, this shall
include parking and travel lane
configurations; warning, regulatory,
guide, and directional signage; and area
sidewalks, bicycle lanes, and parking
lanes. The plan shall include specific
information regarding the Project’s
construction activities that may disrupt
normal pedestrian and traffic flow and the
measures to address these disruptions.
Such plans shall be reviewed and
approved by the Strategic and
Transportation Planning Division prior to
commencement of construction and
implemented in accordance with this
approval.
• Work within the public right-of-way shall
be performed between 9:00 a.m. and 4:00
p.m. This work includes dirt and
demolition material hauling and
construction material delivery. Work
within the public right-of-way outside of
these hours shall only be allowed after the
issuance of an after-hours construction
permit.
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-18 Airport Park Expansion Project
Final EIR – January 2018
• Streets and equipment shall be cleaned in
accordance with established Public Works
Department requirements.
• Trucks shall only travel on a City-
approved construction route. Truck
queuing/staging shall not be allowed on
Santa Monica streets. Limited queuing
may occur on the construction site itself.
• Materials and equipment shall be
minimally visible to the public; the
preferred location for materials is to be
onsite, with a minimum amount of
materials within a work area in the public
right-of-way, subject to a current Use of
Public Property Permit.
• Any requests for work before or after
normal construction hours within the
public right-of-way shall be subject to
review and approval through the After
Hours Permit process administered by the
Building and Safety Division.
• Provision of off-street parking for
construction workers, which may include
the use of a remote location with shuttle
transport to the site, if determined
necessary by the City of Santa Monica.
Project Coordination Elements That Shall Be
Implemented Prior to Commencement of
Construction
• The City shall advise the traveling public
of impending construction activities (e.g.,
information signs, portable message
signs, media listing/notification, and
implementation of an approved
Construction Impact Mitigation Plan).
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-19
Final EIR – January 2018
• The City shall provide timely notification
of construction schedules to all affected
agencies (e.g., MTA, Big Blue Bus,
Police Department, Fire Department,
Public Works Department, and Planning
and Community Development
Department) and to all owners and
residential and commercial tenants of
property within a radius of 500 feet.
• The City shall coordinate construction
work with affected agencies in advance of
start of work. Approvals may take up to
two weeks per each submittal.
Greenhouse Gas Emissions
GHG-1 The Project would generate GHG emissions from mobile
and operational sources, as well as short-term GHG emissions during
construction, but emissions would not exceed the 3,000 MT
CO2e/year threshold. Therefore, this impact would be less than
significant.
No mitigation required Less Than Significant
GHG-2 The Project would not conflict with any applicable plan,
policy, or regulation of an agency that has been adopted for the
purpose of reducing GHG emissions. Therefore, this impact would be
less than significant.
No mitigation required Less Than Significant
Hazards and Hazardous Materials
HAZ-1 The Project would not create a hazard to the public or the
environment through the routine transport, use, or disposal of
hazardous materials. Compliance with local, state, and federal
regulations would ensure that this impact would be less than
significant.
No mitigation required Less Than Significant
HAZ-2 Construction and operation of the Project could potentially
create a hazard to the public or the environment through reasonably
foreseeable upset and accidental conditions involving the release of
hazardous materials into the environment associated with past uses of
the site and demolition of existing buildings. However, compliance
MM HAZ-1: Prior to the start of
construction, the contractor shall conduct a
comprehensive survey of lead based paint
(LBP) and asbestos containing materials
(ACM). If such hazardous materials are
Less Than Significant
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-20 Airport Park Expansion Project
Final EIR – January 2018
with all applicable regulations and implementation of mitigation
would reduce impacts to less than significant.
found to be present, the contractor shall
follow all applicable local, state and federal
regulations, including compliance with
SCAQMD Rule 1403 as well as best
management practices related to the
treatment, handling, and disposal of LBP and
ACM.
MM HAZ-2: Prior to the start of
excavation or grading in areas of known soils
contamination, the construction contractor
shall submit a Soils Management Plan and a
Transportation Plan to the appropriate
cleanup agency (e.g., Los Angeles Regional
Water Quality Control Board [LARWQCB],
Department of Toxic Substances Control
[DTSC], Santa Monica Fire Department
[SMFD]) for review and approval. The Soils
Management Plan and Transportation Plan
shall include the following tasks.
Soils Management Plan
Affected soils shall be either directly loaded
into awaiting trucks for immediate offsite
disposal or temporarily stockpiled on plastic
sheeting prior to load-out and offsite
disposal. If temporarily stockpiled, soil
removed from the excavations shall be
placed next to or as close as possible to the
excavation from which it came.
Prior to load-out, the construction contractor
shall prepare waste profiles and example
waste manifests for approval by the receiving
facilities. Soil and material segregation,
stockpile handling, truck loading, and storm
water management practices shall be
followed during the remedial action
according to the following.
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-21
Final EIR – January 2018
Soil and Material Segregation
Overburden soils shall be screened with an
organic vapor analyzer (OVA) in accordance
with South Coast Air Quality Management
District (SCAQMD) Rule 1166. Any
affected soils shall be segregated and
disposed of in accordance with federal, state,
and local regulations.
Stockpile Management
Any stockpiled soils for load-out shall be
segregated by waste classification:
• Nonhazardous waste.
• Volatile Organic Compound (VOC)-
contaminated nonhazardous waste with
OVA readings greater than 50 parts per
million (ppm) but less than 1,000 ppm.
• VOC-contaminated nonhazardous waste
with OVA readings of 1,000 ppm or
greater. These soils shall be immediately
sprayed with water or suppressant and
placed in a sealed container (roll-off bin)
or directly loaded into a suitable
transport truck, moistened with water,
and covered with a tarp for offsite
transportation to the appropriate disposal
facility, as specified in the SCAQMD Rule
1166 Mitigation Plan.
The temporary stockpiles containing affected
soils shall be managed as follows:
• The temporary stockpiles for non-VOC
contaminants shall be placed on plastic
sheeting and kept moist during working
hours and covered with plastic sheeting
at the end of the day to control dust.
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-22 Airport Park Expansion Project
Final EIR – January 2018
• The VOC-contaminated stockpiles shall
be placed on plastic sheeting and
immediately covered with plastic
sheeting. The edges of the plastic shall
have an overlap of at least 24 inches. The
plastic shall be secured at the base of the
stockpile and along the seams of
overlapping plastic sheeting with
sandbags or equivalent means. The
stockpiles shall remain covered until
load-out.
• Daily inspections of the stockpiles shall
be conducted to verify the integrity of the
stockpile covers. Any gaps, tears, or other
deficiencies shall be corrected
immediately. Daily records shall be kept
of stockpile inspections and any repairs
made.
• If necessary, commercial vapor
suppressants and sealants shall be
prepared and applied to VOC-
contaminated soil in accordance with the
manufacturer’s recommendations.
• During stockpile generation and removal,
only the working face of the stockpile
shall be uncovered.
Decontamination Methods and Procedures
Each piece of equipment used for the
excavation of affected soils shall have a
clean-out bucket or continuous edge across
the cutting face of its bucket. No excavation
of affected soil shall be permitted with
equipment utilizing teeth across the cutting
edge of its bucket.
Entry to the contaminated areas (i.e., work
exclusion zones) shall be limited to avoid
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-23
Final EIR – January 2018
unnecessary exposure and related transfer of
contaminants. In unavoidable circumstances,
any equipment or truck(s) that come into
direct contact with affected soil shall be
decontaminated to prevent the onsite and
offsite distribution of contaminated soil. The
decontamination shall be conducted within a
designated area by brushing off equipment
surfaces onto plastic sheeting. Trucks shall
be visually inspected before leaving the site,
and any dirt adhering to the exterior surfaces
shall be brushed off and collected on plastic
sheeting. The storage bins or beds of the
trucks shall be inspected to ensure the loads
are properly covered and secured. Excavation
equipment surfaces shall also be brushed off
prior to removing the equipment from
contaminated areas.
Movement of affected soils from the
excavation area to temporary stockpiles shall
be conducted using enclosed transfer trucks,
if possible. If affected soils must be moved
within an open receptacle (e.g., loader
bucket), the travel path for the loader shall be
scraped following this activity, with scraped
soils placed in the temporary stockpile for
load-out.
Sampling equipment that comes into direct
contact with potentially contaminated soil or
water shall be decontaminated to assure the
quality of samples collected and/or to avoid
cross-contamination. Disposable sampling
equipment intended for one-time use shall
not be decontaminated, but shall be packaged
for appropriate offsite disposal.
Decontamination shall occur prior to and
after each designated use of a piece of
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-24 Airport Park Expansion Project
Final EIR – January 2018
sampling equipment, using the following
procedures:
• Nonphosphate detergent and tap-water
wash, using a brush if necessary.
• Tap-water rinse.
• Initial deionized/distilled water rinse.
• Final deionized/distilled water rinse.
Truck Loading
Trucks may be loaded directly from the
excavation or temporary stockpile based on
truck availability and excavation logistics.
Trucks shall be routed and stockpile areas
shall be located so as to avoid having trucks
pass through impacted areas. The truckloads
shall be wetted and tarped prior to exiting the
site. All soil hauled from the site shall
comply with the following:
• Materials shall be transported to a Class
II landfill in accordance with applicable
rules and regulations for the handling
and disposal of hazardous materials. If
contamination in the soils is at or above
regulatory levels, the Department of
Toxic Substances Control (DTSC) shall
be contacted and notified to determine
appropriate action.
• No excavated material shall extend above
the sides or rear of the truck/trailer.
• Trucks/trailers carrying affected soils
shall be completely tarped/covered to
prevent particulate emissions to the
atmosphere. Prior to covering/tarping,
the surface of the loaded soil shall be
moistened.
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-25
Final EIR – January 2018
• The exterior of the trucks/trailers shall be
cleaned off prior to leaving the site to
eliminate tracking of material offsite.
Storm Water Management
The good housekeeping practices prescribed
in the City’s Urban Runoff Mitigation Plan
(Municipal Code Section 7.10.060) shall be
implemented during soil excavation activities
to contain and control storm water runoff that
might convey contaminated or excessive
sediments. If rainfall is expected, the areas
around open excavations shall be graded and
bermed to prevent storm water from flowing
into the excavation. Any standing water that
collects in the bottom of the excavations
shall be removed and handled in accordance
with federal, state, and local regulations. The
water shall be sampled and analyzed either as
standing water in the excavation or following
containment in a temporary above-ground
storage tank. Depending on the volume of
water and the sampling results, options for
handling the standing water could include:
• Pumping the standing water into
temporary above-ground storage tanks
for reuse onsite for dust suppression.
• Pumping the standing water through
filters and a carbon adsorption filter (if
required based on analytical results)
prior to discharge to a storm drain,
subject to approval by the City of Santa
Monica Water Resources Protection
Programs Division.
• Pumping the standing water into vacuum
trucks for transport and disposal at a
recycling facility.
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-26 Airport Park Expansion Project
Final EIR – January 2018
Transportation Plan
All affected soils shall be transported offsite
for lawful management and disposal. Prior to
load-out, the construction contractor shall
prepare waste profiles for the receiving
facility using analytical data from the
previous environmental site assessment.
On-Site Soils Remediation Plan
If remediation for contaminated soils
remaining on site is required, all remediation
activities shall be accomplished in a manner
that reduces risk to below applicable
standards and shall be completed prior to
opening the park to the public. Closure report
or other reports regarding investigation
and/or remediation activities regarding
contaminated soil shall be submitted to
DTSC for review and approval. Approved
reports that document the successful
completion of required remediation activities
for contaminated soils shall be submitted to
the DTSC prior to opening the park to the
public.
HAZ-3 Short-term construction activities and operation of the
Project could potentially emit hazardous emissions or handle
hazardous materials, substances, or waste within one-quarter mile of a
school. However, compliance with local, state, and federal regulations
and implementation of mitigation would reduce impacts to less than
significant.
Refer to Mitigation Measures MM HAZ-1
and MM HAZ-2 above.
Less Than Significant
HAZ-4 The Project is located within the SMO AIA and could
potentially result in an increased risk of safety hazard for people
recreating or working at the Project site. However, compliance with
federal, state, and County regulations regarding the construction of
structures within navigable air space would ensure that this impact
would be less than significant.
No mitigation required Less Than Significant
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-27
Final EIR – January 2018
HAZ-5 Construction of the Project would temporarily restrict access
to Donald Douglas Loop South. With implementation of a
Construction Management Plan to maintain access, impacts would be
less than significant.
No mitigation required Less Than Significant
Land Use and Planning
LU-1 The Project would be substantially consistent with the goals
and policies contained within the City’s General Plan, Zoning
Ordinance, and applicable federal, state, and regional plans, including
those that govern airport land uses. Therefore, impacts would be less
than significant.
No mitigation required Less Than Significant
Noise
NOI-1 Construction of the Project would result in a temporary
increase in ambient noise levels in the Project vicinity. The Project
would be required to comply with SMMC regulations related to noise
reduction. With mitigation, construction noise impacts would be
reduced to less than significant when compared to City of Santa
Monica thresholds, but would remain significant and unavoidable
when compared to City of Los Angeles thresholds.
MM NOI-1: A Construction Noise
Management Plan shall be implemented
during Project construction. The Plan would
address noise and vibration impacts and
outline measures that would be used to
reduce impacts. Measures would include:
• To the extent that they exceed the
applicable construction noise limits,
excavation, foundation-laying, and
conditioning activities shall be restricted
to between the hours of 10:00 AM and
3:00 PM, Monday through Friday, in
accordance with Section 4.12.110(d) of
the Santa Monica Municipal Code.
• The construction contracts shall require
implementation of the following
construction best management practices
(BMPs) by all construction contractors
and subcontractors working in or around
the Project site to reduce construction
noise levels:
o Contractors and subcontractors shall
ensure that construction equipment is
Significant and Unavoidable
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-28 Airport Park Expansion Project
Final EIR – January 2018
properly muffled according to
manufactures specifications or as
required by the City’s Department of
Building and Safety, whichever is the
more stringent.
o Contractors and subcontractors shall
place noise-generating construction
equipment and locate construction
staging areas away from sensitive
uses, where feasible, to the
satisfaction of the Department of
Building and Safety.
o Contractors and subcontractors shall
implement noise attenuation
measures which may include, but are
not limited to, noise barriers or noise
blankets to the satisfaction of the
City’s Department of Building and
Safety.
• Contracts with its construction
contractors and subcontractors shall
include the requirement that construction
staging areas, construction worker
parking and the operation of earthmoving
equipment within the project site, are
located as far away from vibration- and
noise-sensitive sites as possible. Contract
provisions incorporating the above
requirements shall be included as part of
the project’s construction documents.
• Contract specifications shall instruct that
heavily loaded trucks used during
construction shall be routed away from
residential streets to the extent possible.
Contract specifications shall be included
in the Project’s construction documents.
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-29
Final EIR – January 2018
NOI-2 Construction of the Project would require the use of
equipment that would temporarily generate ground-borne vibration.
Ground-borne vibration would not occur at levels that would expose
sensitive receptors to excess construction vibration or potentially
damage nearby buildings. Impacts would be less than significant.
No mitigation required Less Than Significant
NOI-3 Operation of the Project could result in increased traffic noise.
The Project would also increase noise generated at Airport Park from
sporting events and crowds. However, operational impacts from
increased noise levels would be less than significant.
No mitigation required Less Than Significant
NOI-4 The Project would introduce new recreational land uses and
visitors to an area within the SMO AIA and could expose visitors and
park goers to excessive airport noise levels generated by SMO.
However, impacts would be less than significant.
No mitigation required Less Than Significant
Transportation and Traffic
T-1 Construction of the Project would create potentially
significant short-term impacts in the Project vicinity due to traffic
lane and sidewalk closures, transit delays, and disruption of
pedestrian and bicycle circulation, associated with operation of heavy
trucks, demolition of paved surface areas adjacent to Airport Avenue,
construction vehicles, and construction fencing, particularly in
combination with construction traffic generation by nearby
cumulative pending development; impacts would be less than
significant with mitigation.
MM T-1: The City shall prepare, implement
and maintain a Construction Impact
Mitigation Plan for review and approval
prior to issuance of a building permit to
address and manage traffic during
construction and shall be designed to:
• Prevent traffic impacts on the surrounding
street network
• Minimize parking impacts both to public
parking and access to private parking to
the greatest extent practicable
• Ensure safety for both those constructing
the Project and the surrounding
community
• Prevent substantial truck traffic through
residential neighborhoods
• Provide for coordination with adjacent or
nearby construction Projects
Less Than Significant
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-30 Airport Park Expansion Project
Final EIR – January 2018
The Construction Impact Mitigation Plan
shall be subject to review and approval by
the following City departments: Public
Works, Fire, Planning and Community
Development, and Police to ensure that the
Plan has been designed in accordance with
this mitigation measure and meets City
standards. This review shall occur prior to
issuance of grading or building permits. It
shall, at a minimum, include the following:
Ongoing Requirements throughout the
Duration of Construction
• A detailed Construction Impact
Mitigation Plan for work zones shall be
maintained. At a minimum, this shall
include parking and travel lane
configurations; warning, regulatory,
guide, and directional signage; and area
sidewalks, bicycle lanes, and parking
lanes. The plan shall include specific
information regarding the Project’s
construction activities that may disrupt
normal pedestrian and traffic flow and the
measures to address these disruptions.
Such plans shall be reviewed and
approved by the Strategic and
Transportation Planning Division prior to
commencement of construction and
implemented in accordance with this
approval.
• Work within the public right-of-way shall
be performed between 9:00 A.M. and 4:00
P.M. This work includes dirt and
demolition material hauling and
construction material delivery. Work
within the public right-of-way outside of
these hours shall only be allowed after the
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
Airport Park Expansion Project ES-31
Final EIR – January 2018
issuance of an after-hours construction
permit.
• Streets and equipment shall be cleaned in
accordance with established Public Works
Department requirements.
• Trucks shall only travel on a City-
approved construction route. Truck
queuing/staging shall not be allowed on
Santa Monica streets. Limited queuing
may occur on the construction site itself.
• Materials and equipment shall be
minimally visible to the public; the
preferred location for materials is to be
onsite, with a minimum amount of
materials within a work area in the public
right-of-way, subject to a current Use of
Public Property Permit.
• Any requests for work before or after
normal construction hours within the
public right-of-way shall be subject to
review and approval through the After
Hours Permit process administered by the
Building and Safety Division.
• Provision of off-street parking for
construction workers, which may include
the use of a remote location with shuttle
transport to the site, if determined
necessary by the City of Santa Monica.
Project Coordination Elements That Shall Be
Implemented Prior to Commencement of
Construction
• The City shall advise the traveling public
of impending construction activities (e.g.,
information signs, portable message signs,
media listing/notification, and
EXECUTIVE SUMMARY
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts (Continued)
Impacts Mitigation Measures Residual Impacts
ES-32 Airport Park Expansion Project
Final EIR – January 2018
implementation of an approved
Construction Impact Mitigation Plan).
• The City shall provide timely notification
of construction schedules to all affected
agencies (e.g., MTA, Big Blue Bus,
Police Department, Fire Department,
Public Works Department, and Planning
and Community Development
Department) and to all owners and
residential and commercial tenants of
property within a radius of 500 feet.
• The City shall coordinate construction
work with affected agencies in advance of
start of work. Approvals may take up to
two weeks per each submittal.
T-2 The Project would generate new vehicle trips to the existing
street network that would result in an exceedance of the City of Santa
Monica LOS thresholds at three intersections under Approval Year
(2017) Plus Project conditions, at four intersections under Future
Year (2025) Plus Project conditions, and at two street segments under
Existing (2017) ADT No feasible mitigation measures are available to
eliminate these impacts; therefore, the Project would generate
significant and unavoidable impacts on intersections.
No mitigation measures are feasible and/or
desirable due to physical constraints or the
secondary adverse effects of further
increasing vehicle delay at significantly
impacted intersections.
Significant and Unavoidable
T-3 The Project would not exceed thresholds at CMP-designated
intersections and/or freeway segments. The Project would therefore
generate a less than significant impact on regional transportation
facilities.
No mitigation required Less Than Significant
T-4 The proposed realignment of and Project driveway at Donald
Douglas Loop South would not create hazardous conditions for
vehicles, bicyclists, or pedestrians; impacts would be less than
significant.
No mitigation required Less Than Significant
T-5 The Project would not conflict with adopted City plans,
policies, and programs supporting alternative transportation.
Therefore, the Project impacts would be less than significant.
No mitigation required Less Than Significant
EXECUTIVE SUMMARY
Airport Park Expansion Project ES-33
Final EIR – January 2018
Table ES-2. Impact Comparison of Alternatives to the Proposed Project
Comparison to Project
Issue Area Project Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5
Air Quality Less Than Significant Less Greater Less Less Greater
Construction Effects Significant and Unavoidable Less Greater Similar Less Greater
Greenhouse Gas Emissions Less Than Significant Less Greater Less Less Greater
Hazards and Hazardous Materials Less Than Significant with Mitigation Less Similar Similar Less Similar
Land Use and Planning Less Than Significant Less Similar Similar Less Similar
Noise Significant and Unavoidable Less Greater Less Similar Less
Transportation / Traffic Significant and Unavoidable Less Greater Less Less Greater
Project Objectives Met? Yes No No No Partially Partially
EXECUTIVE SUMMARY
Airport Park Expansion Project ES-34
Final EIR – January 2018
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Airport Park Expansion Project i
Final EIR – January 2018
ENVIRONMENTAL IMPACT REPORT
FOR THE
PROPOSED AIRPORT PARK EXPANSION PROJECT
FOR THE CITY OF SANTA MONICA, CA
TABLE OF CONTENTS
SECTION TITLE PAGE
EXECUTIVE SUMMARY .................................................................................................... ES-1
LIST OF ACRONYMS AND ABBREVIATIONS ................................................................... ix
1.0 INTRODUCTION.......................................................................................................... 1-1
1.1 OVERVIEW ............................................................................................................ 1-1
1.2 PROJECT BACKGROUND ........................................................................................ 1-1
1.3 REGULATORY FRAMEWORK .................................................................................. 1-3
1.4 EIR PURPOSE AND LEGAL AUTHORITY ................................................................. 1-5
1.5 PUBLIC REVIEW AND COMMENTS ......................................................................... 1-6
1.6 SCOPE OF THE EIR ................................................................................................ 1-6
1.7 REQUIRED APPROVALS ......................................................................................... 1-7
1.8 AREAS OF KNOWN PUBLIC CONTROVERSY ........................................................... 1-7
1.9 ORGANIZATION OF THE EIR .................................................................................. 1-8
2.0 PROJECT DESCRIPTION .......................................................................................... 2-1
2.1 INTRODUCTION ..................................................................................................... 2-1
2.2 EXISTING PROJECT SITE CHARACTERISTICS .......................................................... 2-2
2.2.1 Project Location & Surrounding Land Uses ............................................ 2-2
2.2.2 Existing Site Conditions .......................................................................... 2-4
2.2.3 Land Use Designations ............................................................................ 2-8
2.2.4 Existing Airport Operations ................................................................... 2-10
2.3 PROJECT OBJECTIVES .......................................................................................... 2-12
2.4 PROJECT OVERVIEW ........................................................................................... 2-13
2.4.1 Proposed Recreational Amenities .......................................................... 2-13
2.4.2 Acoustical Berm and Overlook .............................................................. 2-18
2.4.3 Access and Parking ................................................................................ 2-21
2.4.4 Landscaping ........................................................................................... 2-22
2.4.5 Lighting .................................................................................................. 2-26
2.4.6 Sustainability Features ........................................................................... 2-26
2.4.7 Project Operation ................................................................................... 2-27
2.5 CONSTRUCTION ACTIVITIES ................................................................................ 2-27
2.5.1 Phasing ................................................................................................... 2-27
2.5.2 Demolition ............................................................................................. 2-28
2.5.3 Excavation.............................................................................................. 2-28
2.5.4 Construction ........................................................................................... 2-29
2.5.5 Construction Staffing ............................................................................. 2-29
TABLE OF CONTENTS
SECTION TITLE PAGE
ii Airport Park Expansion Project
Final EIR – January 2018
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION
MEASURES ................................................................................................................ 3.0-1
3.0.1 Introduction ..................................................................................................1
3.0.2 Cumulative Impacts Methodology ...............................................................3
3.1 AIR QUALITY ..................................................................................................... 3.1-1
3.1.1 Environmental Setting .......................................................................... 3.1-1
3.1.2 Regulatory Framework ....................................................................... 3.1-11
3.1.3 Impact Assessment and Methodology ................................................ 3.1-19
3.1.4 Project Impacts and Mitigation Measures........................................... 3.1-24
3.2 CONSTRUCTION EFFECTS ................................................................................... 3.2-1
3.2.1 Environmental Setting .......................................................................... 3.2-1
3.2.2 Regulatory Framework ......................................................................... 3.2-6
3.2.3 Impact Assessment and Methodology .................................................. 3.2-7
3.2.4 Project Impacts and Mitigation Measures............................................. 3.2-7
3.3 GREENHOUSE GAS EMISSIONS ........................................................................... 3.3-1
3.3.1 Environmental Setting .......................................................................... 3.3-2
3.3.2 Regulatory Framework ......................................................................... 3.3-7
3.3.3 Impact Assessment and Methodology ................................................ 3.3-18
3.3.4 Project Impacts and Mitigation Measures........................................... 3.3-22
3.4 HAZARDS AND HAZARDOUS MATERIALS ........................................................... 3.4-1
3.4.1 Environmental Setting .......................................................................... 3.4-2
3.4.2 Regulatory Framework ....................................................................... 3.4-15
3.4.3 Impact Assessment and Methodology ................................................ 3.4-24
3.4.4 Project Impacts and Mitigation Measures........................................... 3.4-26
3.5 LAND USE AND PLANNING ................................................................................. 3.5-1
3.5.1 Environmental Setting .......................................................................... 3.5-1
3.5.2 Regulatory Framework ....................................................................... 3.5-11
3.5.3 Impact Assessment and Methodology ................................................ 3.5-18
3.5.4 Project Impacts and Mitigation Measures........................................... 3.5-20
3.6 NOISE ................................................................................................................. 3.6-1
3.6.1 Fundamentals of Sound and Environmental Noise ............................... 3.6-1
3.6.2 Existing Setting ..................................................................................... 3.6-6
3.6.3 Regulatory Framework ....................................................................... 3.6-10
3.6.4 Impact Assessment and Methodology ................................................ 3.6-19
3.6.5 Project Impacts and Mitigation Measures........................................... 3.6-25
3.7 TRANSPORTATION AND TRAFFIC ........................................................................ 3.7-1
3.7.1 Environmental Setting .......................................................................... 3.7-1
3.7.2 Regulatory Framework ....................................................................... 3.7-21
3.7.3 Impact Assessment and Methodology ................................................ 3.7-29
3.7.4 Project Impacts and Mitigation Measures........................................... 3.7-43
4.0 OTHER CEQA CONSIDERATIONS ......................................................................... 4-1
4.1 UNAVOIDABLE SIGNIFICANT ENVIRONMENTAL EFFECTS ..................................... 4-1
TABLE OF CONTENTS
SECTION TITLE PAGE
Airport Park Expansion Project iii
Final EIR – January 2018
4.2 IRREVERSIBLE ENVIRONMENTAL CHANGES .......................................................... 4-2
4.3 GROWTH INDUCING IMPACTS ............................................................................... 4-4
4.3.1 Removal of Obstacles to Growth ............................................................. 4-5
4.4 EFFECTS FOUND NOT TO BE SIGNIFICANT ............................................................ 4-6
5.0 ALTERNATIVES ANALYSIS ..................................................................................... 5-1
5.1 INTRODUCTION ..................................................................................................... 5-1
5.2 PROJECT OBJECTIVES ............................................................................................ 5-2
5.3 SUMMARY OF POTENTIALLY SIGNIFICANT AND UNAVOIDABLE PROJECT
IMPACTS................................................................................................................ 5-3
5.4 ALTERNATIVES CONSIDERED BUT DISCARDED ..................................................... 5-5
5.5 ALTERNATIVES ANALYSIS .................................................................................... 5-8
5.5.1 Alternative 1 - No Project/No Build ........................................................ 5-8
5.5.2 Alternative 2 - No Project/Reasonable Foreseeable Development
(Non-Recreational Use) ......................................................................... 5-10
5.5.3 Alternative 3 - Airport Park Expansion without Fields ......................... 5-29
5.5.4 Alternative 4 - Reduced Project Alternative (East Paved Surface
Area Only) ............................................................................................. 5-44
5.5.5 Alternative 5 - Community Recreation Center Alternative ................... 5-58
5.6 IDENTIFICATION OF ENVIRONMENTALLY SUPERIOR ALTERNATIVE .................... 5-72
6.0 LIST OF PREPARERS ................................................................................................. 6-1
7.0 REFERENCES ............................................................................................................... 7-1
8.0 INTRODUCTION TO THE FINAL EIR .................................................................... 8-1
8.1 PUBLIC REVIEW PROCESS ..................................................................................... 8-1
8.2 CEQA REQUIREMENTS ......................................................................................... 8-1
8.3 USE OF THE FINAL EIR ......................................................................................... 8-1
9.0 RESPONSE TO COMMENTS ..................................................................................... 9-1
10.0 CORRECTIONS AND ADDITIONS ........................................................................ 10-1
11.0 MITIGATION MONITORING AND REPORTING PROGRAM ........................ 11-1
11.1 PURPOSE ............................................................................................................. 11-1
11.2 RESPONSIBILITIES ............................................................................................... 11-1
11.3 MONITORING PROCEDURES................................................................................. 11-2
11.4 MONITORING TABLE ........................................................................................... 11-2
TABLE OF CONTENTS
iv Airport Park Expansion Project
Final EIR – January 2018
LIST OF APPENDICES
A – Notice of Preparation
B – Santa Monica Airport Health Risk Assessment
C – Air Emissions Modeling
D – Hazardous Materials Investigations
E – Project Noise Surveys and Reports
F – Project Transportation and Parking Impact Analyses
G – Comment Letters on the Draft EIR
LIST OF FIGURES
Airport Park Expansion Project v
Final EIR – January 2018
LIST OF FIGURES
NUMBER TITLE PAGE
Figure 2-1. Project Vicinity ................................................................................................... 2-3
Figure 2-2. Project Site ......................................................................................................... 2-5
Figure 2-3. Conceptual Site Plan ........................................................................................ 2-14
Figure 2-4. Cross-Sections at East End of Park .................................................................. 2-15
Figure 2-5. Cross Sections at Central Section of Park ........................................................ 2-19
Figure 2-6. Cross Sections at West End of Park ................................................................. 2-20
Figure 2-7. Conceptual Hydrozone Plan ............................................................................. 2-23
Figure 2-8. Conceptual Landscape Plan .............................................................................. 2-24
Figure 3.0-1. Cumulative Projects in the Vicinity of the Project Site ........................................16
Figure 3.4-1. Santa Monica Airport Influence Area and Runway Protection Zones ............ 3.4-6
Figure 3.5-1. Existing Land Use ........................................................................................... 3.5-6
Figure 3.5-2. Santa Monica Airport Influence Area ........................................................... 3.5-10
Figure 3.6-1. Airport Noise Contours and Noise Monitoring Locations .............................. 3.6-8
Figure 3.7-1. Existing Bus and Bike Routes and Bike Facilities .......................................... 3.7-3
Figure 3.7-2. Existing Levels of Service ............................................................................. 3.7-16
Figure 3.7-3. Proposed Project Approval Year (2017) Level of Service ............................ 3.7-17
Figure 3.7-4. Proposed Project Future Year (2025) Level of Service ................................ 3.7-49
Figure 3.7-5. Airport Park Transportation .......................................................................... 3.7-52
Figure 3.7-6. Airport Avenue Improvement Project ........................................................... 3.7-67
Figure 5-1. Alternative 2 - No Project/Reasonable Foreseeable Alternative ...................... 5-14
Figure 5-2. Alternative 3 - Airport Park Expansion without Fields Alternative ................. 5-31
Figure 5-3. Alternative 4 - Reduced Project Alternative (East Parcel Only) ...................... 5-46
Figure 5-4. Alternative 5 - Community Recreation Center Alternative .............................. 5-60
LIST OF TABLES
vi Airport Park Expansion Project
Final EIR – January 2018
LIST OF TABLES
NUMBER TITLE PAGE
Table ES-1. Project Impacts, Mitigation Measures, and Residual Impacts .........................ES-7
Table ES-2. Impact Comparison of Alternatives to the Proposed Project .........................ES-33
Table 2-1. Non-Aviation Uses South of Airport Avenue in Project Vicinity ...................... 2-4
Table 2-2. Existing Uses by Assessor Parcel Numbers ....................................................... 2-6
Table 2-3. Proposed Development Program ...................................................................... 2-16
Table 2-4. Proposed Hydrozones ....................................................................................... 2-25
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of
Santa Monica ..........................................................................................................5
Table 3.1-1. South Coast Air Basin Attainment Status for Criteria Pollutants ................... 3.1-8
Table 3.1-2. Maximum Estimated Daily Construction Emissions for the Project by
Construction Phase (pounds/day) .................................................................. 3.1-27
Table 3.1-3. Maximum Estimated Daily Construction Emissions for the Project
compared to SCAQMD Regional Thresholds of Significance
(pounds/day) .................................................................................................. 3.1-28
Table 3.1-4. Maximum Estimated Operational Emissions for the Project compared to
SCAQMD Regional Thresholds of Significance (pounds/day) .................... 3.1-28
Table 3.1-5. Maximum Estimated Daily Construction Emissions for the Project
compared to Localized Significance Thresholds (pounds/day) .................... 3.1-30
Table 3.2-1. Development in the Immediate Project Vicinity ............................................. 3.2-2
Table 3.3-1. GHG Emissions from Construction of the Project ........................................ 3.3-22
Table 3.3-2. Combined Annual GHG Emissions for the Project ....................................... 3.3-22
Table 3.3-3. LUCE, Sustainable City Plan, and Climate Action Plan Policy
Consistency Summary ................................................................................... 3.3-24
Table 3.4-1. Previous Site Use ............................................................................................. 3.4-7
Table 3.4-2. Summary of Database Search for Project Site .............................................. 3.4-13
Table 3.4-1. Regulatory Database Search Summary ......................................................... 3.4-16
Table 3.5-1. Non-Aviation Uses on SMO Property in the Immediate Project Vicinity ...... 3.5-4
Table 3.5-2. Project Site Land Use Setting .......................................................................... 3.5-9
Table 3.5-3. Consistency with 2010 LUCE Policies ......................................................... 3.5-22
Table 3.5-4. Other General Plan Policies .......................................................................... 3.5-27
Table 3.5-5 SCAG RTP/SCS Policy Consistency Table .................................................. 3.5-30
Table 3.5-6. CLUP Policy Consistency Table ................................................................... 3.5-31
Table 3.6-1. Representative Noise Levels ........................................................................... 3.6-2
Table 3.6-2. Human Response to Different Levels of Ground-borne Vibration ................. 3.6-5
Table 3.6-3. Vibration Thresholds for Potential Structural Damage ................................... 3.6-5
Table 3.6-4. Existing Noise Levels Measured in the Project Vicinity (in dBA) ................. 3.6-7
Table 3.6-5. City of Santa Monica Land Use/Noise Compatibility Matrix ....................... 3.6-14
Table 3.6-6. City of Los Angeles Land Use/Noise Compatibility Matrix ......................... 3.6-19
Table 3.6-7. Interior and Exterior Noise Thresholds in the City of Santa Monica ............ 3.6-21
Table 3.6-8. Noise Ranges of Typical Construction Equipment ....................................... 3.6-22
Table 3.6-9. Estimated Peak Construction Outdoor Noise Levels at Sensitive
Receptors ....................................................................................................... 3.6-27
Table 3.6-10. Estimated Peak Construction Vibration Levels at Sensitive Receptors ........ 3.6-30
LIST OF TABLES
LIST OF TABLES
(continued)
TABLE TITLE PAGE
Airport Park Expansion Project vii
Final EIR – January 2018
Table 3.6-11. Noise Increase from Project-Related Traffic at Study Intersections
During the P.M. Peak Hour ........................................................................... 3.6-33
Table 3.6-12. Noise Impacts from Project-related Traffic on Neighborhood Street
Segments ....................................................................................................... 3.6-34
Table 3.7-1. Parking Available in the Project Vicinity ........................................................ 3.7-9
Table 3.7-2. Pedestrian and Bicycle Traffic in the Project Vicinity during Weekday
Peak A.M. Hours (7:30-9:15 A.M.) .............................................................. 3.7-13
Table 3.7-3. Level of Service Criteria for Signalized Intersections .................................. 3.7-15
Table 3.7-4. Existing Intersection Levels of Service (2017) (City of Santa Monica
Analysis Methodology - Highway Capacity Manual [HCM]) ...................... 3.7-18
Table 3.7-5. Existing Intersection Levels of Service (2017) (City of Los Angeles
Analysis Methodology - Critical Movement Analysis [CMA]) .................... 3.7-19
Table 3.7-6. City of Santa Monica and Los Angeles Significant Impact Criteria for
Intersections ................................................................................................... 3.7-32
Table 3.7-7. City of Santa Monica Impact Criteria for Collector, Feeder, and Local
Street Segments ............................................................................................. 3.7-34
Table 3.7-8. Project Trip Generation ................................................................................. 3.7-40
Table 3.7-9. Analysis of Project Impacts under Approval Year (2017) Conditions
(City of Santa Monica Analysis Methodology - HCM) ................................ 3.7-50
Table 3.7-10. Analysis of Project Impacts under Approval Year (2017) Conditions
(City of Los Angeles Analysis Methodology - CMA) .................................. 3.7-51
Table 3.7-11. Analysis of Project Impacts under Future Year (2025) Conditions (City
of Santa Monica Analysis Methodology - HCM) ......................................... 3.7-53
Table 3.7-12. Analysis of Project Impacts under Future Year (2025) Conditions (City
of Los Angeles Analysis Methodology - CMA) ........................................... 3.7-54
Table 3.7-13. Approval Year (2017) Street Segment Impact Analysis ............................... 3.7-55
Table 3.7-14. Estimated Project-related Transit Ridership (Transit Persons per Peak
Hour) ............................................................................................................. 3.7-56
Table 5-1. Permitted Uses Under Institutional/Public Lands Land Use Designation ....... 5-11
Table 5-2. Assumed Development of the West and East Paved Surface Areas
Under Alternative 2 Following Closure of SMO in 2028 ................................ 5-12
Table 5-3. Maximum Estimated Daily Construction Emissions for Alternative 2
compared to SCAQMD Regional Thresholds of Significance
(pounds/day) ..................................................................................................... 5-15
Table 5-4. Maximum Estimated Operational Emissions for Alternative 2 compared
to SCAQMD Regional Thresholds of Significance (pounds/day) ................... 5-15
Table 5-5. Maximum Estimated Daily Construction Emissions for Alternative 2
compared to Localized Significance Thresholds (pounds/day) ....................... 5-18
Table 5-6. GHG Emissions from Construction of Alternative 2 (MT/yr) ......................... 5-20
Table 5-7. Combined Annual GHG Emissions for Alternative 2 (MT/yr) ........................ 5-20
Table 5-8. Alternative 2 Annual GHG Emissions Compared to SCAQMD Tier 4
Threshold .......................................................................................................... 5-21
Table 5-9. Alternative 3 Passive Recreational Uses to Replace Project Features ............. 5-30
LIST OF TABLES
LIST OF TABLES
(continued)
NUMBER TITLE PAGE
viii Airport Park Expansion Project
Final EIR – January 2018
Table 5-10. Maximum Estimated Daily Construction Emissions for Alternative 3
compared to SCAQMD Regional Thresholds of Significance
(pounds/day) ..................................................................................................... 5-32
Table 5-11. Maximum Estimated Operational Emissions for Alternative 3 compared
to SCAQMD Regional Thresholds of Significance (pounds/day) ................... 5-33
Table 5-12. Maximum Estimated Daily Construction Emissions for Alternative 3
compared to Localized Significance Thresholds (pounds/day) ....................... 5-34
Table 5-13. GHG Emissions from Construction of Alternative 3 (MT/yr) ......................... 5-37
Table 5-14. Combined Annual GHG Emissions for Alternative 3 (MT/yr) ........................ 5-37
Table 5-15. Maximum Estimated Daily Construction Emissions for Alternative 4
compared to SCAQMD Regional Thresholds of Significance
(pounds/day) ..................................................................................................... 5-47
Table 5-16. Maximum Estimated Operational Emissions for Alternative 4 compared
to SCAQMD Regional Thresholds of Significance (pounds/day) ................... 5-47
Table 5-17. Maximum Estimated Daily Construction Emissions for Alternative 4
compared to Localized Significance Thresholds (pounds/day) ....................... 5-48
Table 5-18. GHG Emissions from Construction of Alternative 4 (MT/yr) ......................... 5-51
Table 5-19. Combined Annual GHG Emissions for Alternative 4 (MT/yr) ........................ 5-51
Table 5-20. Maximum Estimated Daily Construction Emissions for Alternative 5
compared to SCAQMD Regional Thresholds of Significance
(pounds/day) ..................................................................................................... 5-61
Table 5-21. Maximum Estimated Operational Emissions for Alternative 5 compared
to SCAQMD Regional Thresholds of Significance (pounds/day) ................... 5-61
Table 5-22. Maximum Estimated Daily Construction Emissions for Alternative 5
compared to Localized Significance Thresholds (pounds/day) ....................... 5-62
Table 5-23. GHG Emissions from Construction of Alternative 5 (MT/yr) ......................... 5-65
Table 5-24. Combined Annual GHG Emissions for Alternative 5 (MT/yr) ........................ 5-65
Table 5-25. Impact Comparison of Alternatives to the Proposed Project ........................... 5-73
Table 5-26. Maximum Daily Construction Emissions for Alternatives (lbs/day) ............... 5-74
Table 5-27. Maximum Operational Emissions from Alternatives (lbs/day) ....................... 5-75
Table 5-28. Trip Generation Comparison for Alternatives .................................................. 5-76
Table 9-1. Commenters on the Draft EIR ............................................................................ 9-1
Table 11-1. Mitigation Monitoring and Reporting Program ............................................... 11-3
LIST OF ACRONYMS AND ABBREVIATIONS
Airport Park Expansion Project ix
Final EIR – January 2018
LIST OF ACRONYMS AND ABBREVIATIONS
A.M. Ante meridiem (period from midnight to noon)
AAQS ambient air quality standards
AB Assembly Bill
ACM asbestos-containing materials
ADA Americans with Disabilities Act
ADT average daily trips
AF acre-feet
AFY acre feet per year
AHERA Asbestos Hazard Emergency Response Act
AIA Airport Influence Area
ALUC Los Angeles County Airport Land Use Commission
ALUP Airport Land Use Plan
Amec Foster Wheeler Amec Foster Wheeler Environment & Infrastructure, Inc.
APN Assessor’s Parcel Number
APS Alternative Planning Strategy
APU Auxiliary Power Unit
AQMP Air Quality Monitoring Plan
ARB Air Resources Board
asl Above Sea Level
AST Aboveground storage tank
AVR Average Vehicle Ridership
Basin South Coast Air Basin
bgs below ground surface
BMP best management practice
C&D construction and demolition
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CalEEMod California Emission Estimator Model
Cal-EMA California Emergency Management Agency
CalEPA California Environmental Protection Agency
CALGreen California’s Green Building Standard Code
CalRecycle California Department of Resources Recycling and Recovery
Caltrans California Department of Transportation
CAP Clean Air Plan
CARB California Air Resources Board
CAS California Adaptation Strategy
CBC California Building Code
CCAA California Clean Air Act
CCR California Code of Regulations
CEQA California Environmental Quality Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS Comprehensive Environmental Response, Compensation, and Liability
Information System
CFC chlorofluorocarbon
CFR Code of Federal Regulations
CGS California Geological Survey
CH4 methane
LIST OF ACRONYMS AND ABBREVIATIONS
x Airport Park Expansion Project
Final EIR – January 2018
CHHSL California Human Health Screening Level
CHP California Highway Patrol
CISS Coastal Interceptor Sewer System
City City of Santa Monica
CIWMB California Integrated Waste Management Board
CLUP Comprehensive Land Use Plan
CMA Critical Movement Analysis
CMP Congestion Management Program
CNEL Community Noise Equivalent Level
CO carbon monoxide
CO2 carbon dioxide
CO2e Carbon Dioxide Equivalents
COC Contaminants of Concern
CPS Cleanup Program Sites
CTC California Transportation Commission
CUPA Certified Unified Program Agency
cy cubic yard
dB decibel
DNL Day/Night Noise Level
DoD Department of Defense
DOT Department of Transportation
DPM diesel particulate matter
DTSC Department of Toxic Substance Control
DU Dwelling Unit
EDR Environmental Data Resources
EIR Environmental Impact Report
EPA Environmental Protection Agency
ESA Environmental Site Assessment
Expo LRT Expo Light Rail Transit line
FAA Federal Aviation Administration
FAR floor area ratio
FBO fixed-base operator
FEMA Federal Emergency Management Agency
FHWA Federal Highway Administration’s
FIFA International Federation of Association Football
FTIP Federal Transportation Improvement Program
g/L grams per liter
GCF Green Climate Fund
GHG greenhouse gas
GJ Gigajoules
GPD gallons per day
Gt CO2e billions of metric tons
HCM Highway Capacity Manual
HHRA Human Health Risk Assessment
HI hazard index
HMMP Hazardous Materials Management Plans
HMRRP Hazardous Materials Reporting and Response Planning
HQTA High Quality Transit Areas
HRA Health Risk Assessment
LIST OF ACRONYMS AND ABBREVIATIONS
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Final EIR – January 2018
HTP Hyperion Treatment Plant
HVAC heating, ventilation, and air conditioning
I- Interstate
in/sec inches per second
IPCC Intergovernmental Panel on Climate Change
ITE Institute of Transportation Engineers
KSF thousand square feet
LACFD Los Angeles County Fire Department
LADOT Los Angeles Department of Transportation
LAMC Los Angeles Municipal Code
LARWQCB Los Angeles Regional Water Quality Control Board
LBP Lead-Based Paints
Ldn Day-Night Average Noise Level
LEED Leadership in Energy and Environmental Design
Leq Equivalent Noise Level
LHMP Local Hazard Mitigation Plan
LID low-impact development
LOS Level of Service
LRTP Long Range Transportation Plan
LST localized significance threshold
LUCE Land Use and Circulation Element
LUFT Leaking Underground Fuel Tanks
LUST leaking underground storage tank
Metro Los Angeles Metropolitan Transportation Authority
mgd million gallons per day
MICR maximum individual cancer risk
MM Mitigation Measure
MPD Multiple Property Documentation
mph miles per hour
MPO metropolitan planning organization
MT CO2e metric tons
MTBE methyl tertiary butyl ether
MWD Metropolitan Water District of Southern California
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NESHAP National Emissions Standard for Hazardous Air Pollutants
NO2 nitrogen dioxide
NOI Notice of Intent
NOP Notice of Preparation
NOx Nitrogen Oxides
NPDES National Pollutant Discharge Elimination System
O3 ozone
OEHHA Office of Environmental Health Hazard Assessment
OES Office of Emergency Services
OPR Office of Planning and Research
OS Parks and Open Space Zone
OSE Office of Sustainability and the Environment
OSHA Occupational Safety and Health Administration
LIST OF ACRONYMS AND ABBREVIATIONS
xii Airport Park Expansion Project
Final EIR – January 2018
OVA organic vapor analyzer
P.M. post meridiem (the period from 12 noon until 12 midnight)
Pb lead
PCH Pacific Coast Highway
PL Public Lands
PM10 particulate matter equal to or less than 10 microns in diameter
PM2.5 particulate matter equal to or less than 2.5 microns in diameter
ppb parts per billion
ppm Parts per million
PWD Public Works Department
PWWF Peak Wet Weather Flow
RCRA Resource Conservation and Recovery Act
REC recognized environmental conditions
ROG reactive organic gases
RPZ Runway Protection Zones
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SB Senate Bill
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCE Southern California Edison
SCS Sustainable Communities Strategy
SENEL Single Event Noise Exposure Level
sf square foot/feet
SHMP State of California Multi-Hazard Mitigation Plan
SIP State Implementation Plan
SITES The Sustainable SITES Initiative
SLIC Spills, Leaks, Investigations, and Cleanups
SMC Santa Monica College
SMFD Santa Monica Fire Department
SMGB Santa Monica Groundwater Basin
SMMC Santa Monica Municipal Code
SMMUSD Santa Monica-Malibu Union School District
SMO Santa Monica Municipal Airport
SMPD Santa Monica Police Department
SMURRF Santa Monica Urban Runoff Recycling Facility
SO2 sulfur dioxide
SoCal Gas Southern California Gas Company
SOx sulfur oxides
SRA source receptor area
STIP State Transportation Improvement Program
SWRCB State Water Resources Control Board
TAC Toxic Air Contaminants
TAZ traffic analysis zone
TCE trichloroethylene
TDFM Transportation Demand Forecast Model
TDM Transportation Demand Management
TDS total dissolved solids
Tg CO2e millions of metric tons
LIST OF ACRONYMS AND ABBREVIATIONS
Airport Park Expansion Project xiii
Final EIR – January 2018
TIA Transportation Impact Analysis
TPA Transit Priority Areas
U.S. United States
UCLA University of California, Los Angeles
UNFCCC United Nations Framework Convention on Climate Change
USC United States Code
USGS U.S. Geological Survey
UST underground storage tank
UWMP Urban Water Management Plan
V/C volume-to-capacity ratio
VMT vehicle miles traveled
VOC Volatile Organic Compound
WMP Waste Master Plan
μg/m3 micrograms per cubic meter
LIST OF ACRONYMS AND ABBREVIATIONS
xiv Airport Park Expansion Project
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Airport Park Expansion Project 1-1
Final EIR – January 2018
1.0 INTRODUCTION
1.1 OVERVIEW
This Environmental Impact Report (EIR) evaluates the potential environmental impacts of the
proposed Airport Park Expansion Project (Project) in the City of Santa Monica (City), California.
The EIR was prepared by Amec Foster Wheeler Environment & Infrastructure, Inc. (Amec Foster
Wheeler) in cooperation with City of Santa Monica staff.
The Project site lies on approximately 20 acres of non-aviation land at the southeast corner of
Santa Monica Municipal Airport (SMO) property. This non-aviation land comprises all or a
portion of three parcels that are currently improved with two large paved areas (one of which is
used as a surface parking lot), small administrative office buildings and airplane hangars, Donald
Douglas Loop South, and the existing 8.3-acre Airport Park. The Project site lies along the City
boundary with the City of Los Angeles, within a small portion located in City of Los Angeles.
The Project proposes to expand the existing Airport Park by redeveloping approximately 12 acres
of non-aviation land adjacent to the existing park into new recreational amenities. Two new
International Federation of Association Football (FIFA)-regulation-sized sports fields, a multi-
purpose area, three pickleball courts, a continuous loop pathway, restrooms and concession
buildings, a 120-space parking lot, improved vehicle circulation, and a variety of other recreational
amenities would be included as part of the Project. The Project would largely avoid changes to the
existing Airport Park, although approximately 1.5 acres of the lawn area adjacent to the park’s
south parking lot would be renovated to new lawn area and community garden plots, and the
existing 0.7-acre, 58-space north parking lot would be removed to accommodate various park
amenities. In total, approximately 2.2 acres of the existing park would be renovated by the Project.
1.2 PROJECT BACKGROUND
The City has long envisioned park and recreational uses on non-aviation land at the south side of
SMO. Although expired since 2015, the City’s 1984 Settlement Agreement (1984 Settlement
Agreement) with the Federal Aviation Administration (FAA) approved an Airport Layout Plan
that made available a substantial amount of land on the south side of SMO designated in the layout
plan as “residual land”, including the entirety of the Project site, which could be made available to
the City of other uses compatible with SMO operations. Thus, the land was released from exclusive
aviation use and identified for non-aviation uses (City of Santa Monica 1984). Since that time, the
City has been gradually developing the area south of the airport with non-aviation uses, including
commercial/office, restaurant, event venue, and educational uses, as well as the existing Airport
Park.
1.0 INTRODUCTION
1-2 Airport Park Expansion Project
Final EIR – January 2018
In July 2002, the Final EIR for the Santa Monica Airport Park Project was certified, allowing for
the development of the existing 8.3-acre public Airport Park within SMO property. Located in the
northwest corner at the intersection of Airport Avenue and Bundy Drive, the park site was
designated “residual land” and the development of non-aviation uses was permitted under the
Airport Master Plan and the Airport Layout Plan. Off-site improvements included changes to the
streetscapes of Bundy Drive, Airport Avenue, and the corner of 23rd street (City of Santa Monica
2002).
On March 24, 2015, the City Council heard a presentation by City Staff regarding SMO and future
options for its operations, and the City’s use of the land currently occupied by the SMO (City of
Santa Monica 2015). The City Council unanimously voted to provide direction to City Staff to
develop recreational uses on approximately 12-acres of non-aviation land adjacent to the existing
Airport Park and to do so within three years. On June 18, 2016, a community event was held at the
existing Airport Park, attended by approximately 106 people, in which three park concept schemes
were presented. The three park concepts proposed included a Runway Concept (Option 1), a
Landing Strips Concept (Option 2), and a Flight Path Concept (Option 3). Option 1 involved three
new fields, one at FIFA-regulation size, with 192 net new parking spaces and a new
dropoff/turnaround location at the south. Option 2 also involved three new fields, two at FIFA--
regulation size, with 160 net new parking spaces and a new dropoff/turnaround location at the
south. Option 3 involved two new fields, both at FIFA-regulation size, with 102 net new parking
spaces and a new drop-off/turnaround location at the north.
Prior to the event, City Staff sent email announcements and reminders to the City's parks interest
list that includes several thousand community members and all neighborhood organizations. The
event was also marketed on the City's social media accounts and City TV, through a press release
to local newspapers and advertisements in the Santa Monica Daily Press, and with fliers
distributed to local businesses and at the COAST open-streets event. Based on the presentation
and a survey, written input was gathered at this event, as well as online until July 10, 2016, with
an additional 583 respondents participating online. Concept Option 2 was the preferred design
scheme by 60 percent of all respondents. (City of Santa Monica 2016)
Between the community meeting and associated survey, a total of 689 responses were obtained
from both the community event and online feedback. From the feedback, the top chosen amenities
included sports fields (802 points), playgrounds (459), gardens/landscape (455), wildlife habitat
(450), and promenades (392). Between open space and sports fields, 430 respondents indicated a
preference of maximizing sports fields, while 120 respondents indicated a preference for more
open space. Additional written suggestions for amenities included walking, running,
1.0 INTRODUCTION
Airport Park Expansion Project 1-3
Final EIR – January 2018
skateboarding, and biking paths, concessions opportunities, and improved pedestrian access.
Comments indicated a need for non-field sports, shading, community gardens, and improvements
to the existing Donald Douglas Loop South.
On July 21, 2016, the three park concept schemes were presented to the City Recreation and Parks
Commission, along with the data collected from community members on their preferences for park
amenities. Concept Option 3 was unanimously chosen by the Commission, with some additional
recommendations, including: the addition of a “loop” pathway to surround the combined park
areas; provision of a pedestrian entry at Bundy Avenue; placement of the Community Gardens
away from the runway and within close proximity to other new amenities; retention of the size of
both the existing children's playground and dog park, and that consideration be given to add
concessions, a water feature and pickleball courts.
On July 25, 2016, the three park concept schemes were presented to the Santa Monica Airport
Commission, along with the data collected from the community.1 The Commissioners deferred to
public input and the recommendations of the Recreation and Parks Commission. Based on the
Council directive to maximize sports fields, community input, and the recommendations of the
Recreation and Parks Commission, the design team developed a new hybrid concept balancing
active recreation amenities with landscaped less formal areas, and organized to facilitate further
expansion of the park in the future.
1.3 REGULATORY FRAMEWORK
The City assumed ownership of SMO when it purchased the bulk of the land by grant deed in
1926. Over the next 20 years, the City took title to the balance by grant and quitclaim deeds. While
the City owns and operates SMO, various federal statutes that govern aviation give the FAA
control over the use and management of navigable airspace, aviation safety, air traffic control, air
navigation facilities, and certain aspects of airport development and facilities, among other
operations and facilities. The FAA exercises its statutory authority in several ways, including
promulgating several administrative regulations that implement the federal statutes and by
enforcing those regulations on its own and in response to complaints from airport users. In
addition, the City’s ability to control the use of the SMO (and the City land it occupies) is also
subject to limitation by contractual obligations. The 1948 Instrument of Transfer is the form
agreement that the federal government used to transfer its lease of the City’s SMO back to the City
when the lease expired after World War II. However, the Instrument of Transfer contains language
regarding future use of the land, which the federal government claims obligates the City to operate
1 The Santa Monica Airport Commission acts in an advisory capacity to the City Council in all matters pertaining to SMO
and to aviation matters generally to the extent that they affect the City.
1.0 INTRODUCTION
1-4 Airport Park Expansion Project
Final EIR – January 2018
the SMO in perpetuity; and, if the City does not, then SMO “reverts” back to the federal
government.
The 1984 Settlement Agreement, which was also a contract between the City and the federal
government, stated that it resolved all legal disputes that existed between the City and the federal
government in 1984. The 1984 Settlement Agreement allowed the City to make substantial
changes in the operation of SMO, including making available a substantial amount of land on the
south side designated in the new layout plan as "residual land". The 1984 Settlement Agreement
expired on June 30, 2015.
Aviation interests prepared and circulated a ballot measure (Measure D) for the November 2014
election, which would have amended the City Charter to require voter approval to close all or part
of the Airport, to change the use of the Airport Land, or to impose new restrictions on fuel sales
or the use of aviation facilities. Thus, among other things, the measure would have taken away the
City Council's authority to close the Airport and reduced its power to control aviation-oriented
uses of leaseholds. In response, the City Council placed a competing measure on the ballot,
Measure LC (for "local control"), which proposed allowing the City Council to retain its authority
to close the Airport while amending the City Charter to require voter approval of future uses of
the Airport land other than park, recreational, and educational uses. Measure LC passed.
On February 1, 2017, the City entered a consent decree with the FAA to close SMO in 2028 and
shorten the runway from 4,973 feet in length to 3,500 feet by December 7, 2017 to reduce the
number flight operations at the airport. Under this agreement, the City is required to maintain
stable and continuous operations at SMO until its closure on December 31, 2028.
Following this agreement, on May 24, 2017, the City Council approved to shorten the runway at
SMO to 3,500 feet roughly centered on the existing runway with equal amounts of unusable
runway (736 feet) at each end. It is anticipated that shortening the runway to 3,500 feet could cut
jet traffic by 44 percent. Airport runway shortening will be completed by early 2018.
The City’s 2010 Land Use and Circulation Element (LUCE) of the General Plan designates SMO
as within the Airport and Business Park District, with a corresponding land use designation of
Institutional/Public Lands. The Institutional/Public Lands land use designation is intended for
high-intensity government uses, park and open space opportunities, as well as a variety of land
uses, including: commercial, retail, office, affordable, workplace and market-rate housing, and
community facilities. Although not an official zoning designation, the City labels SMO as
“Airport”. The existing Airport Park is zoned OS in the Santa Monica Municipal Code (SMMC).
The OS Zone is intended to preserve, enhance, and expand the City’s existing open space, parks,
1.0 INTRODUCTION
Airport Park Expansion Project 1-5
Final EIR – January 2018
beaches, and recreational areas, providing residents with easy access to a relaxing, visually
appealing amenity that provides opportunities for healthy recreation.
State law mandates an Airport Land Use Commission (ALUC) in every county with airports in
their jurisdiction. Each ALUC must develop a plan for promoting and ensuring compatibility
between each airport in the county and surrounding land uses. Los Angeles County ALUC has
prepared a countywide Comprehensive Land Use Plan (CLUP), which is intended to ensure that
surrounding new or proposed land uses do not adversely impact the County’s airfields’ abilities to
continue operation.
1.4 EIR PURPOSE AND LEGAL AUTHORITY
This EIR was prepared in accordance with the Guidelines for Implementation of the California
Environmental Quality Act (CEQA), published by the Natural Resources Agency of the State of
California (Title 14, California Code of Regulations 15000 et. seq.), and the City of Santa Monica’s
procedures for implementing CEQA. The CEQA process enables public agencies to evaluate a
project in terms of its environmental consequences, to examine and implement mitigation
measures for eliminating or reducing any potentially adverse impacts, and to consider alternatives
to the project. While State CEQA Guidelines Section 150201(a) requires that major consideration
be given to avoiding environmental damage, the Lead Agency and other responsible public
agencies must balance adverse environmental effects against other public objectives, considering
economic, legal, social, and technological factors.
Per Section 21067 of CEQA and Sections 15367 and 15050 through 15053 of the State CEQA
Guidelines, the City of Santa Monica is the Lead Agency under whose authority this document has
been prepared. This EIR is intended to provide information to public agencies, regulatory agencies,
decision-makers, and the public regarding the environmental impacts that would potentially result
from implementation of the Project. Under the provisions of CEQA, “the purpose of the
environmental impact report is to identify the significant effects of a project on the environment,
to identify alternatives to the project, and to indicate the manner in which significant effects can
be mitigated or avoided” (Public Resources Code 21002.1[a]). In a practical sense, this EIR
functions as a tool for fact-finding, allowing the public and the City an opportunity to collectively
review and evaluate baseline existing conditions and the Project’s potential to result in
environmental impacts through a full disclosure process. Additionally, this EIR provides the
primary source of environmental information for the City to consider when exercising any
permitting or approval authority directly related to the Project.
1.0 INTRODUCTION
1-6 Airport Park Expansion Project
Final EIR – January 2018
1.5 PUBLIC REVIEW AND COMMENTS
As a first step in complying with the procedural requirements of CEQA, the City performed a
public scoping process consistent with Section 15082 of the State CEQA Guidelines. The public
was provided an opportunity to comment on the scope of the EIR through a Notice of Preparation
(NOP) released on March 8, 2017, which was distributed to federal, state, regional, and City
agencies, neighborhood groups, and occupants and owners within a 1000-foot radius of the Project
site. The NOP comment period ran from March 8, 2017 through April 8, 2017 (Appendix A).
Comments received during the NOP comment period were considered during EIR preparation and
are included in Appendix A. The scoping process assisted the City in determining if any aspect of
the Project may cause a significant effect on the environment and, based on that determination,
narrowed the focus (or scope) of the subsequent environmental analysis.
The Draft EIR is beingwas distributed to federal, state, regional, and City agencies, neighborhood
groups, occupants and owners within a 1,000-foot radius of the Project site, and NOP commenters
with a 45-day public comment period from October 27, 2017 to December 11, 2017. The Draft
EIR wasis also available for review online at the City’s Planning and Community Development
Department website at:
https://www.smgov.net/Departments/PCD/Plans-Projects/
Hardcopies of the Draft EIR wereare available for review at City Hall, as well as local libraries.
Comments received on the Draft EIR during the public review period will beare addressed in thise
Final EIR (please see Section 8.0, Introduction to the Final EIR, Section 9.0, Response to Comments,
and Section 10.0, Corrections and Additions).
1.6 SCOPE OF THE EIR
This EIR assesses the potential environmental impacts that could occur with implementation of
the Project. The scope of the EIR includes evaluation of potentially significant environmental
issues raised in response to the NOP and during scoping discussions. The NOP and comment
letters received during the NOP comment period are included in Appendix A. The scoping process
determined that construction and/or operation of the Project may result in potentially significant
impacts with respect to the following issue areas, which are addressed in detail in this EIR:
• Air Quality
• Construction Effects
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Land Use and Planning
1.0 INTRODUCTION
Airport Park Expansion Project 1-7
Final EIR – January 2018
• Noise
• Transportation and Traffic
This EIR addresses the issues referenced above and identifies potential environmental impacts,
including project-specific and cumulative effects of the Project, in accordance with the provisions
set forth in the State CEQA Guidelines. In addition, the EIR recommends feasible mitigation
measures, where necessary, that would reduce or eliminate adverse environmental effects.
In accordance with CEQA Guidelines Section 15128 (Effects Not Found to Be Significant),
environmental impacts related to Aesthetics, Agriculture and Forestry Resources, Biological
Resources, Cultural Resources, Geology and Soils, Hydrology and Water Quality, Mineral
Resources, Population and Housing, Public Services, Recreation, Tribal Cultural Resources,
Utilities and Service Systems, and Energy Conservation were not considered significant. Section
4.0, Other CEQA Considerations, provides a discussion of these resources.
A summary of cumulative impacts, which considers other projects in proximity to the Project site,
are discussed in each resource area analysis section of EIR. Cumulative project analyses represent
a comprehensive assessment of potential impacts on City resources using a list of past, present,
and probable future projects capable of producing related or cumulative impacts.
Consistent with State CEQA Guidelines (Section 15126.6[d]), this EIR includes the assessment of
a reasonable range of alternatives to the Project that could feasibly attain the project objectives
while avoiding or substantially lessening any of the significant effects of the proposed Project.
Please refer to Section 5.0, Alternatives.
1.7 REQUIRED APPROVALS
The following approvals would apply to various components of the Project:
• Certification of the Final EIR (City Council);
• FAR Part 77 Clearance Permit;
• Any other incidental discretionary or administrative approvals needed for the construction
and operation of the Project.
1.8 AREAS OF KNOWN PUBLIC CONTROVERSY
Section 15123 of the State CEQA Guidelines states that an EIR shall identify areas of controversy
known to the Lead Agency, including issues raised by the agency and the public. Based on City
Council, Recreation and Parks Commission, Airport Commission hearings and discussions
regarding the Project, as well as feedback received during the community outreach process and
1.0 INTRODUCTION
1-8 Airport Park Expansion Project
Final EIR – January 2018
letters received from the public in response to the NOP, the following environmental issues are
known to be of concern and may be controversial. Each issue is further evaluated in the EIR:
• Temporary and long-term impacts to traffic congestion, parking, and circulation;
• Land use compatibility between the expanded park and adjacent uses, airport operations,
and residential neighborhoods;
• Provision of safe pedestrian and bicycle access routes;
• Park impacts, including those from field lighting, on the safe operation of the airport;
• Air quality and health impacts from airport operations and synthetic turf on park visitors;
and
• Water quality impacts from surface water runoff.
1.9 ORGANIZATION OF THE EIR
This EIR is organized into the following sections.
• Section 1.0, Introduction, summarizes the background of the Project and explains the
environmental review process.
• Section 2.0, Project Description, provides a detailed description of the Project and the
Project site setting.
• Section 3.0, Environmental Impact Analysis and Mitigation Measures, provides analysis
of existing environmental conditions, specific Project impacts, mitigation measures,
cumulative impacts, and residual impacts.
• Section 4.0, Other CEQA Considerations, identifies significant and irreversible, growth-
inducing, and unavoidable effects, as well as resources areas that would not be significantly
affected by the Project.
• Section 5.0, Alternatives, describes alternatives to the Project, and identifies the
Environmentally Superior Alternative.
• Section 6.0, List of Preparers, identifies the EIR project team.
• Section 7.0, References and Persons or Organizations Contacted, provides information
about resources used in the preparation of the EIR.
• Section 8.0, Introduction to the Final EIR, provides an overview of the approach to
preparing this Final EIR.
• Section 9.0, Response to Comments, identifies all comments received on the Draft EIR and
provides responses to each comment.
• Section 10.0, Corrections and Additions, provides a summary of corrections or
clarifications to the Draft EIR.
• Section 11.0, Mitigation Monitoring and Reporting Program, provides a summary of each
mitigation measure required for the Project.
• Appendices to the EIR include the NOP, responses to the NOP, comments on the Draft
EIR, and supporting technical studies used as a basis of information and analyses in
preparation of the EIR.
Airport Park Expansion Project 2-1
Final EIR – January 2018
2.0 PROJECT DESCRIPTION
2.1 INTRODUCTION
The City of Santa Monica (City) is
proposing the Airport Park Expansion
Project (Project) to provide additional
recreational facilities and amenities for City
residents on Santa Monica Municipal
Airport (SMO) property consistent with
long-standing City objectives. This Project
would provide for additional recreation uses,
such as sports fields, on SMO non-aviation
land.1 The Project would expand the existing
Airport Park by developing approximately
12 acres of new recreational amenities on
non-aviation land adjacent to the existing
park (Project site). In response to community
feedback on park design, the Project would expand Airport Park with two International Federation
of Association Football (FIFA)-regulation-sized synthetic turf sports fields; 60 to 80 community
garden plots; a large, natural turf multi-purpose area; three pickleball courts; a continuous loop
path throughout the park; fitness equipment; children’s play areas; and two restroom/concession
buildings.
Access to the Project site would be provided via the existing Donald Douglas Loop South roadway,
which would be realigned to the western perimeter of the Project site to avoid bifurcation of the
park and allow continuous pedestrian access for visitors within the park. Parking would be
accommodated in the existing 60-space south parking lot adjacent to Airport Avenue and in a new
on-site parking lot providing 120 parking spaces, for a total of 180 parking spaces. The existing
58-space north parking lot would be removed to accommodate new Project amenities. An
acoustical berm would also be constructed at the northeast corner of the Project site, adjacent to
existing runways and Bundy Drive, to buffer the park from noise from airport operations and from
park usage on nearby residences.
1 “Non-aviation land” is area on the south side of SMO that was released from exclusive aviation use and categorized as
“parkland and residual use” in the City’s 1984 Settlement Agreement with the Federal Aviation Administration (FAA).
Some aviation uses—such as small hangars and airplane tie-downs—still remain on non-aviation land.
The Airport Park Expansion Project would more than
double the size of Airport Park to provide active
recreational facilities, such as sports fields, playground,
and community garden amenities.
2.0 PROJECT DESCRIPTION
2-2 Airport Park Expansion Project
Final EIR – January 2018
SMO is a 227-acre general aviation airport owned and operated by the City. Except for the existing
Airport Park area, SMO does not have an official zoning designation, but operates within a
complex framework of federal, state and local laws and regulations. The expanded Airport Park is
projected to be open to the public in 2020. Portions of the existing park would remain open during
construction.
2.2 EXISTING PROJECT SITE CHARACTERISTICS
2.2.1 Project Location & Surrounding Land Uses
Located at the northwest corner of Airport Avenue and Bundy Drive, the Project site is situated on
SMO property at the southeast corner of the City (Figure 2-1) and falls within the City’s Airport
Influence Area (AIA). The Project site is located approximately 2.25 miles southeast of Downtown
Santa Monica, approximately 2.5 miles east of the Pacific Ocean, approximately 0.75 mile south
of the Santa Monica (I-10) Freeway, and approximately 1.0 mile west of the San Diego (I-405)
Freeway.
The Project site lies adjacent to the City boundary with the City of Los Angeles. The Project site
is bordered by SMO aviation-related uses to the north, Bundy Drive to the east, Airport Avenue to
the south, and the Barker Hangar event venue to the west. Existing land uses in the Project vicinity
consist of the aviation-related uses of SMO; residential neighborhoods; park, recreation, and
cultural facilities; commercial/office uses; restaurants; event venues; and educational facilities
(Figure 2-1).
Aviation-related uses of SMO are located north
across Donald Douglas Loop South from the Project
site. These uses include the two-story General
Aviation Facility Specialty Hangar (3100 Donald
Douglas Loop South), the two-story Airport
Administration Building & Police Substation
(3223 Donald Douglas Loop South), and the City’s
Transient Aircraft Parking Area. SMO Runway 3/21
is located immediately north of these uses. The
existing alignment of Donald Douglas Loop South
serves as the primary vehicle access to aviation-
related uses north of the Project site.
The Douglas DC-3 Monument and Museum of
Flying are located across Airport Avenue south
of the Project site.
L
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RICHARD RICHARD AVENUE AVENUE ELEMENTARY ELEMENTARY DANIEL WEBSTER DANIEL WEBSTER MIDDLE/MIDDLE/MAGNOLIA MAGNOLIA SCIENCE ACADEMY SCIENCE ACADEMY
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2.0 PROJECT DESCRIPTION
2-4 Airport Park Expansion Project
Final EIR – January 2018
Single-family residences within the City of Los Angeles’ Mar Vista Neighborhood are located east
of the Project site across Bundy Drive. These homes are located on an elevated knoll that overlooks
the Project site and SMO. Venice Reservoir Park is located farther south and across Bundy Drive.
Non-aviation commercial, restaurant, and cultural land uses on SMO property are located south of
the Project site across Airport Avenue (Table 2-1). The Santa Monica College Bundy Campus and
single-family residences located within the City of Los Angeles are located south of these non-
aviation land uses.
Table 2-1. Non-Aviation Uses South of Airport Avenue in Project Vicinity
Address Land Use
3050 Airport Ave Two-story former airplane hangar housing the Santa Monica Art Studio.
3050 Airport Ave SMO Parking Lot # 5, which primarily serves the Santa Monica Airport Outdoor
Antique & Collectable Market on the 1st and 4th Sunday of every month.
3100 Airport Ave Two-story building housing the Douglas DC-3 Monument and The Museum of Flying.
3200 Airport Ave One-story building containing office uses, art studios, the Ruskin Theater Group, and
the Airport Avenue Demonstration Garden.
3200-3300 Airport Ave SMO Parking Lot #4
3300 Airport Ave Two-story building with office uses above The Spitfire Grill.
3400 Airport Ave One-story office building.
3400 Airport Ave SMO Parking Lot #3
The Barker Hangar event venue is located immediately west of the Project site. The approximately
35,000-square-foot (sf) former airplane hangar has been used as an event venue since 1969. Barker
Hangar operates under a Master Lease with the City. Under this lease, Barker Hangar also utilizes
the airport apron at the western portion of the Project site to stage trucks/equipment and to park
approximately 200 cars during events. Surface parking lots and aviation-related land uses are
located farther west of Barker Hangar.
Regional access to the Project site is provided via Bundy Drive, Airport Avenue, and Ocean Park
Boulevard. Regional bus access to the Project site is provided via Big Blue Bus Routes 14 and 44.
2.2.2 Existing Site Conditions
The Project site lies on approximately 15.8 acres of non-aviation land at the southeast corner of
SMO property. Approximately 12 acres is currently improved with paved airport aprons, small
administration office buildings and airplane hangars, and Donald Douglas Loop South. The
remaining 2.2 acres of the Project site consist of portions of the approximately 8.3-acre existing
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2.0 PROJECT DESCRIPTION
2-6 Airport Park Expansion Project
Final EIR – January 2018
portions of the existing park include approximately 1.5 acres of the lawn area adjacent to the south
parking lot, which would be renovated as new lawn area and community garden plots, and the
existing, 0.7 acre, 58-space north parking lot, which would be removed to accommodate various
park amenities. The remaining 1.6 acres is occupied by the existing alignment of Donald Douglas
Loop South. The Project site comprises all or a portion of three parcels (Table 2-2).
Table 2-2. Existing Uses by Assessor Parcel Numbers
Assessor Parcel Numbers (APN) Existing Use
APN No. 4272-026-902
SMO (West Paved Surface Area, Airport Buildings), Barker Hangar,
Existing Airport Park, Airport Avenue, Non-Aviation Uses on SMO
Property South of Airport Avenue
APN No. 4272-027-901 SMO (East Paved Surface Area), Donald Douglas Loop South, Existing
Airport Park
APN No. 4272-027-270 SMO (East Paved Surface Area), Donald Douglas Loop South
The Project site slopes gently downward to the southwest, with a high point of approximately
164 feet above sea level (asl) at the northeast corner of the Project site and a low point of
approximately 128 feet asl at the southwest corner of the Project site, near Barker Hangar. The
Project site is slightly steeper near Bundy Drive, where the roadway is elevated above Airport
Park, and then levels off to become relatively flat across the existing sports field. Runoff from the
Project site flows to the southwest and is captured in eight catch basins located throughout the
Project site. The catch basins flow to a 36-inch stormwater main along Airport Avenue, which then
flows west through a series of stormwater mains and ultimately drains to the Penmar Water Quality
Improvement Project (Penmar Project), located underneath Penmar Recreation Center Park. The
Penmar Project is part of the Implementation Plan for Jurisdictional Groups 2 and 3, including the
City and the City of Los Angeles, to assist in compliance with the Santa Monica Bay Beaches
Bacterial Total Maximum Daily Loads (TMDLs). The Penmar Project includes an underground
storage tank that captures dry weather runoff (e.g., irrigation runoff, pool draining, car washing)
and nearly three million gallons of stormwater per storm event. Runoff is currently diverted to the
sanitary sewer and treated at the City of Los Angeles Hyperion Water Reclamation Plant. Phase II
construction of the Penmar Project is currently in progress and will eventually treat the captured
runoff instead of diverting to Hyperion Treatment Plant.
The existing Airport Park is located at the southeast corner of the Project site. At approximately
8.3 acres in size, the park provides an off-leash dog park, playground, a FIFA-regulation sized
synthetic turf sports field, a picnic area with 17 tables and 6 barbeque grills, and a 0.6-mile walking
loop. The off-leash dog park is separated by a chain-link fence into two separate areas for small
and large dogs. Parking is currently provided in two surface parking lots. The south parking lot
2.0 PROJECT DESCRIPTION
Airport Park Expansion Project 2-7
Final EIR – January 2018
accessed via Airport Avenue provides 60 parking spaces and bicycle racks. The north parking lot
is accessed via Donald Douglas Loop South and provides 58 parking spaces. In total, Airport Park
currently provides 118 parking spaces. A Breeze Bike Share station is located at the intersection
of Airport Avenue and Donald Douglas Loop South.
The Project’s expansion of the park would occur primarily on two large, paved surface areas
located on either side of the existing sports field. The surface area located west of the existing
sports field (west paved surface area) is a roughly rectangular area approximately 6 acres in size.
Vehicle access is provided directly from a driveway on Airport Avenue. The paved surface area
supports the administration offices and maintenance hangars of two aviation services (Proteus Air
Service and Task Us); approximately 12 small, corrugated metal airplane hangars; approximately
48 airplane tie-down spaces, and parking for vehicles. This area also accommodates
supporting/staging activities and parking during events at the adjacent Barker Hangar.
The paved surface area east of the existing sports field (east paved surface area) is a roughly
trapezoidal area approximately 6 acres in size and located north of the existing off-leash dog park.
Vehicle access to the east surface area is provided through a gate in a chain-link fence that lines a
controlled-access segment of Donald Douglas Loop South, east of the Airport Administration
Building. Approximately 5.2 acres of this surface area is paved and previously supported
approximately 78 airplane tie-down spaces, although airplanes are no longer stored on this apron.
The remainder of this surface area consists of a vegetated slope adjacent to Bundy Drive.
Donald Douglas Loop South runs along the northern border of the Project site from the eastern site
boundary to the existing sports field, where it turns south along the west edge of the field,
ultimately intersecting with Airport Avenue.
The existing synthetic turf sports field at Airport Park
is heavily used and would be incorporated into the
newly expanded park. Barker Hangar is visible in the
background.
The existing picnic area at Airport Park, with 17 picnic
tables and 6 barbeque grills, would connect to the
Project’s park expansion area by two public
walkways.
2.0 PROJECT DESCRIPTION
2-8 Airport Park Expansion Project
Final EIR – January 2018
2.2.3 Land Use Designations
The City’s Land Use and Circulation Element (LUCE) designates SMO as within the Airport and
Business Park District, with a corresponding land use designation of Institutional/Public Lands on
the LUCE Land Use Designation Map. The Land Use Designation Map also identifies SMO as
“Airport”. Within the Airport and Business Park District, development includes office uses to the
north of SMO, aviation service facilities, flying schools, parking facilities, arts and event centers,
parks and open space, and restaurants. The Institutional/Public Lands land use designation is
intended for high-intensity government uses, park and open space opportunities, as well as a
variety of land uses, including: commercial, retail, office, affordable, workplace and market-rate
housing, and community facilities.
Although not an official zoning designation, the LUCE Land Use Designation Map labels SMO
as “Airport”. Santa Monica Municipal Code (SMMC) Chapter 9.51.030.D.1, Airports and
Heliports, defines an airport as a “[facility] for the takeoff and landing of airplanes and helicopters,
including runways, helipads, aircraft storage buildings, public terminal buildings and parking, air
freight terminals, baggage handling facilities, aircraft hangar and public transportation and related
facilities, including bus operations, servicing and storage. This classification also includes support
activities … and other equipment and structures required by the United States Government and/or
the State for the safety of aircraft operations.”
The SMO property lies within the jurisdictional boundaries of the City of Santa Monica, with a
small eastern end (including a small portion of the Project site’s east paved surface area) located
within the City of Los Angeles boundaries.
The paved surface area east of the existing sports
field and north of the existing dog park formerly
supported 78 airplane tie-downs. This area would be
the location of the Project’s east sports field and
acoustical berm.
The paved surface area west of the existing sports
field accommodates a paved area, 12 small airplane
hangars and 48 airplane tie-downs. This area would
be the location of the Project’s west sports field and
new parking area. Barker Hangar is seen on the right.
2.0 PROJECT DESCRIPTION
Airport Park Expansion Project 2-9
Final EIR – January 2018
Within the City of Santa Monica, the SMO property (including the Project site’s west paved
surface area and most of the east paved surface area) does not have an existing zoning designation -
with the exception of Airport Park. The existing Airport Park is zoned OS (Parks and Open Space)
in the SMMC. The OS Zone is intended to preserve, enhance, and expand the City’s existing open
space, parks, beaches, and recreational areas, providing residents with easy access to a relaxing,
visually appealing amenity that provides opportunities for healthy recreation. The OS Zone is
applied to areas that will remain as parks or green open space, or be developed as such. Other
allowed uses in the OS Zone include supporting structures such as recreation centers, gymnasiums,
community meeting facilities and small-scale retail uses that support outdoor recreation, such as
restaurants, refreshment stands, or sporting equipment and rental vendors.
The eastern end of SMO and a portion of the Project site (Parcel APN 4272-027-270) are within
the boundaries of the City of Los Angeles and zoned R1-1 (One-Family Zone, Height District 1)
by the Los Angeles Municipal Code. These parcels have been owned in fee by the City (i.e. deeded
to the City) since it assumed operation of SMO in 1926. Los Angeles’ One-Family Zone permits
the development of parks, playgrounds, owned and operated by a governmental agency, even
though under Government Code sections 53090-91, the City is not strictly required to comply with
the City of Los Angeles Zoning Code. Lawler v. City of Redding (1992) 7 Cal.App.4th 778, 783.
The Project site is located within the AIA of SMO. As such, it is within the airport planning area
of the Los Angeles County Airport Land Use Commission (ALUC). The purpose of the ALUC is
to protect the public health, safety, and welfare by ensuring the orderly expansion of airports and
the adoption of land use measures that would minimize public exposure to adverse noise and safety
impacts within areas around public use airports. ALUC is also involved with airport activities that
may adversely affect adjacent areas and nearby land use that may interfere with airport operations.
Under the State Aeronautics Act (California Public Utilities Code sections 21001 et seq.), the
ALUC must prepare a land use compatibility plan for each airport and the area surrounding each
airport within its jurisdiction. The land use compatibility plan shall be based upon a long-range
master plan or an airport layout plan that reflects projected growth for 20 years.
In 1991, the Los Angeles County ALUC adopted a Countywide Comprehensive Land Use Plan
(CLUP), which is intended to safeguard the welfare of both inhabitants in the vicinity of the airport
and the airfield operators/ occupants themselves. The CLUP is also intended to ensure that
surrounding new or proposed land uses do not adversely impact the airfield’s ability to continue
its operation, as it hosts multiple entities with a variety of federal and non-federal missions. Despite
the goals of the ALUC CLUP, its jurisdiction and power are limited. The ALUC does not have
jurisdiction over airport operations, nor does the ALUC have the authority to zone property or
2.0 PROJECT DESCRIPTION
2-10 Airport Park Expansion Project
Final EIR – January 2018
apply other land use controls. State law emphasizes local general and specific plans as the primary
mechanism for implementing the compatibility policies set forth in an ALUC’s plan. Thus, Los
Angeles County and each city affected by an airport land use compatibility plan is required to
make its general and specific plans consistent with the ALUC plan. Recommendations made by
the ALUC are advisory to local jurisdictions and may be overruled by a two-thirds vote of the City
Council. The City has sole responsibility to specify which compatible land uses at SMO and
surrounding SMO property are appropriate through its planning and zoning powers.
2.2.4 Existing Airport Operations
The City records and tracks SMO operations annually. Most recently, these records were published
in the Santa Monica Airport Calendar Year 2016 Annual Operations Report (Appendix E). The
total number of aircraft operations (an aircraft operation is defined as one takeoff or one landing)
recorded in 2016 was 87,904, which represents an increase of approximately 5.5 percent from the
83,324 operations recorded in 2014.
Approximately 67,500 of the total aircraft operations for 2016 were from propeller aircraft, with
propeller aircraft representing 76.5 percent of the total operations. Annual propeller aircraft
operations (single-engine, multi-engine, and turbo-prop) increased by 4.9 percent compared to
calendar year 2014. From the total propeller operations recorded, approximately 5,933 were by
turboprop aircraft. Approximately 17,338 of the total aircraft operations for 2016 were jet aircraft.
In 2016, jets represented 20.0 percent of the total annual operations. During calendar year 2016,
jet operations increased by 13.8 percent compared to calendar year 2014. Approximately 3,066 of
the total aircraft operations for 2016 were helicopter operations. During calendar year 2016,
helicopters represented 3.5 percent of the total annual operations.
Airport operations have been declining over the last decade, although 2016 saw a 5.5 percent increase over 2014
operations.
Source: Santa Monica Airport Calendar Year 2016 Annual Operations Report; Appendix E.
2.0 PROJECT DESCRIPTION
Airport Park Expansion Project 2-11
Final EIR – January 2018
No takeoffs or engine starts, including the operation of auxiliary power units (APU), are permitted
between 11:00 p.m. and 7:00 a.m. Monday to Friday, or until 8:00 a.m. on weekends. Exceptions
are only allowed for bona fide medical or public safety flights. Although arrivals are permitted
24 hours a day, pilots are requested to avoid all operations between 11:00 p.m. and 7:00 a.m.
Monday through Friday, or until 8 a.m. on weekends.
On February 1, 2017, a consent decree between the City and the FAA was approved. The
agreement established that the City would be able to close SMO by 2028 and shorten the runway
from 4,973 feet in length to 3,500 feet to reduce the number of flight operations at the airport.
Airport runway shortening will be completed by early 2018. Under this agreement, the City is
required to maintain stable and continuous operations at the airport until its closure on December
31, 2028.
Jet operations have remained relatively steady over the last decade, and represented 20.0 percent of total operations
in 2016.
Source: Santa Monica Airport Calendar Year 2016 Annual Operations Report; Appendix E.
Helicopter operations decreased by 17.5 percent in 2016 when compared to 2014 operations, and represented
3.5 percent of total airport operations.
Source: Santa Monica Airport Calendar Year 2016 Annual Operations Report; Appendix E.
2.0 PROJECT DESCRIPTION
2-12 Airport Park Expansion Project
Final EIR – January 2018
2.3 PROJECT OBJECTIVES
Section 15124(b) of the California Environmental Quality Act (CEQA) Guidelines requires a
project description to contain a statement of a project’s objectives and Section 15124(b) requires
that the statement of objectives includes the underlying purpose of the project. The City has
determined that the Project has 10 major objectives, as follows:
1) Provide a Broad Range of Safe Park Uses: Enhance and expand the City of Santa Monica
open space system by providing a broad range of safe, high-quality recreational amenities
for residents of all ages and abilities, with an emphasis on maximizing the total square
footage of sports fields available at Airport Park.
2) Accommodate Future Expansion of Airport Park: Ensure that the design of Airport
Park is compatible with the goal of a much larger and more varied mix of active and natural
park uses anticipated following the closure of the airport, to facilitate further expansion of
Airport Park in the future.
3) Community Needs: Develop recreational uses that would meet the highest priority needs
of the community.
4) Compatible Interface with Adjacent Uses: Design a park and recreation facility that is
sensitive to, and compatible with surrounding land use and the environment.
5) General Plan Open Space Element: Implement Policy 2.1 of the Open Space Element to
revise portions of public lands, including the “conversion of non-aviation lands at the
Municipal Airport including streetscape improvements to Airport Avenue, sports fields,
picnic areas, and an off-leash dog area.”
6) Streetscape Improvements: Provide sidewalk, street and streetscape improvements along
the relocated portion of Donald Douglas Loop South and portions of Bundy Drive north of
the existing dog park to the project’s northerly boundary to enhance aesthetics of the
Airport, including Airport Park and its surrounding land uses.
7) Minimize Noise Impacts: Buffer potential noise impacts associated with airport
operations on Airport Park, and potential noise impacts associated with Airport Park on the
nearby residential and commercial uses.
8) Minimize Traffic Impacts: Develop high-quality recreational facilities in walking
distance to residents and with convenient access to public transit options.
2.0 PROJECT DESCRIPTION
Airport Park Expansion Project 2-13
Final EIR – January 2018
9) Architectural Design: Ensure high-quality architectural design that enhances the park’s
surroundings, including by incorporating attractive architectural features, landscaping, and
lighting.
10) Sustainability: Build new and modern energy-efficient amenities and water saving
features that are sustainable and meet the latest building and energy codes.
2.4 PROJECT OVERVIEW
The Project would involve redevelopment of non-aviation land within the SMO property to
provide new recreational facilities. The Project would more than double the size of Airport Park,
with improvements including constructing approximately 12 acres of new recreational amenities
and renovating a 2.8-acre portion of the existing park (Figure 2-3). For the purposes of this EIR,
the Project’s development program is provided in Table 2-3. The development program may
experience minor revisions and refinements during final project design and approval; however, the
total park area would not exceed 20.3 acres. The Project would primarily serve Santa Monica’s
Sunset Park and Ocean Park neighborhoods, as well as Los Angeles’ Mar Vista neighborhood.
2.4.1 Proposed Recreational Amenities
The Project would largely avoid changes to the existing 8.3-acre Airport Park. The only proposed
modification would include the removal of the lawn area and trees adjacent to the north side of the
existing parking lot to accommodate the installation of drought tolerant landscape and 60–
80 community garden plots. The existing 58-space north parking lot would also be removed to
accommodate proposed amenities. The additional recreational amenities to be provided by the
Project include the following:
Synthetic Turf Sports Fields: Project development would include construction of two FIFA-
regulation-sized (210 feet x 360 feet) synthetic-turf sports fields and would be designed to
accommodate soccer, lacrosse, football, and rugby, among other sports. One field would be located
west of the existing sports field, near the Barker Hangar; the other would be located east of the
existing sports field, north of the off-leash dog park. Both sports fields could be divided
horizontally to accommodate two to three practice fields within each field. The fields would be
bordered by 12-foot-tall tall chain link fencing with 4–8-foot-tall mesh above for security and ball
containment (Figure 2-4). Each field would be lit by 70–80-foot-tall light standards with anti-glare
features to accommodate game play at night. Shaded spectator areas would be located adjacent to
each sports field and in close proximity to a sun-screened children’s play area.
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2.0 PROJECT DESCRIPTION
2-16 Airport Park Expansion Project
Final EIR – January 2018
Table 2-3. Proposed Development Program
Amenity Description Area Size
(sf)
Area Size
(Acre)
Existing Airport Park
Synthetic Turf Sport
Field
FIFA-regulation size (210 ft x 360 ft) sports field
and sidelines. 128,560 sf 2.95 ac
Off-Leash Dog Park Dog park with separate areas for large and small
dogs. 38,210 sf 0.88 ac
Playground Area Playground area with shaded play structures 5,880 sf 0.13 ac
Restroom/ Storage
Building Restroom/storage building. 1,640 sf 0.04 ac
Parking Lots/
Circulation Area
Driveways, two parking lots providing a total of
118 spaces total, and sidewalks (58-spot northern
parking lot to be removed).
49,250 sf
(28,210 sf to
be renovated)
1.14 ac
(0.65 ac to
be renovated)
Park Slope Entrance
Northwest corner of Airport Avenue and Bundy
Drive, where the park slopes upward toward
Bundy Drive.
10,510 sf 0.25 ac
Park Landscaping
and Walking/
Jogging Path
Lawn area, landscaping, and 0.6-mile Loop
pathway.
91,360 sf
(65,800 sf to
be renovated)
2.10 ac
(1.51 sf to
be renovated)
Total Existing Park Area
360,900 sf
(119,570 sf to
be renovated)
8.29 ac
(2.16 ac to
be renovated)
Proposed Recreational Amenities
Synthetic Turf Sport
Fields
Two, FIFA-regulation size (210 ft x 360 ft) sports
fields and sidelines. 200,670 sf 4.61 ac
Natural Turf Multi-
Purpose Areaa
A multi-purpose area for passive recreational
activities such as gathering and play. 56,045 sf 1.29 ac
Community
Gardensa 60-80 community garden plots 11,092 sf 0.25 ac
Pickleball Courts Three, regulation-sized (44 ft x 20 ft) pickleball
courts and sidelines. 4,370 sf 0.10 ac
Continuous Loop
Path
A network of multi-use pathways throughout the
site, including a pathway extending from the Main
Bundy Entry to the west sports field.
27,120 sf 0.62 ac
Miscellaneous Park
Amenities
Miscellaneous non-programmed amenities, fitness
equipment, adult-sized swings located between the
sports fields and Donald Douglas Loop South
23,900 sf 0.55 ac
Parking, Roadways,
and Other
Hardscapes
A 128-space parking lot, new alignment of Donald
Douglas Loop South, park drop-off area,
sidewalks, and hardscape areas.
181,245 sf 4.16 ac
Park Landscaping Non-active portions of Airport Park (slopes) would
be landscaped with drought-tolerant species. 180,000 sf 4.14 ac
2.0 PROJECT DESCRIPTION
Airport Park Expansion Project 2-17
Final EIR – January 2018
Table 2-3. Proposed Development Program (Continued)
Amenity Description Area Size
(sf)
Area Size
(Acre)
Restroom/
Concession/
Maintenance
Building No. 1
233 sf of restroom area providing all-gender stalls,
concession area, storage area, and
electrical/mechanical area.
720 sf 0.016 ac
Restroom/
Concession/
Maintenance
Building No. 2
244 sf of restroom area providing all-gender stalls,
concession area, storage area, and
electrical/mechanical area.
925 sf 0.021 ac
Total New/Renovated Amenities 686,087 sf 15.75 ac
Total Park Area After Project 884,268 sf 20.3 ac
a This amenity would be located in a renovated portion of the existing Airport Park.
Natural Turf Multi-Purpose Area: A 56,045-sf (1.29-acre), natural turf multi-purpose area would
be located in the central park area, between the existing sports field and the new east sports field.
The multi-purpose area would be intended for gathering and informal play use. The multi-purpose
area would be divided by a pedestrian path; the area west of the path would include a generous
clustering of approximately 20 palm trees for shading, while the area east of the path would reserve
trees to the area’s perimeter, allowing a large lawn area open to the sky.
Community Gardens: The Project would develop 60–80 community garden plots adjacent to the
north side of the existing south parking lot. To maintain the continuity of the park, the community
garden is placed away from park edges to a more central location within the park, making them
readily accessible to other park amenities including the natural turf multi-purpose area. The
gardens are located in close proximity to parking to accommodate gardeners who routinely bring
supplies to their plots.
Pickleball Courts: Three regulation-sized (44 feet x 20 feet) pickleball courts would be located
north of the existing sports field. The pickleball courts would be flanked by staging/observation
areas consisting of decomposed granite paving. Chain-link fencing approximately 5–10 feet in
height would be provided around each court to control stray balls. Lighting would be provided by
30–40-foot lighting standards with anti-glare features to accommodate game play at night.
Non-Programmed Recreational Amenities, and Adult-Sized Swing: An approximately
23,900-square-foot (0.55 acre) area between the sports fields and Donald Douglas Loop South
would include a variety of non-programmed recreation, amenities, and a structure containing
several adult-size swings.
2.0 PROJECT DESCRIPTION
2-18 Airport Park Expansion Project
Final EIR – January 2018
Continuous Loop Pathways: The Project’s pedestrian pathways have been arranged to form a
continuous loop network of pathways around and throughout the park, to provide pedestrians a
variety of options for traversing through and exercising in the park. The pathways comprising the
loop network would be composed of decorative asphalt or concrete and range from 6- to 2424-feet
in width. The pathways would provide access from the Main Bundy Entry to the existing sports
field.
Restrooms, Concession, and Maintenance Buildings: The Project would construct two new
restroom/concession buildings to augment the existing restroom at the park’s midpoint, one
adjacent to each sports field. Each Restroom/Concession Building would provide approximately
240 square feet (sf) of restroom area providing four all-gender restroom stalls, between 80–450 sf
of storage area, and between 120–320 sf of electrical/mechanical area. One or both buildings
would provide concession area (e.g., snack bar). Both restrooms/concession buildings would be
American with Disabilities Act (ADA) accessible, and would allow visitors to gather on the
rooftops to enjoy views of the park and beyond (Figure 2-5 and Figure 2-6).
2.4.2 Acoustical Berm and Overlook
An acoustical berm would wrap around the northeast corner of the Project site and rise from 10–
15 feet above the finished grade. Pedestrian pathways would be placed atop the berm, terminating
in an overlook at the northeast corner of the Project site. The Main Bundy Entry to the park would
consist of a 24-foot-wide path that passes through the acoustical berm to a promenade area,
creating a defined park entrance complete with monument signs.
As shown in this conceptual rendering, the Main Bundy Entry would pass through an acoustical berm. A pedestrian
path on top of the berm would follow the northern park boundary and terminate at an overlook at the northeast
corner of the park.
Overlook
MATCHLINE (SECTION CONTINUES BELOW)MATCHLINE (SECTION CONTINUES BELOW)MATCHLINE (SECTION CONTINUES BELOW)
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2.0 PROJECT DESCRIPTION
Airport Park Expansion Project 2-21
Final EIR – January 2018
2.4.3 Access and Parking
Primary vehicular access to new recreational facilities provided at Airport Park would be provided
off of the realigned segment of Donald Douglas Loop South, which would be relocated to the
western site boundary to prevent bifurcation of the park. The new alignment of Donald Douglas
Loop South would be approximately 24 feet wide at its intersection with Airport Avenue and
would accommodate a single-lane of traffic in each direction. Traffic to the Airport Administration
Building would be routed around the north side of the new parking area following the re-alignment
of the roadway. Turnarounds would be provided at two locations to accommodate the movement
of emergency vehicles. One turnaround would be located north of the multi-use area, the other
would be located north of the east sports field. The current north-south segment of Donald Douglas
Loop South would be vacated and converted into a pedestrian path (Figure 2-3). Access would
continue to be available off Airport Avenue as well.
Additional parking to serve the Project site would be provided in a new 120-space parking lot
constructed at the northwest portion of the park off the west end of the Donald Douglas Loop
South. The new parking lot would be composed of permeable asphalt paving to allow stormwater
infiltration and include landscaped planters throughout the parking lot. A new loading area would
also be provided along the new alignment of Donald Douglas Loop South, adjacent to the west
sports field, to allow for loading/unloading of sports equipment.
The existing 60-space parking lot off of Airport Avenue would be retained, bringing total onsite
off-street parking for 180 vehicles.
Regional bus access to the Project site would continue to be provided via Big Blue Bus Routes 14
and 44. Route 14 maintains bus stops at the intersection of Bundy Drive and Airport Avenue, while
Route 44 runs in a loop around the Santa Monica College Bundy Campus, with the nearest bus
stop located at the Museum of Flying.
Bicycle racks to accommodate approximately 45 bicycles would be placed adjacent to the new
pathways. The Breeze Bike Share location at the current intersection of Airport Avenue and
Donald Douglas Loop South would be temporarily relocated during Project construction, and
placed at the new intersection of these two ways upon Project completion.
Pedestrian access would be provided at two locations along Bundy Avenue, including at the Main
Bundy Entry and the Secondary Bundy Entry, and at six locations along Airport Avenue, including
a pedestrian path at the vacated alignment of Donald Douglas Loop South. The pedestrian access
points are designed to provide linkages to surrounding uses and facilitate an uninterrupted flow
through the park and to other pedestrian entrances.
2.0 PROJECT DESCRIPTION
2-22 Airport Park Expansion Project
Final EIR – January 2018
2.4.4 Landscaping
The Project’s landscaping program would intersperse garden and green space among fenced
synthetic turf sports fields. Naturally landscaped areas are located in less active areas of the park
and incorporate vegetation selections offering shade, seasonal variation and natural habitat The
Project would develop seven hydrozones to selectively landscape different areas within the Project
site to minimize water usage while accommodating the greatest use of Airport Park (Figure 2-7).
Table 2-4 details the representative plant species and vegetation extents in each of the seven
hydrozones. Drought-tolerant species would be utilized in less active areas of the park
(Figure 2-8).
In addition, the Project includes streetscape improvements along relocated Donald Douglas Loop
South and Bundy Drive. The streetscape improvements would extend along Bundy Drive between
the southern end of SMO and the northern end of the existing dog park, and would include
landscaped slopes, the Main Bundy Entry with monument signage and overlook, pedestrian
lighting, and landscaping. Streetscape improvements would also be completed along relocated
Donald Douglas Loop South from Airport Avenue, extending through the new northern parking
lot. These improvements would include completion of the sidewalk along the western park border
to the new parking lot, and include landscaping street trees, and pedestrian-level lighting
immediately adjacent to sidewalk.
The Project does not propose roadway, streetscape, sidewalk, or landscape improvements to
Airport Avenue along the park’s southern boundary. However, these improvements are envisioned
under a separate project, the Airport Avenue Improvement Project, which is currently in the
preliminary design phase. The Airport Avenue Improvement Project would extend from Bundy
Avenue to 23rd Street. Tentative improvements being considered under this project include
sidewalk improvements, bike lanes, retaining walls (to replace existing gunite slopes), striped
crosswalks and curb ramps, street lighting, street trees, and amenities such as benches, signage and
trash containers. The Airport Avenue Improvement Project is tentatively scheduled to overlap with
the construction of the Airport Park Expansion Project to provide uniform improvements and
minimize the duration of construction impacts along Airport Avenue. The specific design of the
Airport Avenue Improvement Project will be finalized in early 2018.
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2-24
2.0 PROJECT DESCRIPTION
Airport Park Expansion Project 2-25
Final EIR – January 2018
Table 2-4. Proposed Hydrozones
Hydrozone Water Use Park Area Representative Plant Species
Succulent
Understory Low Streetscape Improvements
Foxtail Agave
Yellow Bulbine
Chalk Dudleya
Catalina Island Dudleya
Red Yucca
White Naked Lady
Cool Season
Meadow Low Adjacent to Sports Fields & Community
Gardens, Streetscape on Bundy Drive
California Melica
Foothill Stipa
Purple Needlegrass
Warm Season
Meadow Low Adjacent to Sports Fields & Community
Gardens, Streetscape on Bundy Drive
Purple Tree-Awn
Blue Grama Grass
California Fescue
Deer Grass
Carex Meadow Med Adjacent to Sports Fields, Seating Areas,
Parking Lot Planters, Acoustical Berm
Berkeley Sedge
California Dune Sedge
Sage Slopes Low Non-programmed recreational areas,
Adult-Sized Swing, Pickleball Courts
Southern Mon key Flower
Red-Flowered Buckwheat
California Poppy
Sky Lupine
Matilija Poppy
White Sage
Autumn Sage
Purple Sage
Hummingbird Sage
Blue-Eyed Grass
Perennials Med Landscaped Areas Adjacent to pathways
California Milkweed
Single Leaf Onion
Dark Blue Agapanthus
California Corethrogyne
Blue Dicks
Fortnight Lily
Wayne Roderick Daisy
Douglas Iris
Dwarf Yellow Poker
Margarita Bop Penstemon
Midnight Penstemon
Great Lawn High Natural Turf Multi-Use Area TBD
Community
Gardens High Community Garden Plots Determined by Gardener
2.0 PROJECT DESCRIPTION
2-26 Airport Park Expansion Project
Final EIR – January 2018
2.4.5 Lighting
The Project would implement security, wayfinding,
architectural, and field lighting systems for park visitors,
with an emphasis on providing adequate light levels for
safety and security and to minimize light spillover and
glare to adjacent uses. The sports fields, pickleball
courts, and parking lots would be lit with pole-mounted
light fixtures approximately 70 to 80 feet in height and
directed toward the area to be lit while also incorporating
anti-glare features such as baffles, louvers, and side
shields to reduce light spillover. Pedestrian pathways
would be lit with human-scale post-top lighting fixtures
approximately 2–3 feet in height and directed downward
to the path. Site features like benches or vertical walls would be accented with concealed lighting
or wash lighting. The pedestrian underpass at the Main Bundy Entry would be accented with
uplighting.
Lighting would be designed in accordance with the SMMC. Energy efficient lighting, including
LED technology and sensible lighting controls will be used throughout the park. Light spillover
and pollution will also be mitigated through thoughtful fixture specification and best practices.
Best practices would include lighting controls that allow for full lighting output only during
operational and occupied times. Lighting will be designed so that it is not confused with runway
lighting for SMO. Athletic field lighting would be turned off when not in use.
2.4.6 Sustainability Features
The Project would, at a minimum, comply with the green building requirement requirements
included in the CALGreen Building Standards Code and the City’s Green Building Standards. The
sustainable design features include energy-efficient lighting fixtures that meet or exceed the
Code’s requirement, the use of synthetic turf on the sports fields and drought-tolerant plant species
in less active areas of the park, and water-efficient equipment and plumbing infrastructure. The
Project would not involve the use of crumb rubber.
The Project includes an onsite stormwater treatment system designed to retain and treat stormwater
on the Project site in accordance with the City’s Low Impact Development (LID) Ordinance. The
Project site is upstream of the Penmar Project described above. Two options are proposed to treat
stormwater on the Project site. Option 1 provides native meadow habitat to capture and treat site
Lighting would be directed at the area to be
lit, to provide uniform lighting while
minimizing spillover though the use of anti-
glare features.
2.0 PROJECT DESCRIPTION
Airport Park Expansion Project 2-27
Final EIR – January 2018
storm water, as well as the installation of bioswales, hydrodynamic separators, and subterranean
detention chambers. Option 2 would eliminate the use of native meadow habitat and subterranean
detention chambers, but would increase the number and size of bioswales installed throughout the
park. Both options would be designed to treat only “first flush” flows and ultimately discharge to
the existing storm drain along Airport Avenue. The proposed BMPs would be designed to slow
down stormwater flowrates and serve to pre-treat runoff prior to discharging to the existing
stormwater system.
2.4.7 Project Operation
The proposed park’s hours of operation would be the same as under existing conditions, with the
park open from 6:00 A.M. to 11:00 P.M. The off-leash dog park would continue to be open Monday
to Friday, 7:30 A.M. to 8:30 P.M., and on Saturdays, Sundays, and Holidays from 8:30 A.M. to
8:30 P.M. Park visitation would continue to be higher during the weekends than during the
weekdays.
As under existing conditions, use of the sports fields would be regulated and monitored by the
Community & Cultural Services Department. As with the existing sports field, the two new sports
fields would be divisible into two to three practice fields when required. Peak times for the sports
fields are generally anticipated to be: Monday to Friday from 4:00 P.M. to 9:00 P.M.; and Saturday
and Sundays from 9:00 A.M. to 12:00 P.M. and from 3:00 P.M. to 9:00 P.M. Typical use of the sports
fields for a practice session would last approximately 2 hours, while typical use of a field for league
play would last approximately 4 hours. Some events—such as City Camps Soccer—could utilize
a sports field for a period of up to 8 hours.
The three pickleball courts would be available for both reservation and walk-up play. Peak times
for the pickleball courts are anticipated to be Monday to Friday from 9:00 A.M. to 3:00 P.M. and
on Saturday and Sunday from 9:00 A.M. to 5:00 P.M.
The concession stands would generally be open during select sporting events. As under existing
conditions, reservations would also be available for the picnic area and barbeque grills.
2.5 CONSTRUCTION ACTIVITIES
Details regarding construction activities for the Project are provided below.
2.5.1 Phasing
Construction for the Project would occur in a single phase. For the purposes of the EIR,
construction work is assumed to begin in 2019, with the expanded portion of the park opening to
2.0 PROJECT DESCRIPTION
2-28 Airport Park Expansion Project
Final EIR – January 2018
the public in 2020. This construction timeline provides the worst-case analyses of environmental
impacts. Specific elements of the construction period – some of which would occur concurrently –
are summarized in the following paragraphs.
2.5.2 Demolition
Demolition and removal of the paved areas, aviation-related structures, vegetation/trees, and
existing alignment of Donald Douglas Loop South would occur over a period of approximately
one month involving one or two phases for both onsite and, if needed, offsite Project components
(e.g., Project-related utility infrastructure upgrades). Demolition would require the use of typical
construction equipment, such as backhoes and jackhammers, to break up and remove existing
asphalt, concrete, and building materials; heavy equipment, such as bulldozers, and excavators;
and heavy trucks to haul away debris. Demolition of Donald Douglas Loop South would occur in
a manner to provide continued access to airport uses north of Airport Park. Where needed, any
existing hazardous materials used in construction of park amenities would be properly handled and
disposed of in accordance with governing authority requirements. The construction haul route
would be determined in coordination with City staff and residential streets would be avoided.
2.5.3 Excavation
Excavation and grading would occur for a period of one to two months. The Project would involve
excavation to a depth of approximately five feet below existing grade on average. The Project
would require an estimated 32,400 cubic yards (cy) of cut and approximately 27,000 cy of fill,
with a net export of approximately 5,000 cy of soil from the Project site. Grading activities would
be more extensive at the east end of the Project site to level the existing slope near Bundy Drive
to construct the east sports field and the acoustical berm.
Excavation and grading would be completed by construction equipment that may include a
medium-sized track bulldozer, an all-terrain rubber-tired forklift, one or more small rubber-tired
backhoes, a rubber tired front-end loader, one or more track-mounted excavators, dump trucks,
and miscellaneous small tools, compressors, mixers, generators, portable welding machines, and
light duty pickup trucks.
The approximately 5,000 cy of soil that would be exported from the Project site would occur at a
maximum rate of approximately 278 double-trailer haul “end dump” trucks per day (10 trucks per
hour, 4 hours per day, and 18 cy per load at maximum export operations). This average may be
increased or decreased depending on the availability of truck haulers during the timeframe of work
activity. In addition to these haul truck trips, additional heavy truck traffic during this period would
include cement trucks, material and equipment delivery trucks, and worker vehicles.
2.0 PROJECT DESCRIPTION
Airport Park Expansion Project 2-29
Final EIR – January 2018
2.5.4 Construction
Construction of the Project would consist of the construction of park and recreational amenities,
and associated infrastructure, on the Project site. Project construction is estimated to require
approximately 11 to 12 months to complete.
All construction activities would be staged within secured construction areas. Based upon the flow
of materials and services to the site(s), as well as the relocation of Donald Douglas Loop South,
traffic control may be required during certain periods of Project construction. Construction
activities may require use of the following types of equipment:
• All terrain rubber tired forklift and material handling equipment
• Concrete trucks
• Material deliveries (daily)
• Office trailers and storage containers
• Light truck vehicles
• Miscellaneous small tools, compressors, mixers, generators, and portable welding
machines
• During excavation, earthmoving equipment as indicated in excavation section
All required equipment and material staging would be provided onsite and within the traffic
controlled or delineated areas and all work would be subject to a Construction Mitigation Plan
required and implemented by the City.
2.5.5 Construction Staffing
An estimated 39 workers would be onsite at during active construction of the Project.2 Staging
would be completed so that all construction workers would be accommodated on-site during
demolition, excavation, and construction periods and all work shall be subject to the Construction
Mitigation Plan.
2 Average construction employees may go up or down depending on construction phase and daily activities. Typical
construction employees on site is based on CalEEMod default inputs for Project (see Appendix C).
2.0 PROJECT DESCRIPTION
2-30 Airport Park Expansion Project
Final EIR – January 2018
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Airport Park Expansion Project 3.0-1
Final EIR – January 2018
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
3.0.1 Introduction
This section of the Environmental Impact Report (EIR) addresses potentially significant
environmental impacts of the proposed Airport Park Expansion Project (Project). The EIR
addresses potential environmental impacts that could result from the construction and operation of
the Project. The discussion of each environmental topic area is subdivided into the following
subsections: Environmental Setting, Regulatory Framework, Impact Assessment and
Methodology, Project Impacts and Mitigation Measures, and Cumulative Impacts.
Impact Assessment Guidelines and Impact Classification
The California Environmental Quality Act (CEQA) requires an EIR analysis to “identify and focus
on the significant environmental effects of a proposed project” [CEQA Guidelines, Section
15126.2 (a) and Public Resources Code Section 21000 (a)]. The emphasis of the EIR should be
placed on the potential “physical” adverse effects of a proposed project on the environment. CEQA
Guidelines Section 15360 define “environment” as the physical conditions that exist within the
area that would be affected by a proposed project including, but not limited to, land, air, water,
minerals, flora, fauna, ambient noise, and objects of historical or aesthetic significance. The section
further defines the area involved as the area in which significant effects would occur either directly
or indirectly as a result of a proposed project. The “environment” includes both natural and man-
made conditions.
CEQA Guidelines Section 15382 further clarifies the definition of “significant effect on the
environment” as a substantial, or potentially substantial, adverse change in any of the physical
conditions within the area affected by the project. An economic or social change by itself shall not
be considered a significant effect on the environment. However, an economic or social change that
may have a physical impact (such as large-scale big box retail uses resulting in urban decay) should
be considered in an EIR (Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124
Cal.App.4th 1184). The Project does not propose any uses which would result in urban decay
impacts. Therefore, economic effects are not analyzed in this EIR pursuant to CEQA.
For each impact topic, thresholds for determining impact significance are identified based on State
CEQA Guidelines and City standards, along with descriptions of methodologies used for
conducting the impact analysis. For some topics, such as air quality, greenhouse gas (GHG)
emissions, traffic, and noise, the analyses of impacts are more quantitative in nature and involve
the comparison of effects against a numerical threshold. For other topics, such as land use and
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
3.0-2 Airport Park Expansion Project
Final EIR – January 2018
planning, the analyses of impacts are inherently more qualitative, involving the consideration of a
variety of factors, such as adopted City policies and regulations.
The EIR impact discussions classify impact significance levels as:
1. Significant and Unavoidable - a significant impact to the environment that remains
significant even after mitigation measures are applied;
2. Less Than Significant with Mitigation - a significant impact that can be avoided or
reduced to a less than significant level with mitigation;
3. Less Than Significant - a potential impact that would not meet or exceed the identified
thresholds of significance for the impact topic; and
4. No Impact/Beneficial Impact – no impact would occur for the topic area or a beneficial
effect would result from the project.
Determinations of significance levels in the EIR are made based on impact significance criteria
and applicable CEQA Guidelines for each impact topic.
Mitigation Measures and Monitoring
Per CEQA Guidelines Section 15126.4, where potentially significant environmental impacts have
been identified in the EIR, feasible mitigation measures that could avoid or minimize the severity
of those impacts are also identified. The mitigation measures are identified as part of the analysis
of each impact topic in Sections 3.1 through 3.14 of this EIR.
Pursuant to CEQA, feasible mitigation measures must be implemented for all significant impacts.
In this context, feasible is defined as “capable of being accomplished in a successful manner within
a reasonable period of time, taking into account economic, environmental, legal, social, and
technological factors.” A Lead Agency must impose mitigation measures unless findings can be
made that the mitigation measures are found to be infeasible or within the jurisdiction of another
agency (City of Marina v. Board of Trustees of the California State University (2006) 39 Cal.4th
341). Mitigation measures must be fully enforceable and may involve various means of
implementation, such as:
• Measures incorporated directly into the project design as new or revised development
standards, or in conditions of approval.
• Measures implemented in multi-year City operational programs, such as a capital
improvements program or development impact fee program.
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
Airport Park Expansion Project 3.0-3
Final EIR – January 2018
• Measures incorporated as new or revised policies or development standards, or in
implementing ordinances for the project site.
CEQA requires that implementation of adopted mitigation measures or any revisions made to the
project by the Lead Agency to mitigate or avoid significant environmental effects be monitored
for compliance. Accordingly, CEQA Guidelines Section 15097 require that a public agency adopt
a Mitigation Monitoring and Reporting Program (MMRP) for adopted mitigation measures and
project revisions. With respect to responsibility of MMRP implementation, the CEQA Guidelines
provide that “…until mitigation measures have been completed the lead agency remains
responsible for ensuring that implementation of the mitigation measures occurs in accordance
with the [MMRP]”. That is, the MMRP may include a range of types of mitigation measures and
responsible parties (e.g., individual City departments, etc.), but the City is responsible for
overseeing and implementing the MMRP (CEQA Guidelines Section 15097(b)). A draft MMRP
will be provided in Section 6.0 of this EIR following public review and preparation of a final
document.The MMRP is provided in Section 11.0 of this Final EIR.
3.0.2 Cumulative Impacts Methodology
CEQA Guidelines Section 15130(a) states that an EIR shall “discuss the cumulative impacts of a
project when the project’s incremental effect is cumulatively considerable”. In this context,
“cumulatively considerable” means that the incremental effects of an individual project are
considerable when viewed in connection with the effects of past projects, the effects of other
current projects, and/or the effects of probable future projects (as defined by CEQA Guidelines
Section 15130). The CEQA Guidelines define cumulative impacts as “two or more individual
effects that, when considered together, are considerable or which compound or increase other
environmental impacts.” Section 15355 of the CEQA Guidelines further state that the individual
effects can be various changes related to a single project or the change involved in several other
closely related past, present, and reasonably foreseeable future projects. The Guidelines allow for
the use of two different methods to determine the scope of projects for the cumulative impact
analysis:
• List Method - A list of past, present, and probable future projects producing related or
cumulative impacts, including, if necessary, those projects outside the control of the agency
(Section 15130).
• General Plan Projection Method - A summary of projections contained in an adopted
General Plan or related planning document, or in a prior environmental document which
has been adopted or certified, which described or evaluated regional or area-wide
conditions contributing to the cumulative impact (CEQA Guidelines Section 15130).
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
3.0-4 Airport Park Expansion Project
Final EIR – January 2018
This EIR examines cumulative effects using the List Method. Table 3.0-1 contains a list of
pending, approved, and recently completed projects within the vicinity of the Project site, the Santa
Monica Municipal Airport (SMO), the Santa Monica Business Park, and surrounding residential
development (i.e., related projects). This list of cumulative projects was compiled by using
citywide permit records information, with additional information provided by appropriate City
departments. The Los Angeles Department of Transportation (LADOT) was also consulted for a
list of past, present, and foreseeable projects in the City of Los Angeles that may affect the physical
environmental conditions of the Project vicinity. The approximate locations of the cumulative
projects listed in Table 3.0-1 are shown in Figure 3.0-1.
Although the list of cumulative projects includes those that are more than 0.5 mile removed from
the Project site due to their potential to affect regional issues such as air quality, GHG emissions,
and transportation and circulation, the affected environment for most of the resource areas
analyzed in this EIR was determined to be limited to the Project site or immediate vicinity. The
analysis of cumulative impacts contained in each environmental topic area includes the impacts of
the Project plus other pending, approved, or recently constructed projects within the affected area
for each topic area (Table 3.0-1) Notably, the transportation impacts analysis addressed in the
Project’s Traffic Impact Analysis (Appendix F) considers cumulative projects in terms of baseline
conditions in 2017 (Approval Year) and future conditions following Project implementation in
2015 (Future Year). The impacts of cumulative projects that were final/occupied in 2017 have
been captured in 2016/2017 traffic counts used in the Traffic Impact Analysis; therefore, recently
completed projects are not included as cumulative projects in the Traffic Impact Analysis to avoid
double counting the impacts of those projects in the traffic modeling.
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
Airport Park Expansion Project 3.0-5
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica
No. Project Location Use Description of Net
New Development Status
1 Mixed Use DA 1318 2nd Street residential 56 DU Under
construction
retail (7.172) KSF
2 Residential 1012 2nd Street residential 0 DU Under
construction
3 Residential 2316 3rd Street residential 2 DU Final
4 5-Unit Condominium 947 4th Street residential 5 DU Final
5 Retail/Office
(Michael's Building)
1427 4th Street retail 0 KSF Under
construction
office 7.5 KSF
6 3-Unit condo 1919 4th Street residential 1 DU Final
7 Residential 908 5th Street residential (5) DU Final
8 5-Unit Condominium 914 5th Street residential 5 DU Final
9 SM Post Office
Adaptive Reuse
1248 5th Street creative office 46.82 KSF Under
construction
10 Mixed Use DA 1317 7th Street residential 57 DU Final
retail 2.6 KSF Final
11 Senior Housing
(affordable)
1514 7th Street affordable housing 26 DU Approved
12 Residential 1827 9th Street residential 2 DU Final
13 5-Unit Condominium 1211 9th Street residential 5 DU Under
construction
14 5-Unit Condominium 1750 10th Street residential 7 DU Under
construction
15 8-Unit Condominium 1444 11th Street residential 2 DU Approved
16 5-Unit Condominium 1518 11th Street residential 5 DU Under
construction
17 5-Unit Condominium 1533 11th Street residential 2 DU Approved
18 8-unit Condominium 1837 12th Street residential 4 DU Final
19 Condominium 1433 14th Street residential 19 DU Under
construction
20 6-Unit Condominium 1434 14th Street residential 5 DU Approved
21 Media Production 1523 14th Street creative office 7.414 KSF Final
22 5-Unit Condominium 943 16th Street residential 3 DU Final
23 11-Unit
Condominium
1803 16th Street residential 10 DU Approved
24 Residential
(5 condos/1 low
income)
1807 17th Street residential 4 DU Approved
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
3.0-6 Airport Park Expansion Project
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
23 11-Unit
Condominium
1803 16th Street residential 10 DU Approved
24 Residential
(5 condos/1 low
income)
1807 17th Street residential 4 DU Approved
25 6-Unit Condominium 1949 17th Street residential 6 DU Approved
26 3-Unit Condo 1136 18th Street residential 1 DU Under
construction
27 Residential 1433 18th Street residential 5 DU Under
construction
28 Senior Housing
(affordable) FAME
1753 18th Street affordable housing 15 DU Final
29 3-Unit Condominium 1927 18th Street residential 2 DU Approved
30 Mixed artist studio
and Office
1347 19th Street residential 3 DU Under
construction creative office 1.9 KSF
31 New Science Building
Crossroads
1731 20th Street School 20.45 KSF Final
32 Residential 1959 20th Street residential 2 DU Under
construction
33 Industrial 1645 21st Street industrial 1 KSF Final
34 Residential 1236 25th Street residential 1 DU Final
35 Creative Office (old
Papermate site
conversion of vacant
light industrial to
office)
1681 26th Street creative office 7.5 KSF Under
construction
36 8-Unit Condominium 2323 28th Street residential 6 DU Approved
37 Mixed Use 702 Arizona Ave residential 45 DU Final
affordable housing 4 DU
retail (8.7) KSF
38 Mixed Use (Sway
Building)
525 Broadway residential 125 DU Final
restaurant (26.29) KSF
39 St. Monica School
Expansion (also 1030
Lincoln)
725 California
Ave.
church/school 11.887 KSF Final
40 Affordable Housing
(Step Up on Fifth)
520 Colorado affordable housing 34 DU Final
41 Lionsgate/Post
Production DA
2834 Colorado creative office 133 KSF Under
construction retail 9 KSF
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
Airport Park Expansion Project 3.0-7
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
42 Village Trailer Park –
Mixed-Use DA
2930 Colorado apartments 324 DU Under
construction affordable housing (70) DU
retail 24.94 KSF
creative office 4.2 KSF
43 SM Place Movie
Theater
315 Colorado movie 0 KSF Final
44 5-Unit Condominiums 1025 Euclid
Street
residential
45 6-Unit Condominium 1171 Franklin
Street
residential 6 DU Final
46 Apartments 1541 Franklin
Street
residential 5 DU Approved
47 Condominiums 1621 Franklin
Street
residential 0 DU Under
construction
48 45-Unit Affordable
Condominium
1943-59 High
Place
affordable housing 38 DU Final
49 Residential/retail
building
207 Hollister residential 1 DU Final
50 Edison Elementary
School
2425 Kansas school 65 KSF Final
51 4-Unit Townhomes 612 Lincoln Blvd residential 0 DU Final
52 Walgreens
(conversion of
existing retail)
1907 Lincoln
Blvd
retail 0 KSF Final
53 2-Story Commercial 3204 Lincoln
Blvd
office 2.853 KSF Approved
auto repair (1.4) KSF Approved
54 Retail/Office 2321 Main St. retail 0.9 KSF Final
office 2 KSF Final
55 423 Ocean Avenue 423 Ocean Ave residential 4 DU Pending
56 Remodel of Existing
47 apartments
301 Ocean Ave residential 0 DU Under
construction
57 Santa Monica High
School (science and
technology building)
601 Pico Blvd school 0 KSF Final
58 4-Story residential 1112-1122 Pico
Blvd
residential 28 DU Approved
affordable housing 4 DU
59 3-Unit Condo 1127 Princeton residential 2 DU Final
60 Mixed Use DA (Mini) 1402 Santa
Monica Blvd
auto dealership 33.75 KSF Under
construction
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
3.0-8 Airport Park Expansion Project
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
61 Affordable Housing
(addressed as
1349/1347 Yale
Street)
2901 Santa
Monica Blvd
affordable housing 52 DU Pending
creative office 0 DU
retail 5.1 KSF
62 Santa Monica College
AET Campus
Expansion (SMC
jurisdiction)
1660 Stewart St School 20 KSF Under
construction
creative office 28 KSF
63 Pico Branch Library 2200 Virginia
Avenue
library 7.5 KSF Final
64 Mixed-Use
Condos/Commercial
2300 Wilshire
Blvd
residential 30 DU Under
construction retail 22.3 KSF
restaurant 2.7 KSF
restaurant 9.11 KSF
65 Mixed-Use Hotel
(adaptive reuse of
historic building)
710 Wilshire
Blvd
hotel 150.148 KSF Under
construction office (31.138) KSF
retail (11.793) KSF
66 6-Unit Condominium 1319 Yale Street residential 1 DU Final
office 53 KSF
city service building 40 KSF
auditorium 20 KSF
early childhood center 12.5 KSF
soccer field 1 field
67 Civic Center Specific
Plan
Colorado to
north, Pico to
south, 4th to east,
Ocean to west
residential 318 DU Final
affordable housing DU
retail/restaurant 25 KSF
park 12.8 acre
68 15-Unit
Condominium (Turtle
Villas)
1211 12th Street residential 13 DU Approved
69 Parking Structure 6
Rebuild
1431 2nd Street parking 350 spaces Final
70 New Courtyard by
Marriot DA
1554 5th Street hotel 74.25 KSF Final
restaurant (17.6) KSF
71 New Hampton Inn
and Suites DA
501 Colorado hotel 76.25 KSF Final
retail/restaurant (19.578) KSF
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
Airport Park Expansion Project 3.0-9
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
72 Colorado Esplanade Colorado Avenue
between 4th and
Ocean
pedestrian promenade 0 KSF Final
73 California Incline
Bridge Replacement
Ocean Avenue
and California
bridge replacement 0 KSF Final
74 Mixed Use DRP 1665 Appian Way residential Pending
retail
75 4th/Arizona 1301 4th Street office 203.104 KSF Pending
retail 17.645 KSF
hotel 117 KSF
museum 12 KSF
affordable housing 48 DU
76 Arclight 1318 4th Street movie 2700 SEATS Pending
retail 2.5 KSF
restaurant 2.25 KSF
77 Mixed Use DA 1235 5th Street residential 24 DU Pending
affordable housing 3 DU
retail 1.36 KSF
78 Mixed Use DA 1323 5th Street residential Pending
retail
79 Mixed-Use DRP 1338 5th Street residential Pending
retail
80 Mixed Use DA 1342 5th Street residential Pending
retail
81 Mixed Use DA 1415-1423 5th
Street
residential 50 DU Approved
affordable housing 14 DU
retail (4.535) KSF
82 Mixed Use DA 1425-1427 5th
Street
residential Pending
retail
83 Mixed Use affordable
housing
1437 5th Street affordable housing 43 DU Approved
retail/restaurant (0.2) KSF
84 Mixed Use DA 1313-1325 6th
Street
residential 50 DU Pending
affordable housing 10 DU
retail 2.717 KSF
85 Mixed Use DA 1238 7th Street residential Pending
retail
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
3.0-10 Airport Park Expansion Project
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
86 Mixed Use DA 1437 7th Street residential 60 DU Pending
retail 10.14 KSF
87 Affordable Housing 1543 7th Street residential 62 DU Pending
retail 3.617 KSF
88 21-Unit
Condominium/2020
Virginia
2002 21st Street residential 4 DU Pending
affordable housing 2 DU
89 Mixed Use DA (63
hotel rooms)
603 Arizona Ave hotel 27.5 KSF Pending
restaurant (3.64) KSF
90 401 Broadway 401 Broadway commercial Under
construction
91 500 Broadway DA
(Fred Segal) Site
500 Broadway residential 249 DU Approved
affordable housing 60 DU
retail 22.997 KSF
92 Mixed Use DA
(Performance
Bicycles)
501 Broadway residential 65 DU Pending
retail (2.254) KSF
93 Wyndam Hotel DA
(211 rooms)
120 Colorado hotel 104190.647 KSF Pending
residential 25 DU
affordable housing 3 DU
meeting space 5.47 KSF
retail/restaurant 17.244 KSF
94 Mixed Use DA 525 Colorado residential 47 DU Pending
affordable housing
retail (1.45) KSF
95 Mixed Use DA 1431 Colorado residential 42 DU Pending
affordable housing 8 DU
retail (6.556) KSF
96 Mixed Use DA (Fritto
misto)
601-609 Colorado residential 80 DU Pending
affordable housing 20 DU
retail 2.125 KSF
97 SM Pier Bridge
Widening and Pier
Ramp
Colorado/Ocean widen pier bridge &
construct ramp to
PCH1440/1550 Lot
0 KSF Pending
98 6-Unit Condominium 1134 Euclid
Street
residential 3 DU Pending
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
Airport Park Expansion Project 3.0-11
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
99 Mixed Use DA 1318 Lincoln
Blvd
residential 39 DU Pending
affordable housing 4 DU
retail (3.376) KSF
100 Mixed Use DA 1430 Lincoln
Blvd
residential Pending
affordable housing
retail
101 Mixed Use DA
(Upscale furniture
building)
1437-1443
Lincoln Blvd
residential 35 DU Pending
affordable housing 8 DU
retail 3.598 KSF
102 Mixed-Use DRP 1430-1444
Lincoln Blvd
residential Pending
retail
103 Mixed Use DA
(Denny's site)
1560 Lincoln
Blvd
residential 80 DU Approved
affordable housing 20 DU
retail/restaurant 9.402 KSF
104 Mixed Use DA
(Norm's site)
1601 Lincoln
Blvd
residential 72 DU Approved
affordable housing 18 DU
retail/restaurant 6.448 KSF
105 Mixed Use DRP
(Wertz Bros site)
1613-1637
Lincoln Blvd
residential 192 DU Pending
affordable housing 0 DU
retail (13.94) KSF
106 Mixed Use DRP
(Aarons brothers)
1641 Lincoln
Blvd
residential 68 DU Approved
affordable housing 10 DU
retail (0.1099) KSF
107 Mixed Use DRP
(Joann's Fabric site)
1637 Lincoln
Blvd
residential 96 DU Pending
affordable housing 0 DU
retail (12.6) KSF
108 Mixed-Use DRP 1650 Lincoln
Blvd
residential 84 DU Pending
affordable housing 16 DU
retail (14.611) KSF
109 Mixed-Use DRP 1660 Lincoln
Blvd
residential 49 DU Pending
affordable housing 25 DU
retail (3.217) KSF
110 Mixed-Use DRP 2903 Lincoln
Blvd
residential Pending
retail
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
3.0-12 Airport Park Expansion Project
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
111 2919 Lincoln/802
Ashland
2919 Lincoln
Blvd
residential 10 DU Under
construction
112 Mixed Use building 3280 Lincoln
Blvd
residential Pending
113 Mixed Use DRP 3030 Nebraska
Ave
residential Pending
creative office
114 Mixed Use DRP 3025 Olympic
Blvd
residential Pending
creative office
retail
115 Miramar Hotel
Revitalization Plan DA
1133 Ocean Ave hotel 35.056 KSF Pending
residential 120 DU
1127/1129 2nd
Street
affordable housing 40 DU
retail/spa 16.69 KSF
restaurant 8.704 KSF
meeting space (7.125) KSF
116 Mixed Use DA
(bowling alley)
234 Pico Blvd residential 79 DU Pending
affordable housing 12 DU
retail (3.914) KSF
117 Hotel/Mixed Use DA
(Ocean Avenue)
101-129 Santa
Monica Blvd
residential 22 DU Pending
affordable housing 5 DU
1327-1333-1337
Ocean Ave
hotel 165 KSF
museum 40.722 KSF
retail 21.75 KSF
118 Mixed Use 1802 Santa
Monica Blvd
residential 5 DU Pending
retail
auto dealership 15.1 KSF
119 Mixed Use DA 3008 Santa
Monica Blvd
residential 25 DU Under
construction affordable housing 3 DU
retail 0.246 KSF
120 Mixed Use DRP 601-611 Wilshire
Blvd
residential Pending
affordable housing
retail
121 Mixed Use DA 3032 Wilshire
Blvd
residential 80 DU Pending
affordable housing 20 DU
retail 4.232 KSF
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
Airport Park Expansion Project 3.0-13
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
122 St Johns Campus
Master Plan Phase II
2121 Santa
Monica Blvd
hospital and health care Pending
medical research
health wellness center
education/conference
center
child & family
development center
health related services
day care
restaurants
neighborhood
commercial
visitor housing
multifamily
replacement housing
123 2903-2931 Lincoln
Boulevard
2903 Lincoln
Blvd
residential Pending
affordable housing
retail
124 1828 Ocean Avenue 1828 Ocean Ave residential Pending
125 1921 Ocean Front
Walk
1921 Ocean Front
Walk
residential Pending
retail
126 1242 20th Street
Wellness Center
1242 20th Street R&D Pending
medical office
cultural
127 1626 Lincoln
Boulevard Affordable
Housing
1626 Lincoln
Blvd
affordable housing Under
construction
128 AA 2919 Wilshire
Blvd
retail Pending
129 Medical Office 1419 19th Street medical office Pending
130 Creative office
addition
2041 Colorado
Ave
creative office Pending
131 1550 Euclid Mixed
Use retail/office
1550 Euclid
Street
office Pending
restaurant Pending
132 Airport Park
Expansion (excluded)
park Pending
133 City Services
Building
1685 Main Street government office Approved
134 Fire Station #1 1337 7th Street fire station Approved
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
3.0-14 Airport Park Expansion Project
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
135 Green Hollow Square
(City of LA)
11961 San
Vincente Blvd
retail 51.5 KSF Pending
restaurant 6.8 KSF
office 8 KSF
storage 7 KSF
136 House Pies 1020 E Venice
Blvd
restaurant 3.895 KSF Approved
137 WLA Vons
Supermarket
11660 W Santa
Monica Blvd
supermarket 53.23 KSF Approved
138 Mixed-Use
Condos/Commercial
3115 S Sepulveda
Blvd
retail 28 KSF Approved
condominium 138 DU
139 Westside Family
YMCA
1466 S Westgate
Ave
recreational community
center 65 KSF Under
construction
140 Pico-Sepulveda
Mixed-Use
11122 Pico Blvd apartment 538 DU Under
construction retail 212.45 KSF
other 54.35 KSF
other (6.5) KSF
141 New Apartment &
Office Building
4140 S Glencoe
Ave
office 3.211 KSF Under
construction apartment 67 DU
142 Martin Expo Town
Center
12101 W
Olympic Blvd
apartment 516 DU Approved
retail 67 KSF
creative office 200 KSF
143 New Mixed-Use 11421 W
Olympic Blvd
apartment 89 DU Approved
specialty retail 6.03 KSF
144 Mixed-Use to Replace
Nursery Garden
Center
1900 S Sawtelle
Blvd
apartment 52 DU Under
construction restaurant 3.3 KSF
145 Condominium &
Commercial
4091 S Redwood
Ave
condominium 67 DU Under
construction
office 7.525 KSF
146 Mixed-Use
Development
11800 W Santa
Monica Blvd
apartment 175 DU Under
construction retail 45 KSF
147 Mixed-Use
Development
4040 S Del Rey
Ave
apartment 168 DU Approved
office 33 KSF
148 Trident Center 11355 W
Olympic Blvd
office 120.24 KSF Approved
149 Mixed-Use
Development
11460 W
Gateway Blvd
retail 5.153 KSF Approved
apartment 128 DU
3.0 ENVIRONMENTAL IMPACT ANALYSIS AND MITIGATION MEASURES
Airport Park Expansion Project 3.0-15
Final EIR – January 2018
Table 3.0-1. Pending, Approved, and Recently Constructed Projects in the City of Santa
Monica (Continued)
No. Project Location Use Description of Net
New Development Status
150 Buerge East 11750 W Santa
Monica Blvd
mixed use 187 DU Under
construction
151 Mixed-Use Project 4065 S Glencoe
Ave
office 35.206 KSF Approved
retail 1.5 KSF
apartment 49 DU
other 14 Lanes
industrial 5.05 KSF
152 New Office Building 12414 W
Exposition Blvd
office 70.844 KSF Approved
A Airport Avenue
Improvement Project
Airport Avenue
from Bundy
Drive to
23rd Street
Roadway, bicycle lane,
sidewalk, streetscape,
and landscaping
improvements along
Airport Avenue.
Construction schedule
programmed to overlap
with the Project.
N/A Pending
B Runway Shortening
Project
SMO Runway The February 2017
consent decree with the
Federal Aviation
Administration (FAA)
will shorten
Runway 3/21 from
4,973 feet to 3,500 feet
by early 2018.
N/A Approved
C FAA – SMO Airport
Closure
SMO The February 2017
consent decree with the
FAA will allow the
City to cease operations
at SMO by December
31, 2028.
N/A Pending
Notes:
DA = Development Agreement
DU = Dwelling Unit
KSF = Thousand Square Feet
Shaded listings correspond to locations depicted in Project vicinity on Figure 3.0-1.
Net New Development includes proposed new DU and KSF after demolition of existing onsite structures.
List of projects current as of May 9, 2017 and represent known projects pending, approved, and completed since the time of 2013
Citywide traffic counts.
Project locations depicted in Figure 3.0-1 are highlighted in blue within Table 3.0-1.
*Cumulative projects list includes all projects as of May 2017, which may include projects completed or withdrawn during
preparation of this EIR; therefore, project is conservatively accounted for in the cumulative analysis.
Source: City of Santa Monica 2017.
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LEGEND Santa Monica Airport Existing Santa Monica Airport Park Project Site School Fire Station Fairview Branch Library Neighborhood Boundary Park City of Santa Monica City of Los Angeles Pending Approved Under Construction Final – ConstructedFL############Cumulative Project Locations Notes: Project numbers and letters correspond to those presented in Table 3.0-1.Not all listed projects fall within map frame; those that do are highlighted.0 1,400SCALE IN FEET N 3.0-1FIGURE
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3.0-16
3.1 AIR QUALITY
This section assesses the existing air quality conditions and evaluates the potential impacts of the
proposed Airport Park Expansion Project (Project) on air quality in the Project vicinity and the
South Coast Air Basin (Basin). This evaluation addresses both short-term construction and long-
term operational air emissions generated by the Project. An analysis of greenhouse gas (GHG)
emissions and associated impacts is included in Section 3.3, Greenhouse Gas Emissions.
3.1.1 Environmental Setting
Location and Climate
The City of Santa Monica (City) is located in the
western coastal portion of Los Angeles County,
which is within the Basin, which includes Orange
County and the non-desert portions of Los
Angeles, Riverside, and San Bernardino counties.
The Basin is bounded by the Pacific Ocean to the
west, and the San Gabriel, San Fernando, and San
Jacinto Mountains to the north and east that trap air
and its pollutants in the valleys below, making the
Basin an area of high air pollution potential. Air
quality within the Basin is influenced by a wide
range of emissions sources, such as dense
population centers, heavy vehicular traffic, industry, and weather. Air quality within the Basin is
monitored and regulated by the South Coast Air Quality Management District (SCAQMD).
The regional climate within the Basin is considered semi-arid and is characterized by warm
summers, mild winters, infrequent seasonal rainfall, moderate daytime onshore breezes, and
moderate humidity. The City is located in the western coastal portion of the Basin, which has
moderate variability in temperatures, with average monthly highs from 61 to 73 degrees Fahrenheit
(°F) and lows from 50 to 63°F. The majority of annual rainfall in the Basin occurs between
December and March, and the annual average total of rainfall in the City is 13.2 inches (U.S.
Climate Data 2017).
The Basin frequently experiences weather conditions that trap air pollutants within the Basin. First,
the Basin has persistent temperature inversions formed by warmer air in the upper layer and cooler
air in the lower layer. Temperature inversions limit the vertical dispersion of air contaminants,
South Coast Air Basin
The South Coast Air Basin (Basin) includes Orange
County and the non-desert portions of Los Angeles,
San Bernardino, and Riverside Counties. Source:
California ARB.
Airport Park Expansion Project 3.1-1
Final EIR – January 2018
3.1 AIR QUALITY
holding them relatively near the ground. These inversions break when the sun heats the lower
layer, allowing the two layers to mix and the previously trapped air to leave the Basin. Second, the
Basin experiences periods of stagnant wind conditions, which also limit the movement of air
pollutants. The combination of stagnant wind conditions and low inversions produces the greatest
pollutant concentrations. Conversely, on days of no inversion or high wind speeds, ambient air
pollutant concentrations are the lowest.
Air Pollutants
Air pollutant emissions within the Basin are generated from several stationary, mobile, and natural
sources—from large power plants and manufacturing facilities to residential water heaters and
consumer products. Stationary sources can be divided into two major subcategories: point and area
sources. Point sources occur at an identified location and are usually associated with
manufacturing and industry. Examples are boilers or combustion equipment that produces
electricity or generates heat. Area sources are widely distributed and produce many small
emissions. Examples of area sources include residential and commercial water heaters, painting
operations, agricultural fields, landfills, and consumer products such as barbecue lighter fluid and
hair spray. Mobile sources, including motor vehicles, aircraft, trains, and construction equipment,
account for most of the air pollutant emissions within the Basin. Air pollutants can also be
generated naturally when winds lift fine dust particles off the ground surface into the air.
Criteria Air Pollutants
To protect the public health and welfare, the federal and state governments have identified six
criteria air pollutants and a range of air toxics, and established ambient air quality standards
through the federal Clean Air Act (CAA) and the California Clean Air Act (CCAA). The air
pollutants for which federal and state standards have been promulgated and which are most
relevant to air quality planning and regulation in the Basin include ozone (O3), carbon monoxide
(CO), suspended particulate matter (PM10), fine particulate matter (PM2.5), nitrogen dioxide (NO2),
sulfur dioxide (SO2), and lead (Pb). These pollutants are described as follows (refer to Table 3.1-
1 for federal, state, and local standards:
• Ozone (O3)
Ozone is a gas that is produced by a photochemical reaction (triggered by sunlight) between
nitrogen oxides (NOx) and reactive organic gases (ROGs), also referred to as volatile
organic compounds (VOCs). NOx is formed during the combustion of fuels, while ROGs
are formed during combustion and evaporation of organic solvents. Conditions that
produce high concentrations of ozone are direct sunshine, stagnation in source areas, high
3.1-2 Airport Park Expansion Project
Final EIR – January 2018
3.1 AIR QUALITY
ground surface temperatures, and a strong inversion layer that restricts vertical mixing.
Ozone concentrations are generally highest during the summer months when direct
sunlight, light wind, and warm temperature conditions are favorable.
Ozone is a pungent, colorless, toxic gas with direct health effects on humans including
respiratory and eye irritation and possible changes in lung functions. Groups most sensitive
to ozone include children, the elderly, people with respiratory disorders, and people who
exercise strenuously outdoors.
• Carbon Monoxide (CO)
CO is a colorless, odorless gas produced by the incomplete combustion of fuels. CO
concentrations tend to be the highest near congested transportation corridors and
intersections, especially during winter mornings with little to no wind, when surface-based
inversions trap the pollutant at ground levels.
CO’s health effects are related to its affinity for hemoglobin in the blood. At high
concentrations, CO reduces the amount of oxygen in the blood, causing heart difficulties
in people with chronic diseases, reduced lung capacity, and impaired mental abilities.
Individuals most at risk include fetuses, patients with diseases involving heart and blood
vessels, and patients with chronic hypoxemia (oxygen deficiency) as seen at high altitudes.
• Respirable Particulate Matter (PM10) and Fine Particulate Matter (PM2.5)
PM10 and PM2.5 consist of extremely small, suspended particles or droplets with diameters
less than 10 microns and less than 2.5 microns, respectively. PM10 generally comes from
fugitive dust (windblown dust and dust kicked up from mobile sources), while PM2.5 is
generally associated with combustion processes as well as being formed in the atmosphere
as a secondary pollutant through chemical reactions. Most particulate matter in urban areas
is produced by fuel combustion, motor vehicle travel, and construction activities.
Children, the elderly, and people with pre-existing respiratory or cardiovascular disease
appear to be more susceptible to the effects of high levels of PM10 and PM2.5. Potential
impacts of elevated levels of PM10 and PM2.5 include increased mortality rates, respiratory
infections, number and severity of asthma attacks, and number of hospital admissions.
Daily fluctuations in PM2.5 concentration levels have been related to hospital admissions
for acute respiratory conditions in children, to school absences, to a decrease in respiratory
lung volumes in normal children, and to increased medication use in children and adults
Airport Park Expansion Project 3.1-3
Final EIR – January 2018
3.1 AIR QUALITY
with asthma. Recent studies show lung function growth in children is reduced with long-
term exposure to particulate matter.
• Nitrogen Dioxide (NO2)
NO2 is a reddish-brown toxic gas with a characteristic sharp, biting odor and is a prominent
air pollutant resulting from nitrogen oxides emitted primarily by motor vehicles, making it
a strong indicator of vehicle emissions. Population-based studies suggest that an increase
in acute respiratory illness, including infections and respiratory symptoms in children (not
infants), is associated with long-term exposure to NO2 at levels found in homes with gas
stoves, which are higher than ambient levels found in Southern California. Increase in
resistance to air flow and airway contraction is observed after short-term exposure to NO2
in healthy subjects. Larger decreases in lung functions are observed in individuals with
asthma or chronic obstructive pulmonary disease (e.g., chronic bronchitis, emphysema)
than in healthy individuals, indicating a greater susceptibility of these sub-groups.
• Sulfur Dioxide (SO2)
SO2 is a colorless, extremely irritating gas or liquid. The largest sources of SO2 are fossil
fuel combustion at power plants and other industrial facilities. Smaller sources of SO2
emissions include industrial processes such as extracting metal from ore, and the burning
of high sulfur-containing fuels by locomotives, large ships, and non-road equipment.
SO2 is linked with several adverse effects on the respiratory system. Asthmatics are
particularly sensitive to SO2, with only a few minutes of exposure to low levels of the gas
potentially resulting in airway constriction.
• Lead
Lead occurs in the atmosphere as particulate matter. The combustion of leaded gasoline is
the primary source of airborne lead in the Basin. While the use of leaded gasoline is no
longer permitted for on-road motor vehicles; leaded gasoline is used for aircraft (as well as
some racing and off-road vehicles). Aircraft emissions are not as strictly regulated as other
emissions sources, such as motor vehicles. The use of leaded gas is permitted in aviation
uses to provide high octane fuel to produce enough thrust in combustion to achieve takeoff
and maintain safe flight. Substantial lead emissions also occur in the manufacturing and
recycling of batteries, paint, ink, ceramics, ammunition, and secondary lead smelters.
However, from 1980 to 2014, lead emissions in the U.S. dropped by 98 percent (U.S. EPA
2017).
3.1-4 Airport Park Expansion Project
Final EIR – January 2018
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Fetuses, infants, and children are more sensitive than others to the adverse effects of lead
exposure. Exposure to low levels of lead can adversely affect the development and function
of the central nervous system, leading to learning disorders, distractibility, inability to
follow simple commands, and lower intelligence quotient. In adults, increased levels of
lead are associated with increased blood pressure. Lead poisoning can cause anemia,
lethargy, seizures, and death; although it appears that there are no direct effects of lead on
the respiratory system.
Toxic Air Contaminants (TACs)
In addition to criteria pollutants described above, there are toxic air contaminants (TAC) that are
of concern in the Basin. A TAC is defined by the California Health and Safety Code Section 39655:
“Toxic Air Contaminant” means an air pollutant which may cause or contribute to an
increase in mortality or in serious illness, which may pose a present or potential health
to human health.
TACs are a diverse group of air pollutants including both organic and inorganic chemical
substances that may be emitted from a variety of common sources including gasoline stations,
motor vehicles, dry cleaners, industrial operations, painting operations, airports, and research and
teaching facilities. TACs are different than the criteria pollutants previously discussed in that
ambient air quality standards have not been established for them, largely because there are
hundreds of air toxics and their effects on health tend to be local rather than regional. The
California Air Resources Board (ARB) has designated nearly 200 compounds as TACs.
Additionally, the California ARB has implemented control measures for several compounds that
pose high risks and show potential for effective control.
TACs can cause chronic and acute adverse effects on human health. These health impacts include
increased risk of cancer due to continual inhalation of toxic air pollutants. The majority of the
estimated health risks from TACs can be attributed to a relatively few compounds, the most
important being particulate matter from diesel-fueled engines.
Volatile Organic Compounds (VOCs)/Reactive Organic Gases (ROGs)
VOCs are organic chemicals that have a high vapor pressure at ordinary room temperature and
include any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid,
metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric
photochemical reactions. Their high vapor pressure results from a low boiling point, which causes
large numbers of molecules to evaporate or sublimate from the liquid or solid form of the
Airport Park Expansion Project 3.1-5
Final EIR – January 2018
3.1 AIR QUALITY
compound and enter the surrounding air. For example, formaldehyde, which evaporates from
paint, has a boiling point of only –2 degrees Fahrenheit.
VOCs are numerous, varied, and ubiquitous. They include both human-made and naturally
occurring chemical compounds. Most scents or odors are of VOCs. Some VOCs are dangerous to
human health or cause harm to the environment. Anthropogenic VOCs are regulated by law,
especially indoors, where concentrations are the highest. Harmful VOCs typically are not acutely
toxic, but have compounding long-term health effects.
Odors
Odors are not regulated under the federal CAA or CCAA; however, they are considered nuisances
under CEQA. Odors can potentially affect human health in several ways. Odorant compounds can
irritate the eyes, nose, and throat, which can reduce respiratory volume. Additionally, the VOCs
that cause odors can stimulate sensory nerves to cause neurochemical changes that might influence
health, for instance, by compromising the immune system. Unpleasant odors can also trigger
memories or attitudes linked to unpleasant odors, causing cognitive and emotional effects such as
stress.
Regional Air Quality
Under the federal CAA of 1963, federal air quality standards, known as the National Ambient Air
Quality Standards (NAAQS), were established for the six criteria air pollutants described
previously. Similarly, the CCAA of 1988 establishes state air quality standards that are more
stringent than the NAAQS as part of the California Ambient Air Quality Standards (CAAQS).
Measurements of ambient concentrations of criteria air pollutants are used by the United States
Environmental Protection Agency (U.S. EPA) and the California ARB to assess and classify the
air quality of each air basin, county, or in some cases a specific developed area. The classification
is determined by comparing monitoring data with the federal and California air quality standards.
If a pollutant concentration in an area is lower than the standard, the area is classified as being in
“attainment.” If the pollutant exceeds the standard, the area is in marginal, moderate, serious,
severe, or extreme “nonattainment,” depending on the magnitude of the air quality standard
exceedance. If there is not enough data available to determine whether the standard is exceeded in
an area, the area is designated “unclassified.”
The entire Basin is designated as a federal and/or state-level nonattainment area for ozone, PM2.5,
and PM10. At the federal level, the Basin is designated as a nonattainment area for ozone, lead, and
PM2.5. The Basin is in attainment of federal standards for CO, SO2, and NO2, a subcategory of NOx.
3.1-6 Airport Park Expansion Project
Final EIR – January 2018
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The Basin is in attainment for the state ambient air quality standards for CO, NO2, and SO2, and the
Los Angeles County portion of the Basin is designated as attainment for lead (SCAQMD 2016a).
Local Air Quality
Ambient Air Quality
In an effort to monitor the various concentrations of air pollutants throughout the Basin, the
SCAQMD has divided the region into 38 source receptor areas (SRAs) in which 42 monitoring
stations operate. The City is located within SRA 2, which covers the northwest coastal Los Angeles
County area. Ambient air pollutant concentrations within SRA 2 are monitored at the Veterans
Administration building in West Los Angeles, which is approximately six miles west of the City.
Of the air pollutants discussed previously, only ambient concentrations of ozone, CO, and NO2 are
monitored in SRA 2. Measurements for SO2, PM10, and PM2.5 were taken in SRA 1 in Los Angeles
at the North Main Street monitoring station, as these pollutants are not measured in SRA 2.
Within the Basin, SCAQMD maintains and operates a total of 42 air monitoring stations across 38 SRAs. Each
station is capable of monitoring a number of air pollutants or meteorological data. Within SRA 2, in which the Project
site is located, the nearest monitoring station is located in West Los Angeles.
Source: SCAQMD 2008.
Airport Park Expansion Project 3.1-7
Final EIR – January 2018
3.1 AIR QUALITY
Table 3.1-1 identifies the national and state ambient air quality standards for relevant air pollutants
and provides a summary of ambient air quality measured within SRA 2 through the period of 2012
to 2015, the most recent year for which data is available. Since 2012, exceedances have occurred
for the state 1-hour standards for ozone, the state and federal 8-hour ozone standard, the federal
24-hour standard for PM10, and the federal 24-hour PM2.5 standard. The state standards for CO,
PM10, NO2, and SO2, and the federal standards for CO, NO2, and SO2 were not exceeded from
2012 through 2015.
Table 3.1-1. South Coast Air Basin Attainment Status for Criteria Pollutants
Averaging
Period
California
Standard
Federal
Standard
Criteria Pollutant Attainment
Level Summary
# of
Monitoring
Sites California Federal
Ozone (O3)
1 houra 0.09 ppm 0.12 ppm Nonattainment Extreme
Nonattainment 29
8 hour 0.07 ppm 0.075 ppm Nonattainment Extreme
Nonattainment
Carbon
Monoxide
(CO)
1 hour 20 ppm 35 ppm
Attainment
Attainment as
Maintenance
Area
25 8 hour 9 ppm 9 ppm
Respirable
Particulate
Matter (PM10)
24 hour 50 μg/m3 150 μg/m3
Nonattainment
Attainment as
Maintenance
Area
25 Annual 20 μg/m3 -
Fine
Particulate
Matter (PM2.5)
24 hour - 35 μg/m3
Nonattainment Serious
Nonattainment 26 Annual 12 μg/m3 12 μg/m3
Nitrogen
Dioxide (NO2) 1 hour 0.18 ppm 0.10 ppm Attainment Attainment 27
Sulfur Dioxide
(SO2)
1 hour 0.25 ppm 0.075 ppm Attainment Attainment 6 24 hour 0.04 ppm 0.14 ppm
Lead (Pb)
3 month
rolling
average
- 0.15 μg/m3 - Partial
Nonattainmentb
13 30 day
rolling
average
1.5 - Attainment -
a 1-hour O3 standard (0.12 ppm) was revoked, effective June 15, 2005; however, according to the Basin attainment status table,
dated February 2016, the Basin has not attained this standard based on 2008-2010 data and is still subject to anti-backsliding
requirements.
b Partial Nonattainment designation – Los Angeles County portion of Basin only for near-source monitors. Expect to remain in
attainment based on current monitoring data.
Source: (SCAQMD 2016a, 2016b).
3.1-8 Airport Park Expansion Project
Final EIR – January 2018
3.1 AIR QUALITY
Project Site Emissions
The Project site is currently occupied with the existing Airport Park, paved airport aprons, small
administration office buildings, and airplane hangars. The office buildings and existing Airport
Park generate operational emissions associated with the buildings’ energy needs and vehicle trips
generated by employees and visitors to the existing park. These uses contribute incrementally to
local and regional emissions. Aviation-related businesses (e.g., Proteus Air) currently occupy the
paved airport aprons and hangars on the Project site’s west paved surface area. These businesses
include routine aircraft operations on this portion of the Project site, including idling and taxiing,
and aircraft maintenance. As the operation of aircraft is an energy-intensive use that requires the
burning of fossil fuels, the existing aviation-related businesses currently contribute to localized
and regional emissions of criteria pollutants from the Project site.
CO Hotspots
Traffic-congested streets and intersections have the potential to generate localized high levels of
CO. Localized areas where ambient concentrations exceed national and/or state standards for CO
are termed “CO hotspots.” SCAQMD’s CEQA Air Quality Handbook identifies CO as a localized
problem requiring additional analysis when a project is likely to subject sensitive receptors to CO
hotspots.
Based on analyses of localized concentrations within the Basin, the SCAQMD concluded that even
the most congested intersection in Los Angeles County, the intersection of Wilshire Boulevard
and Veteran Avenue, which has an average daily traffic volume of 100,000 vehicles per day, did
not result in a CO hotspot exceeding the SCAQMD standards (SCAQMD 2003). Moreover, based
on analyses of localized concentrations within the San Francisco Bay Area, which has similar
ambient CO concentrations as SRA 2, a project would have to increase traffic volumes at affected
intersections to more than 44,000 vehicles per hour for a CO hotspot to occur.
Sensitive Receptors
Sensitive receptors are populations that are more susceptible to the effects of air pollution than the
population at large. According to California ARB, sensitive receptors include children less than
14 years of age, the elderly over 65 years of age, athletes, and people with cardiovascular and
chronic respiratory diseases. While the ambient air quality standards are designed to protect public
health and are generally regarded as conservative for healthy adults, there is greater concern to
protect adults who are ill or have long-term respiratory problems, and young children whose lungs
are not fully developed. The SCAQMD CEQA Air Quality Handbook identifies the following as
locations that may contain a high concentration of sensitive receptors: long-term health care
Airport Park Expansion Project 3.1-9
Final EIR – January 2018
3.1 AIR QUALITY
facilities, rehabilitation centers, convalescent centers, retirement homes, residences, schools,
playgrounds and parks with active recreational uses, childcare centers, and athletic facilities.
The existing Airport Park is a sensitive receptor and the nearest offsite sensitive uses to the Project
site include the residences surrounding the Santa Monica Municipal Airport (SMO), particularly
to the east and south. These residential and recreational uses would be considered sensitive
receptors to air quality with respect to the Project. The sensitive receptors outside the Project site
are listed below:
• Grand View Boulevard residential neighborhood, located east of the Project site across
South Bundy Drive — apartment buildings located at 3051 Grand View Boulevard and
single-family residences located along Grand View Avenue and side streets.
• Santa Monica College South Bundy Campus, 3171 South Bundy Drive, located southeast
of the Project site across Airport Avenue — a community college which provides
additional special classes for children and teens. The Santa Monica College South Bundy
Campus is located within the City of Los Angeles.
• Dewey Street residential neighborhood, located south of the Project site across Airport
Avenue — a residential street with single-family residences located within the City of Los
Angeles.
Sensitive land uses in the Project vicinity include the residential neighborhood adjacent to the Project site across
South Bundy Drive, including many units with balconies or patios facing directly toward the Project site (left). The
Santa Monica College Bundy Campus provides community college courses and other educational amenities, in
addition to providing special classes for children and teens.
Source: Google Earth 2017.
3.1-10 Airport Park Expansion Project
Final EIR – January 2018
3.1 AIR QUALITY
3.1.2 Regulatory Framework
Air quality within the Basin is addressed through the efforts of various federal, state, regional, and
local government agencies. These agencies work jointly, as well as individually, to improve air
quality through legislation, regulations, planning, policy-making, education, and a variety of
programs. The agencies responsible for improving the air quality within the air basins are discussed
below.
Federal
Clean Air Act
The federal CAA was passed in 1963 and amended in 1990, and was the first comprehensive
federal law to regulate air emissions from stationary and mobile sources. Among other things, the
law authorizes the U.S. EPA to establish national ambient air quality standards. The NAAQS helps
to ensure basic health and environmental protection from air pollution. The CAA also gives the
U.S. EPA the authority to limit emissions of air pollutants coming from sources like chemical
plants, utilities, and steel mills.
U.S. Environmental Protection Agency
The U.S. EPA is responsible for setting and enforcing the NAAQS for the six criteria air pollutants.
It also regulates emission sources that are under the exclusive authority of the federal government,
such as aircraft, ships, and certain locomotives. The U.S. EPA also maintains jurisdiction over
emissions sources outside state waters (outer continental shelf), and establishes various emissions
standards for vehicles sold in states other than California.
As part of its enforcement responsibilities, the U.S. EPA requires each state with federal
nonattainment areas to prepare and submit a State Implementation Plan (SIP) that demonstrates
the means to attain the federal standards. The SIP must integrate federal, state, and local plan
components and regulations to identify specific measures to reduce pollution, using a combination
of performance standards and market-based programs within the timeframe identified in the SIP.
State
California Clean Air Act
The CCAA requires all areas of the state to achieve and maintain the CAAQS by the earliest
practicable date. The CAAQS includes more stringent standards than the NAAQS.
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California Air Resources Board
California ARB, a part of the California Environmental Protection Agency (Cal EPA), is
responsible for the coordination and administration of both federal and state air pollution control
programs within California. In this capacity, California ARB conducts research, sets CAAQS,
compiles emission inventories, develops suggested control measures, provides oversight of local
programs, and prepares the SIP. California ARB establishes emissions standards for motor
vehicles sold in California, consumer products (such as hair spray, aerosol paints, and barbecue
lighter fluid), and various types of commercial equipment. It also sets fuel specifications to further
reduce vehicular emissions.
In April 2005, California ARB issued a guidance document on air quality and land use, Air Quality
and Land Use Handbook: A Community Health Perspective, which recommends that sensitive
land uses not be located within 500 feet of a freeway or other high traffic roadway and that a site-
specific health risk assessment (HRA) be performed as a way to more accurately evaluate the risk.
In traffic-related studies, the additional non-cancer health risk attributable to proximity to high-
volume roadways was seen within 1,000 feet and was strongest within 300 feet. California freeway
studies show about a 70 percent drop-off in particulate pollution levels at 500 feet. The Project site
does not lie within 500 feet of a freeway or roadway that carries more than 100,000 vehicles on
average per day. However, the Project site lies within approximately 300 feet of the south SMO
runway, which produce emissions of diesel particulate matter (DPM) from airplane and jet
operations. For this reason, an HRA has been prepared to evaluate the risk associated with airport
operations on visitors to the Project site, which would include sensitive populations, including
children and elderly persons (Appendix B).
California Air Toxics “Hot Spots” Information and Assessment Act
The Air Toxic “Hot Spots” Information and Assessment Act identifies TAC hot spots where
emissions from specific stationary source facilities may expose individuals to an elevated risk of
adverse health effects. It requires that a business or other establishment identified as a significant
source of toxic emissions provide the affected population with information about health risks posed
by the emissions.
The nearest stationary source facility subject to the Air Toxic “Hot Spots” Information and
Assessment Act is the Santa Monica Propeller Service, located approximately 50 feet northwest
of the Project site. There is also a Volkswagen of America stationary source facility located
approximately 1,130 feet northwest of the Project site, on the opposite side of the SMO runway.
Both of these facilities are part of SMO operations. Although SMO is not considered a stationary
3.1-12 Airport Park Expansion Project
Final EIR – January 2018
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source subject to this Act, a HRA was performed in order to determine the health risk impacts of
TACs from airport operations on visitors to and employees of Airport Park.
ARB Off-Road Mobile Sources Emission Reduction Programs
The CCAA mandates California ARB to achieve the maximum degree of emission reductions from
all off-road mobile sources in order to attain the state ambient air quality standards. Off-road
mobile sources include heavy construction equipment. Tier 1, Tier 2, and Tier 3 standards for large
compression-ignition engines used in off-road mobile sources went into effect in California for
most engine classes in 1996, 2001, and 2006, respectively. Tier 4 or Tier 4 Interim (4i) standards
apply to all off-road diesel engines model year 2012 or newer. In addition, equipment can be
retrofitted to achieve lower emissions using the ARB-verified retrofit technologies. The engine
standards and ongoing rulemaking jointly address the products of diesel combustion, including
emissions and toxic DPM. The California Emission Standards for Off-Road Compression-Ignition
Engines are as specified in California Code of Regulations (CCR) Title 13, Division 3, Chapter 9,
Article 4, Section 2423.
Regional
South Coast Air Quality Management District
SCAQMD is the agency principally responsible for comprehensive air pollution control in the
Basin. To that end, SCAQMD, a regional agency, works directly with the Southern California
Association of Governments (SCAG), county transportation commissions, local governments, and
cooperates actively with all federal and state government agencies. SCAQMD develops rules and
regulations, establishes permitting requirements, inspects emissions sources, and enforces such
measures though educational programs or fines, when necessary. SCAQMD is directly responsible
for reducing emissions from stationary (area and point), mobile, and natural sources.
Air Quality Management Plan
The Air Quality Management Plan (AQMP) responds to the air quality mandates of the CAA and
CCAA by preparing a series of AQMPs. The most recent of these was adopted by the Governing
Board of SCAQMD on March 3, 2017. This AQMP, referred to as the 2016 AQMP, was prepared
to comply with the CAA and CCAA, and amendments, to accommodate growth, to reduce the
high pollutant levels in the Basin, to meet federal and state ambient air quality standards, and to
analyze the impact of existing pollution control measures.
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The 2016 AQMP aims to attain the 2006 federal 24-hour PM2.5 standard by 2019, the 1979 1-hour
ozone standard by 2022, the 1997 8-hour ozone standard by 2023, the 2012 annual PM2.5 standard
by 2025, and the 2008 8-hour ozone by 2031.
The most significant air quality challenge in the Basin is to reduce NOx emissions sufficiently to
meet the upcoming ozone standard deadlines. The 2016 AQMP analysis suggests that total Basin
emissions of NOx must be reduced 45 percent by 2023, and an additional 55 percent beyond 2031.
The strategy to meet the 8-hour ozone standard in 2023 should lead to sufficient NOx emission
reductions to attain the 1-hour ozone standard by 2022. Also, since NOx emissions also lead to the
formation of PM2.5, the NOx reductions needed to meet the ozone standards will likewise lead to
improvement of PM2.5 levels and attainment of PM2.5 standards.
The 2016 AQMP represents a thorough analysis of existing and potential regulatory control
options, includes available, proven, and cost-effective strategies, and seeks to achieve multiple
goals in partnership with other entities promoting reductions in GHGs and toxic risk, as well as
efficiencies in energy use, transportation, and goods movement. These planning efforts have
substantially decreased the population’s exposure to unhealthful levels of pollutants, even while
substantial population growth has occurred within the Basin.
SCAQMD Rule Book
The SCAQMD has adopted the SCAQMD Rule Book, which establishes a set of rules and
regulations that address air pollution sources. Some SCAQMD rules are administrative in nature,
but many relate to a specific type of operation or source of pollution. Because knowledge about
air pollution is constantly growing, these rules and regulations are in a dynamic state, constantly
changing. Each regulation is broken down into several rules, each of which deals with a specific
topic. SCAQMD rules that may apply to the Project include:
• Rule 402 Nuisance – This rule prohibits discharge from any source whatsoever such
quantities of air contaminants or other material which cause injury, detriment, nuisance, or
annoyance to any considerable number of persons or to the public, or which endanger the
comfort, repose, health or safety of any such persons or the public, or which cause, or have
a natural tendency to cause, injury or damage to business or property.
• Rule 403 Fugitive Dust – The purpose of this rule is to reduce the amount of particulate
matter (e.g., PM10) entrained in the ambient air as a result of anthropogenic (man-made)
fugitive dust sources, such as grading and excavation, by requiring actions to prevent,
reduce or mitigate fugitive dust emissions.
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• Rule 1113 Architectural Coatings – This rule requires manufacturers, distributors, and end
users of architectural and industrial maintenance coatings to reduce VOC emissions from
the use of these coatings, primarily by placing limits on the VOC content of various coating
categories. For example, exterior paints and finishes are limited to a VOC emissions rate
of 50 grams per liter (g/L).
• Rule 1186 PM10 Emissions from Paved and Unpaved Roads – This rule applies to owners
and owners of paved and unpaved roads. The rule is intended to reduce PM10 emissions by
requiring the cleanup of material deposited onto paved roads, use of certified street
sweeping equipment, and treatment of high-use unpaved roads.
• Rule 1401 New Source Review of Toxic Air Contaminants – This rule specifies limits for
maximum individual cancer risk (MICR) cancer burden, and non-cancer acute and chronic
hazard index (HI) from new sources which emit toxic air contaminants.
CEQA Air Quality Handbook
Although the SCAQMD is responsible for regional air quality planning efforts, it does not have
the authority to directly regulate the air quality issues associated with plans and new development
projects within its jurisdiction. Instead, the SCAQMD has used its expertise and prepared the
CEQA Air Quality Handbook (1993). Over the years, the SCAQMD has supplemented the CEQA
Air Quality Handbook with updated/new thresholds of significance published on its website. The
purpose of the CEQA Air Quality Handbook and updated/newer thresholds of significance is to
assist lead agencies, as well as consultants, project proponents, and other interested parties, in
evaluating potential air quality impacts of projects and plans proposed in the Basin. The CEQA
Air Quality Handbook and newer thresholds of significance provide direction on how to evaluate
potential air quality impacts in CEQA documents, how to determine whether these impacts are
significant, and how to mitigate these impacts. The SCAQMD intends that by providing this
guidance, the air quality impacts of plans and development proposals will be analyzed accurately
and consistently throughout the region, and adverse impacts will be minimized. Although the
Governing Board of the SCAQMD has adopted the CEQA Handbook, and is in the process of
updating it, the SCAQMD does not, nor intends to, supersede a local jurisdiction’s CEQA
procedures.
Southern California Association of Governments
SCAG is the Metropolitan Planning Organization for Imperial, Los Angeles, Orange, Riverside,
San Bernardino, and Ventura Counties. SCAG serves as the regional planning agency for regional
issues relating to transportation, the economy and community development, and the environment.
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Although SCAG is not an air quality management agency, it is responsible for developing
transportation, land use, and energy conservation plans and policies that affect air quality. As
required by SB 375, SCAG was tasked with developing a Sustainable Communities Strategy
(SCS), a required element of the Regional Transportation Plan (RTP) that provides a plan for
meeting GHG emissions reduction targets set forth by the ARB. SCAG’s 2016–2040 Regional
Transportation Plan/Sustainable Communities Strategies (RTP/SCS) provides growth forecasts
that are used in the development of land use and transportation planning strategies to reduce air
quality emissions and greenhouse gas emissions. These growth forecasts are in turn utilized by the
SCAQMD in its development of the AQMP. The 2016–2040 RTP/SCS places a greater emphasis
on integrated land use and transportation planning, sustainability, preserving existing
transportation infrastructure while giving people more transportation choices, leveraging
technology, and supporting commerce, economic growth, and opportunity. Refer to Section 3.3.2
for a discussion of the RTP/SCS and GHGs.
Local
City of Santa Monica
As a local jurisdiction, the City has the authority and responsibility to reduce air pollution through
its police power and decision-making authority. Specifically, the City is responsible for the
assessment and mitigation of air emissions resulting from its land use decisions. The City is also
responsible for the implementation of transportation demand management measures as outlined in
the AQMP (SCAQMD 2016b). In accordance with CEQA requirements and the CEQA review
process, the City assesses the air quality impacts of new development projects, requires mitigation
of potentially significant air quality impacts by conditioning discretionary permits, and monitors
and enforces implementation of such mitigation.
City of Santa Monica General Plan Land Use and Circulation Element (LUCE)
The City of Santa Monica General Plan Land Use and Circulation Element (LUCE) was adopted
by the City on July 6, 2010 (and most recently amended on July 24, 2015), and includes the
following policies that are directly related to reducing air quality impacts. Other proposed policies,
as set forth in Section 3.3, Greenhouse Gas Emissions, and Section 3.7, Transportation and
Traffic, also have the practical effect of reducing air pollution by reducing vehicle miles traveled
and energy consumption.
Goal S5: Improve the environmental performance of buildings.
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Policy S5.8. Encourage installation of electrical outlets in loading zones and on the exterior
of new buildings to reduce emissions from gas-powered landscape maintenance and
operating refrigeration for delivery trucks.
Goal T25: Design parking to meet applicable urban design goals and minimize negative impacts
on pedestrians, bicyclists, and transit users.
Policy T25.7. Encourage installation of electrical outlets in loading zones, including
signage, to reduce vehicle idling associated with operating refrigeration for delivery trucks.
City of Santa Monica General Plan Conservation Element
The City of Santa Monica General Plan Conservation Element (1975) has identified the following
goals and objectives for improving air quality:
Goal: An atmosphere free of pollution.
Objectives. 1. Eliminate all detrimental sources of air pollution.
2. Encourage lowest feasible emission from stationary and
moving sources.
3. Cooperate with and support federal, state, and regional efforts
to reduce smog and pollution.
4. Reduce the total volume of vehicular traffic.
Other City Programs
Local jurisdictions, such as the City, have the shared responsibility to help develop and implement
some of the control measures of the AQMP. Transportation-related strategies for congestion
management, low emission vehicle infrastructure, and transit accessibility and non-transportation-
related strategies for energy conservation can be encouraged by policies of local governments.
As part of this effort, the City has several existing programs that it uses to improve health and
sustainability of the community through improved regional air quality and reduced GHG emissions
(discussed in Section 3.3, Greenhouse Gas Emissions). These programs/regulations include:
• Transit Ridership—The City collaborates with local transit agencies to develop programs
and educate employers about employee rideshare and transit opportunities. The City
promotes mass transit ridership through careful planning of routes and by maintaining a
local point of contact for potential ride-sharers.
• Low Emission City Fleet Vehicles—The City has purchased, and continues to purchase,
low-emission vehicles for the City’s fleet and uses available clean fuel sources for trucks
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and heavy equipment. The City Fleet Management Division has set a goal for 75 percent
of Public Works vehicles to be alternatively fueled.
• Transportation Systems Management and Trip Reduction—The City has implemented
a variety of strategies, including Chapter 9.53, Transportation Demand Management, of
the City Zoning Code, which encourages employees to use means other than a single-
occupant vehicle for their daily work commute and promotes alternate modes of
transportation for employees such as: walking, carpooling, vanpooling, biking, using
public transit, compressed work schedules, telecommuting, and other nonpolluting forms
of transit.
• Incentives for Privately Owned Low-Emission Vehicles—The City encourages the use
of zero- and low-emission vehicles, and provides incentives such as free parking at City
meters. Additionally, electric vehicle spaces are required to be included in new parking
facilities. Alternative fuel and electric recharging stations have also been installed at
various locations throughout the City. Evaluation of other sites is currently under review.
• Employer Education Programs—The City encourages employers to participate in
SCAQMD public education programs.
• Business Greening Program—The City implemented “The Business Greening Program”
which assists local businesses to increase resource efficiency and “green their bottom-line.”
Ordinance 8.108 implements Green Building Standards.
• Emissions Reduction—The City requires new development projects that exceed the
SCAQMD VOC and operational thresholds to incorporate design or operational features
that reduce emissions equal to 15 percent from the level that would be produced by an
unmitigated project.
• Citywide Greenhouse Gas Assessment—The City is committed to complying with
pertinent state regulations to assess citywide GHG emissions for existing land uses and the
future development. The Santa Monica Sustainable City Plan has developed indicators to
assess citywide GHG emissions for existing land uses. These indicators are monitored on
an ongoing basis and results are published regularly in “Report Cards.”
• Preference for Renewable Energy—The City was the first in the nation to purchase
“green” energy produced from nonpolluting geothermal sources in Central California.
Further, the City maintains the Solar Santa Monica Program to increase renewable energy
production locally and adopted a Net Zero Energy Plan on October 25, 2016.
• Ban on Gasoline Powered Leaf Blowers—Section 4.08.270 of the City Municipal Code
bans the operation of gasoline powered leaf blowers within the City limits.
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3.1.3 Impact Assessment and Methodology
Thresholds for Determining Significance
Appendix G of the 2017 CEQA Guidelines provides a set of screening questions that address
impacts on air quality. Specifically, the Guidelines state that a proposed project may have a
significant adverse impact on air quality if the project would:
a) Conflict with or obstruct implementation of the applicable air quality plan;
b) Violate any air quality standard or contribute substantially to an existing or projected air
quality violation;
c) Result in a cumulatively considerable net increase of any criteria pollutant for which the
project region is in nonattainment under an applicable federal or state ambient air quality
standard (including releasing emissions that exceed quantitative thresholds for ozone
precursors);
d) Expose sensitive receptors to substantial pollutant concentrations; and/or
e) Create objectionable odors affecting a substantial number of people.
SCAQMD, the air pollution control agency in the Basin, has developed specific regional and local
significance thresholds for air quality impacts, and recommends that projects in the Basin be
evaluated in terms of these thresholds. The City uses these SCAQMD thresholds to assess whether
air pollution effects of a proposed project are significant. The following thresholds are currently
recommended by the SCAQMD and have been used to determine the significance of air quality
impacts associated with the proposed Project.
Construction Emissions Thresholds
The SCAQMD’s thresholds recommend that projects with construction-related emissions that
exceed any of the following regional (max daily) emissions should be considered potentially
significant.
• 550 pounds per day of carbon monoxide (CO)
• 100 pounds per day of nitrogen oxides (NOX)
• 150 pounds per day of sulfur oxides (SOX)
• 75 pounds per day of reactive organic gases (VOC)
• 150 pounds per day of Respirable Particulate Matter (PM10)
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• 55 pounds per day of Fine Particulate Matter (PM2.5)
In addition, localized significance thresholds (LSTs) were developed for construction phases in
response to the SCAQMD Governing Board’s Environmental Justice Enhancement Initiative I-4.
LSTs represent the maximum emissions from a project that are not expected to 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 consideration ambient concentrations in each
SRA, project size, and distance to the sensitive receptor, etc. LSTs are only applicable for
emissions of CO, NOx, PM10, and PM2.5. LSTs only apply to emissions at a fixed location,
including idling emissions, during both project construction and operation. LSTs do not apply to
emissions from mobile sources traveling over roadways.
The LST methodology recommends that project-specific air quality modeling be performed for
project areas that exceed five acres in size. California Emission Estimator Model (CalEEMod)
results can be used in determining the maximum daily disturbed acreage.
Although the area of disturbance required for the Project is greater than five acres, a SCAQMD
mass rate look-up threshold was used as a conservative approach. Maximum onsite emissions from
all phases of construction across approximately 15.8 acres of the Project site were compared to
mass look-up thresholds for a five-acre site, which designate lower emissions thresholds than
would be allowed if project-specific modeling were completed for an area of disturbance of
15.8 acres.
The Project site is located in SRA 2. The existing Airport Park is a sensitive use and the nearest
offsite sensitive receptors to the Project site are located approximately 25–30 meters from the
eastern boundary of the Project site, and consist of the residential uses located across South Bundy
Drive to the east of the Project site. SCAQMD’s thresholds recommend that projects with
construction emissions that exceed any of the following LSTs should be considered potentially
significant.1
• 1,531 pounds per day of CO
• 221 pounds per day of NOx
• 13 pounds per day of PM10
• 6 pounds per day of PM2.5
1 LST based in SRA-2 within a 25-meter distance of sensitive receptors, and using SCAQMD, Appendix C – Mass Rate
LST Look-up Table, revised October 2009.
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Final EIR – January 2018
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Operational Emissions Thresholds
SCAQMD’s thresholds recommend that projects with operational emissions that exceed any of the
following regional (max daily) emissions should be considered potentially significant.
• 550 pounds per day of CO
• 55 pounds per day of NOX
• 150 pounds per day of SOX
• 55 pounds per day of VOC
• 150 pounds per day of PM10
• 55 pounds per day of PM2.5
Toxic Air Contaminants
The California ARB indicates that one of the highest public health priorities is the reduction of
DPM generated by vehicles on California’s freeways and highways, as it is one of the primary
TACs. The nearest freeway is I-10, located approximately 3,500 feet north of the Project site.
Other potential TAC generators within the Project vicinity are associated with specific types of
facilities, such as gas stations, dry cleaners, and auto body repair shops, and are the focus of local
control efforts. The California ARB has made specific recommendations with respect to
considering existing sensitive uses when siting new TAC-emitting facilities or with respect to
TAC-emitting sources when siting sensitive receptors. The California ARB recommends the
following buffer distances be observed when locating these types of TAC emitters or sensitive
land uses:
• Freeways or major roadways - 500 feet
• Dry cleaners - 500 feet
• Auto body repair services - 500 feet
• Gasoline dispensing stations with an annual throughput of less than 3.6 million gallons -
50 feet; gasoline dispensing stations with an annual throughput at or above 3.6 million
gallons - 300 feet
SCAQMD recommends that site-specific health risk assessments be performed to document
potential cancer risk when siting sensitive land uses within the above buffer zones. Although the
Project site is located outside of the established buffer zone for these identified land uses, it is
located within 300 feet of SMO and the airport’s runway. Since the emissions from aircraft
operations may combine with other sources of TACs (such as the I-10 Freeway and local
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roadways) to result in health risk impacts to visitors of Airport Park, a health risk assessment
(HRA) was prepared for the Project (Appendix B). Based on the methodology established by the
Office of Environmental Health Hazard Assessment (OEHHA) and the SCAQMD, the following
thresholds have been established to determine the MICR, and HI for development of the Project:
• MICR – cancer risk of less than 10 in one million
• HI – highest chronic health index of less than 1
Cumulative Impacts
In order to assess cumulative impacts, the SCAQMD recommends that projects be evaluated to
determine whether they would be consistent with current AQMP performance standards and
project-specific emissions thresholds. In the case of the Project, air pollutant emissions would be
considered to be cumulatively considerable if the new sources of emissions exceeded SCAQMD
emissions thresholds.
Methodology
This analysis focuses on the air quality impacts that could occur from air pollutant emissions
associated with the construction and operation of the proposed Project, including impacts from
Project-related traffic volumes. Project-related construction and operational emissions were
estimated using SCAQMD’s CalEEMod Version 2016.3.1, and then compared to the thresholds
of significance defined above. See Appendix C for CalEEMod worksheet results.
Construction Emissions
Construction emissions are estimated using CalEEMod, which estimates emissions from each
phase of Project construction, including demolition, excavation and site preparation, and
construction (which is subdivided into building construction, paving, and architectural coating for
the purposes of evaluating air quality impacts). Emission estimates are based on the anticipated
types and amount of equipment that would be used in Project construction, the amount of
demolition debris and excavated soil to be removed, the size and type of new construction,
anticipated construction schedule, and the vehicle trips generated by construction workers.
Project construction would temporarily increase emissions of DPM and would generate particulate
matter (dust). Construction equipment within the Project site that would generate DPM and NOx
emissions could include graders, excavators, dump trucks, cranes, and bulldozers. Although much
of the smaller construction equipment would be electrically powered, this analysis conservatively
assumed that all heavy construction equipment used would be diesel powered. The precise
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Final EIR – January 2018
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construction timeline for the Project depends on the timing of entitlements and City approvals. For
the purposes of studying the worst-case emissions for this EIR, construction activity for the Project
is assumed to begin in 2019, with occupancy and operation commencing in 2020. The Project’s
construction activities and estimated durations are as follows:
• Demolition – 1 month
• Excavation/Grading – 1 month 2
• Building construction – 9.5 months
• Paving – 1 month
• Architectural coating – 0.5 month
Localized Significance Thresholds for Construction
The potential for Project construction emissions to cause localized impacts at nearby sensitive
receptor locations was analyzed using SCAQMD’s LST threshold methodology. LSTs are only
applicable for NOx, CO, PM2.5, and PM10.
The area of disturbance from the Project would be greater than five acres. As a conservative
approach, a SCAQMD mass rate look-up threshold was used. Maximum on-site emissions from
all phases of construction across approximately 15.8 acres of the Project site were compared to
mass look-up thresholds for a five-acre site, which designate lower emissions thresholds than
would be allowed if project-specific modeling were completed for an area of disturbance of
15.8 acres.
Operational Emissions
Operational emissions associated with the Project are estimated using CalEEMod for mobile
source, area, and energy emissions. Mobile emissions would be generated by the net increase in
motor vehicle trips to and from Airport Park and are calculated based on the CalEEMod default
traffic assumptions (Appendix C) and adjusted based on trip generation estimates in the Project’s
Traffic Impact Assessment (Appendix F). Area source emissions would be generated by landscape
maintenance equipment and consumer products. Energy source emissions would be generated by
emissions resulting from electricity and natural gas consumption for park facilities, lighting, and
the Project’s two concession/restroom buildings. To determine if an air quality impact would
occur, the increase in emissions was compared with the SCAQMD’s regional (mass daily)
2 As discussed in Section 2.0, Project Description, of this Draft EIR, Project excavation and grading could occur over a
period of 1-2 months. However, the evaluation of air quality impacts assumes that excavation and grading would be
completed within one month because it presents a conservative analysis (i.e., compressing equipment usage into one
month increases air emissions).
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Final EIR – January 2018
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thresholds. The default emissions were used for area and energy sources with consideration of
SCAQMD rules and regulations that would be required of the Project related to the Project’s
operations.
As discussed above, the west paved surface area is currently occupied by aviation-related
businesses (e.g., Proteus Air) that generate emissions of air pollutants. While these businesses
would be removed from the Project site to accommodate the Project, their operation may be
relocated and continued at another location at SMO. Therefore, the CalEEMod estimates
conservatively do not take credit for any reduction in emissions that would occur if these
businesses were to cease operation as a result of the Project.
3.1.4 Project Impacts and Mitigation Measures
Would the project conflict with or obstruct implementation of the applicable air quality plan?
AQ-1 Construction and operation of the Project would generate emissions that
would contribute to Basin-wide air pollutant emissions. However, since the
Project would not increase the severity of or cause existing air quality
violations and would not generate population growth such that the AQMP’s
population forecast would be exceeded, the Project would not conflict with the
AQMP and this impact would be less than significant.
Impact Description (AQ-1)
As further discussed in Impact Description AQ-2 below, Project construction would occur in
accordance with applicable regulations and plans to reduce emissions from construction activities,
including CCR Title 13, SCAQMD Rule 403, SCAQMD Rule 1186, and SCAQMD Rule 1113.
In addition, control strategies in the AQMP that address short-term construction emissions
construction would be followed, including the strategies denoted in the AQMP as ONRD-04 and
OFFRD-01, which are intended to reduce emissions from on-road and off-road heavy-duty
vehicles and equipment by accelerating replacement of older, emissions-prone engines with newer
engines meeting more stringent emissions standards. As discussed in Impact Description AQ-2
below, the Project would be constructed using equipment meeting Tier 3 Emissions Standards for
Off-Road Compression-Ignition Engines, or higher. Therefore, the Project would not conflict with
the implementation of these strategies.
A Project is deemed inconsistent with the air quality plan if it results in population and/or
employment growth that exceeds growth estimates in the applicable air quality plan. Generally, a
proposed project would conflict with or potentially obstruct implementation of an air quality plan
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Final EIR – January 2018
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if a project would contribute to population growth in excess of that forecasted in the SCAQMD’s
adopted 2016 AQMP. In turn, the AQMP relies upon growth projections adopted by SCAG, which
in turn relies upon cities’ adopted general plan growth projections. Consequently, compliance with
the City’s General Plan typically results in compliance with the AQMP. 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 does not involve development of new housing, and would not directly generate long-
term residential population increases. Rather, as an expansion to the existing Airport Park, the
Project is intended to serve the existing population and anticipated future population. The Project
would generate short-term employment opportunities during construction, but would not generate
any long-term employment opportunities during operation. Since these short-term employment
opportunities would not significantly increase the population of the City, there would be no indirect
increase in residential population that could result in substantial population growth. Accordingly,
since no population growth is anticipated to result from the Project, no conflicts with the AQMP
would occur, and this impact would be less than significant.
Would the project violate any air quality standard or contribute substantially to an existing or
projected air quality violation?
AQ-2 Construction activity for the Project would generate air pollutant emissions.
Emissions of NOx, VOC, PM10, PM2.5, SOx, and CO would not exceed
SCAQMD regional thresholds; therefore, this impact would be less than
significant.
Impact Description (AQ-2)
Construction activities for the Project would include demolition and removal of the existing paved
areas, aviation-related structures, limited ornamental vegetation/trees, and the existing alignment
of Donald Douglas Loop South. It would also include the excavation of the Project site to a depth
of approximately 5 feet below existing grade, with a net export of 5,000 cubic yards (cy) of soil,
and would include building construction, paving, and architectural coating. Construction pollutant
emissions, such as NOx and PM10, would be generated through the use of heavy-duty construction
equipment and through vehicle trips generated by construction workers traveling to and from the
Project site. In addition, fugitive dust emissions would result from demolition, earthwork, and
construction activities. During the finishing phase, paving, and the application of architectural
coatings (i.e., paints) and other building materials would release VOCs.
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Construction emissions can vary substantially from day to day, depending on the level of activity,
the specific type of operation and, for dust, prevailing weather conditions. Compliance with several
existing state and local regulations would substantially limit the generation of construction
emissions related to the Project, including construction vehicles, excavation, building construction,
and architectural coating. A summary of these regulations and their objectives is provided herein.
As required by the U.S. EPA (beginning in 2000) and the California ARB (beginning in 2006),
and as specified in the CCR Title 13, Division 3, Chapter 9, Article 4, Sec. 2423(b)(1), all off-road
diesel engines are required to meet at a minimum the Tier 3 Emission Standards for Off-Road
Compression-Ignition Engines (with proper diesel particulate controls).Although Tier 4 or Tier 4
Interim (4i) standards apply to all off-road diesel engines model year 2012 or newer and would
likely be present in the fleet mix, this analysis takes a conservative approach by assuming that
none of the off-road construction equipment would meet Tier 4 standards, but would at least meet
Tier 3 standards. Tier 3 vehicles operate with significantly less emissions than Tier 1 or Tier 2, as
regulated by the U.S. EPA. Heavy off-road construction equipment used for the Project would
comply with state and federal operational standards to reduce the potential generation of NOx or
PM10 emissions for off-road diesel vehicles in compliance with CCR.
Additionally, SCAQMD Rule 403 requires management of all fugitive dust (PM10) generated
during Project construction. All heavy-haul trucks would be required to be covered to contain dirt,
sand, soil, or other loose materials during transport. Wheel washers would be installed where
vehicles enter and exit the construction site onto paved roads, and/or wash-off trucks would be
required for any equipment leaving the site each trip to prevent tracking of construction dust/dirt
offsite. The Project would be required to control dust during construction, including application of
water two times daily, or by application of non-toxic soil stabilizers to all unpaved parking or
staging areas or unpaved road surfaces, as well as application of non-toxic soil stabilizers to all
inactive construction areas. The Project would also be required to comply with SCAQMD Rule
1186, which requires certified street sweepers or roadway washing trucks if visible soil materials
are carried onto adjacent streets. Compliance with these requirements would ensure that fugitive
dust and NOx emissions would be minimized during the demolition, excavation, building
construction, and paving phases of the Project.
The majority of the Project’s VOC emissions would be generated from the application of
architectural coatings, including paints, stains, and other finishes that off-gas VOCs during the
drying/curing process. However, in compliance with the SCAQMD Rule 1113, the Project would
use “No VOC” or “Low VOC” finishes (VOC emission ratings <50g/L). Use of No VOC or Low
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Final EIR – January 2018
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VOC finishes would ensure that VOC emissions during the architectural coating phase of
construction would be minimized.
Total pollutant emissions for Project construction were estimated using CalEEMod for each stage
of construction, including demolition, grading/excavation, building construction, paving, and
architectural coating. The maximum emissions levels for each pollutant on a daily basis were also
estimated using CalEEMod for each year of the construction phase from early 2018 through early
2019 and compared to SCAQMD thresholds for maximum daily emissions (see Table 3.1-2).3 The
CalEEMod estimates of construction emissions assume the Project’s construction activities would
comply with SCAQMD and California ARB regulations. As indicated in Tables 3.1-2 and 3.1-3,
overall construction emissions would not exceed SCAQMD thresholds for NOx, VOC, PM10,
PM2.5, SOx, or CO. Therefore, air quality impacts related to construction emissions would be less
than significant.
Table 3.1-2. Maximum Estimated Daily Construction Emissions for the Project by
Construction Phase (pounds/day)
Air Pollutant
Onsite Construction Emissions (pounds/day)
Demolition
(2018)
Grading
(2018)
Building
Construction
(2018)
Paving
(2018-2019)
Architectural
Coating
(2019)
NOx 47.99 63.84 60.46 22.71 1.41
VOC 2.49 3.32 3.68 2.20 6.70
PM10 11.46 7.10 4.07 1.56 0.26
PM2.5 3.51 4.21 3.27 1.31 0.14
SOx 0.10 0.14 0.13 0.05 0.01
CO 58.34 74.33 72.63 36.02 2.51
Notes: Refer to Appendix C for CalEEMod output sheets.
3 While Section 2.0, Project Description, describes a 2019-2020 construction schedule, the air pollutant modeling prepared
using CalEEMod software was run assuming a reasonable worst-case scenario for construction emissions in the event
Project construction should begin in 2018.
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Table 3.1-3. Maximum Estimated Daily Construction Emissions for the Project compared
to SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds2
Onsite Construction Emissions1 Exceeds Threshold? 2018 2019
NOx 100 63.84 11.35 No
VOC 75 3.68 6.70 No
PM10 150 11.46 0.78 No
PM2.5 55 4.21 0.66 No
SOx 150 0.14 0.02 No
CO 550 74.33 17.97 No
Notes: Bold text indicates the highest potential daily emission level from onsite and offsite sources over the assumed Project
construction period (early 2018 – early 2019).
1 Refer to Appendix C for CalEEMod output sheets.
2 Source: SCAQMD 2015.
AQ-3 Operation of the Project would generate air pollutant emissions that would be
below SCAQMD mass daily thresholds; therefore, this impact would be less
than significant.
Impact Description (AQ-3)
Operational emissions of the Project include those generated by the addition of new vehicle trips
(mobile emissions) to and from the Project site, the use of landscaping maintenance equipment
and consumer products (area source emissions), and the use of natural gas (energy emissions) and
the use of appliances (e.g., microwaves, food preparation appliances) for the concession/bathroom
buildings. Maximum daily operational emissions of the Project were estimated using CalEEMod.
As indicated in Table 3.1-4, the maximum operational emissions anticipated during operation of
the Project would not exceed SCAQMD thresholds for NOx, VOC, PM10, PM2.5, SOx, or CO;
therefore, this impact would be less than significant.
Table 3.1-4. Maximum Estimated Operational Emissions for the Project compared to
SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds2
Onsite Operational Emissions1 Exceeds
Threshold Area Energy Mobile Overall
NOx 55 0.00 0.00 4.94 4.94 No
VOC 55 3.69 0.00 0.99 4.68 No
PM10 150 0.00 0.00 3.21 3.21 No
PM2.5 55 0.00 0.00 0.89 0.89 No
SOx 150 0.00 0.00 0.04 0.04 No
CO 550 0.00 0.00 12.26 12.26 No
1 Refer to Appendix C for CalEEMod output sheets.
2 Source: SCAQMD 2015.
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Would the project expose sensitive receptors to substantial pollutant concentrations?
AQ-4 Onsite construction-related emissions would not exceed the SCAQMD
localized significance thresholds (LSTs), would not generate substantial Toxic
Air Contaminants (TACs), and would not place sensitive receptors within
buffer zones of potential TAC emitters; therefore, this impact would be less
than significant.
Impact Description (AQ-4)
The existing Airport Park, which the Project would be expanding, would remain open during
construction, and is a sensitive receptor. At the eastern site perimeter, the Project site is located
approximately 25–30 meters from additional sensitive receptors, including residences located east
of the Project site across South Bundy Drive (see also, Section 3.1.1, Existing Setting). Visitors to
Airport Park and these residences could experience adverse health effects from PM10, PM2.5, CO,
or NOx if concentrations exceed the LSTs. For example, fugitive dust (PM) would be generated
due to the earthwork required to excavate soils and grade the Project site, and by diesel trucks and
construction equipment. As discussed in Impact AQ-2, compliance with California ARB
regulations and SCAQMD rules would control fugitive dust and emissions from off-road
construction equipment and haul trucks to acceptable levels from the site.
The LST thresholds only apply to those emissions generated by onsite construction activities, such
as particulate matter released into the local area from onsite grading and excavation activities, and
do not apply to offsite mobile emissions (i.e., heavy-haul trucks). Total pollutant emissions were
estimated using CalEEMod for the key stages of construction, including demolition,
grading/excavation, paving, construction, and architectural coating. The maximum emissions
levels for each pollutant on a daily basis were also estimated using CalEEMod for each year of the
construction phase from 2019 through 2020. The LSTs for sensitive receptors within 25–30 meters
(or 82–98 feet) of the Project site were used to represent the distance to the closest receptors and
are the most conservative LSTs. Although in some instances, park visitors would be located closer
than 25 meters from construction activities, they would experience less exposure overall than the
residential sensitive receptors, as they would only encounter construction emissions for the
relatively short duration of their visit. Further, there would be occasions when construction
activities would not overlap with park hours, such as in the evening. Construction occurring on the
eastern side of the site would have the greatest likelihood to adversely affect residential sensitive
receptors given closer proximity. With construction that occurs within the center and western
portions of the Project site, the distance between emissions sources and the residences would be
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Final EIR – January 2018
3.1 AIR QUALITY
substantially increased and the pollutant emissions that reach the adjacent residences would be
substantially less. LSTs and estimates of onsite construction-related project emissions for the
Project are shown in Table 3.1-5. Construction-related emissions during implementation of the
Project would be below all LSTs; therefore, impacts would be less than significant.
Table 3.1-5. Maximum Estimated Daily Construction Emissions for the Project compared
to Localized Significance Thresholds (pounds/day)
Air Pollutant LST Thresholds Onsite Construction Emissions Exceeds Threshold? 2018 2019
CO 1,531 74.33 17.97 No
NOx 221 63.84 11.35 No
PM10 13 11.46 0.78 No
PM2.5 6 4.21 0.66 No
Notes: Refer to Appendix C for CalEEMod output sheets.
In addition, the potential for TACs to have an effect on sensitive receptors would occur if a project
is located near an existing significant source of TACs or if it would generate TACs in quantities
that may have an adverse effect on sensitive receptors. California ARB identifies high-volume
freeways and roads, dry cleaners, and large gas stations as potential sources of TACs. Additionally,
as discussed under SCAQMD Rule 1401, if TAC risks exist for a proposed use, TACs would need
to be limited through the use of pollution controls to meet OEHHA Guidelines for MICR, cancer
burden, and non-cancer acute and chronic HI from uses that emit TACs, such as freeways, gas
stations, and auto body shops. In habitable structures, these pollution controls typically include
design features to reduce interior concentrations of TACs, such as non-openable windows and
specially designed filtration/HVAC systems. In a park and open space setting, these types of
measures are infeasible. However, no new or additional pollution controls would be required where
either the cancer risk was well below the Rule 1401 risk, or there were no major TACs associated
with the proposed use(s). The Project would expand Airport Park with an additional 12 acres of
open space and recreational amenities, which are all considered to be uses that would not generate
substantial amounts of TACs and would not pose a risk to sensitive receptors in the Project vicinity.
Accordingly, TAC pollution controls would not be required for the Project.
Additionally, according to the 2005 California ARB’s Air Quality and Land Use Handbook, it is
recommended to maintain 500 feet of separation between sensitive land uses (including parks) and
dry cleaners using perchloro-ethylene, 500 feet between sensitive uses and a major freeway, and
more than 50 feet from a typical gas station. The Project site is not located within the designated
buffer for these identified uses. The I-10 (Santa Monica Freeway) is located approximately
3,500 feet to the north, and a gas station is located at the intersection of South Bundy Drive and
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Final EIR – January 2018
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National Boulevard, approximately 525 feet to the northeast. As such, the Project is well outside
the recommended buffer zone of potential TAC emitters as defined by SCAQMD and California
ARB.
However, SMO and the airport runway are located approximately 300 feet north of the Project
site. Because of the horsepower required to produce enough thrust to achieve takeoff and maintain
safe flight, aircraft emissions are not as strictly regulated as other emissions sources, such as motor
vehicles. For example, as discussed above, the use of leaded gas is still permitted in aviation uses.
In 2015, the most recent year in which data is tabulated, SMO managed a total of 90,319 aircraft
operations. Of these operations, 78 percent were from propeller aircraft, 18 percent were from jet
aircraft, and 4 percent were from helicopter operations. The City will shorten the runway to
3,500 feet by December 7, 2017. With a shortened runway, jet aircraft operations would be
potentially reduced by approximately 44 percent, based on the current operational fleet mix
(Coffman Associates 2017).
Nonetheless, emissions from remaining aircraft operations would expose park visitors to identified
TACs until SMO ceases operation on December 31, 2028. Although park visits typically last only
a couple of hours, many of the visitors will be engaged in sporting events which greatly increase
the rate of respiration. Further, it is anticipated that the park would employ at least one full-time
employee at the Project site. Therefore, a health risk assessment (HRA) was prepared to determine
if operations at SMO would generate TACs in quantities that may have an adverse effect on
sensitive receptors (Appendix B). As concluded in the HRA, TAC emissions SMO from aircraft
are not expected to pose significant carcinogenic risk to future or recreators or visitors at the
expanded Airport Park. For acute non-carcinogenic risk, the highest predicted target organ-specific
acute Health Index (HI) was 0.05 for the eye at the PMI. The acute hazards predicted for the
residents and workers in the project are below the SCAQMD threshold. The highest target organ-
specific chronic HI was 0.005 for the respiratory system at the PMI. Acrolein contributed most
significantly at approximately 89 percent. The chronic hazards predicted for the residents and
workers in the project are below the SCAQMD threshold. The highest target organ-specific 8-hour
HI was 0.007 for the respiratory system at the PMI. Acrolein contributed most significantly at
approximately 82 percent. Therefore, the 8-hour hazards predicted for workers in the project are
below the SCAQMD threshold. Upon cessation of operations at SMO, the emission of aviation-
related TACs from SMO operations in the Project vicinity would cease.
Given that the Project’s estimated construction emissions would be below LSTs, the Project does
not include major TAC emitters, and the HRA concluded that visitors and employees at the park
would not be exposed to significant TACs from operation of aircraft at SMO, and that the exposure
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3.1 AIR QUALITY
of these TACs would be well below SCAQMD thresholds. Therefore, the Project’s potential
impacts to sensitive receptors would be less than significant.
AQ-5 Project-generated traffic, together with other cumulative traffic in the area,
would incrementally increase carbon monoxide (CO) levels in the vicinity of
local intersections. However, state and federal CO standards would not be
exceeded with implementation of the Project and this impact would be less
than significant.
Impact Description (AQ-5)
Areas with high vehicle density, such as congested intersections, have the potential to create high
concentrations of CO, known as CO hotspots. Carbon monoxide decreased dramatically in the
Basin with the introduction of the catalytic converter in 1975. No exceedances in CO have been
reported at monitoring stations on the Basin for some time, and Basin in currently designated as a
CO attainment area for both the NAAQS and CAAQS. Thus, it is not expected that CO levels at
Project-impacts intersections would rise to the level of an exceedance of these standards. The
SCAQMD conducted CO modeling for the four worst-case intersections in the Basin. The most
congested of these, and in Los Angeles County, as the intersection of Wilshire Boulevard and
Veteran Avenue, with an average daily traffic volume of about 100,000 vehicles per day. The
evidence provided in Table 4-10 of Appendix V of the 2003 AQMP shows that the peak modeled
CO concentrations due to vehicle emissions at this intersection was 4.6 ppm (1-hour average) and
3.2 ppm (8-hour average). When added to the existing background CO concentrations, the
screening values would be 7.6 ppm (1-hour average) and 5.6 ppm (8-hour average). Per SCAQMD
guidance, if a project causes the state 1-hour (20 ppm) or 8-hour (9 ppm) CO standards to be
exceeded, then a “CO hot spot” is created. However, since the Project’s 1-hour average (7.6 ppm)
and 8-hour average (5.6 ppm) both do not exceed the state CO standards, the Project would not
cause or contribute to a CO exceedance of a state air quality standard.
Based on the Project’s Transportation Impact Analysis, of the studied intersections that are
predicted to operate at a Level of Service (LOS) D, E, or F under Future (2025) With Project
cumulative conditions, no intersections would have peak traffic volumes even approaching
100,000 vehicles (Appendix F). As mentioned above, data from the San Francisco Bay Area
indicate that intersections with as little as 44,000 vehicles during the peak hour may also result in
CO hotspots. The intersection with the highest projected volume after implementation of the
Project is the intersection of Bundy Drive and Airport Avenue, with an estimated total 4,099
vehicles during the PM peak hour. Since none of the study area intersections analyzed in the
Transportation Impact Analysis prepared for the Project (see Appendix F) exceed 44,000 vehicles
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Final EIR – January 2018
3.1 AIR QUALITY
per hour, CO concentrations would be well below the 7.6 ppm screening value established by the
SCAQMD and CO hotspots would not occur at these intersections. Therefore, state and federal
CO standards would not be exceeded at these intersections with the implementation of the Project,
and impacts would be less than significant.
Would the project create objectionable odors affecting a substantial number of people?
AQ-6 None of the land uses included in the Project would result in objectionable
odors that would affect a substantial number of people. Therefore, this impact
would be less than significant.
Impact Description (AQ-6)
According to the SCAQMD CEQA Air Quality Handbook (Figure 5-5, Land Uses Associated with
Odor Complaints), objectionable odors are typically associated with industrial uses such as
agricultural facilities (e.g., farms and dairies), refineries, wastewater treatment facilities, and
landfills. The Project would expand the existing recreational park uses at Airport Park. Similar to
the existing Airport Park, this land use type would not generate objectionable odors that would
affect a substantial number of people. Odors that would be expected from the Project would be
associated with solid waste (refuse) storage typical of urban uses. In accordance with City
requirements, all refuse would be stored in covered containers and removed regularly. Therefore,
impacts associated with objectionable odors would be less than significant.
Cumulative Impacts
Would the project conflict with or obstruct implementation of the applicable air quality plan?
Would the project violate any air quality standard or contribute substantially to an existing or
projected air quality violation?
Would the project expose sensitive receptors to substantial pollutant concentrations?
Would the project result in a cumulatively considerable net increase of any criteria pollutant for
which the project region is nonattainment under an applicable federal or state ambient air quality
standard (including releasing emissions that exceed quantitative thresholds for ozone
precursors)?
Development of the Project in conjunction with future projects would potentially result in a
cumulative increase in construction-related and traffic-related air emissions, as well as onsite
stationary sources of air pollution in the City. Such development would generate emissions during
Airport Park Expansion Project 3.1-33
Final EIR – January 2018
3.1 AIR QUALITY
both the construction and operation phases that would result in cumulative impacts to local and
regional air quality.
With regard to cumulative effects related to operation of the Project, the Basin is a non-attainment
area for the state standards of ozone, PM10, and PM2.5. In addition, the Basin is in non-attainment
for the federal standards of ozone and PM2.5. Any growth within the City as well as the Los Angeles
metropolitan area would contribute to existing exceedances of ambient air quality standards when
taken as a whole with existing development. Cumulative impacts to air quality are evaluated under
two sets of thresholds for CEQA and SCAQMD.
According to CEQA Guidelines Sections 15064(h)(3):
A project’s incremental contribution to a cumulative effect is not cumulatively considerable
if the project will comply with the requirements in a previously approved plan or mitigation
program (including an air quality attainment or management plan) that provides specific
requirements that will avoid or substantially lessen the cumulative problem within the
geographic area in which the project is located.
As discussed in Impact AQ-1, the Project would not conflict with the 2016 AQMP; therefore, it
would not be cumulatively considerable under CEQA.
Construction of the Project would potentially overlap with other future projects in the immediate
vicinity, including the Airport Avenue Improvement Project. Construction-period emissions for
the Project and each future development project (that has not yet been approved or built) would be
localized. It should be noted that the City has limited control over the timing or sequencing of
many of the future development projects that may occur within the Project vicinity. However,
based on a review of Table 3.0-1 (Cumulative Projects List), the Airport Avenue Improvement
Project (Airport Avenue from Bundy Drive to 23rd Street) is immediately adjacent to the Project
site and would result in temporary cumulative increases in construction emission levels at the same
sensitive receptors as the Project, as its construction schedule is programmed to overlap with the
Project’s. Temporary construction emissions are discussed under Impacts AQ-2 and AQ-4. Since
the Project’s regional NOx emissions from construction are relatively close to the threshold, it is
possible that the construction of these two projects concurrently could constitute a significant
impact related to regional NOx emissions. However, regional emission thresholds are designed to
account for numerous construction projects occurring throughout the Basin, and the Project’s
construction emissions would not exceed SCAQMD maximum emissions thresholds or LSTs.
Further, like the Project, projects would be subject to SCAQMD’s standards, rules, and thresholds
3.1-34 Airport Park Expansion Project
Final EIR – January 2018
3.1 AIR QUALITY
to cumulatively control construction emissions. Therefore, the Project’s contribution to cumulative
construction emissions impacts would be less than significant.
SCAQMD has additional requirements for assessing cumulative impacts of a project on air quality.
SCAQMD’s approach is to first determine whether the proposed project would result in a
significant project-level impact to regional air quality based on SCAQMD significance thresholds.
If the project exceeds SCAQMD thresholds, then the lead agency needs to consider the additive
effects of cumulative projects only if a proposed project is part of an ongoing regulatory program
or is contemplated in a Program EIR, and the cumulative projects are located within approximately
one mile of the proposed project site. If there are cumulative projects within a one-mile radius of
the proposed project site that are part of an ongoing regulatory program or are contemplated in a
Program EIR, then additive effects of the cumulative projects should be considered.
As the Project is not part of an ongoing regulatory program, the SCAQMD recommends that
project-specific air quality impacts be used to determine the potential cumulative impacts to
regional air quality. As discussed under Impact AQ-3, long-term operational emissions included
in the proposed Project would not exceed SCAQMD significance thresholds and cumulative
impacts would be less than significant.
As discussed under Impact AQ-5, traffic generated by the Project would not create a CO “hotspot”
at congested intersections and impacts would be less than significant. Because the SCAQMD
thresholds would not be exceeded, the Project would not result in a cumulatively considerable
contribution with regard to criteria pollutants and cumulative impacts would be less than
significant.
Would the project create objectionable odors affecting a substantial number of people?
As discussed under Impact AQ-6, the Project would not create objectionable odors. The Project
would not contribute to a cumulatively considerable source of odor in the area and cumulative
impacts would be less than significant.
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3.1-36 Airport Park Expansion Project
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Airport Park Expansion Project 3.2-1
Final EIR – January 2018
3.2 CONSTRUCTION EFFECTS
This analysis evaluates construction effects of the Airport Park Expansion Project (Project) on the
sensitive uses in vicinity of the Project site. Although construction activities are temporary and
common in urban environments, nearby sensitive uses around a construction site may be adversely
affected by construction-related impacts associated with aesthetics and visual resources; air
quality; hazards and hazardous materials; noise; and transportation and traffic. While construction
effects associated with all of these issues are analyzed fully in the individual sections of this EIR
chapter, they are also summarized here for ease of understanding the full range of construction-
related impacts on sensitive uses.
3.2.1 Environmental Setting
The Project is located within the Santa Monica Municipal Airport (SMO) property, which has
experienced relatively little construction activity in recent years because the permitted land uses
at SMO are regulated and limited by a complex framework of federal, state and local laws and
regulations. These regulations generally restrict changes in land use that would result in
construction activity and the land uses currently in place at SMO have been established for
approximately three decades. The most recent construction activity in the Project vicinity was the
construction of the existing Airport Park in 2002. As such, the SMO property and areas
surrounding the Project site have experienced few developments in recent years.
Existing Land Uses
The Project site is situated on approximately 15.8 acres of SMO designated as “parkland and
residual land” by 1984 Settlement Agreement between the City of Santa Monica (City) and the
Federal Aviation Administration (FAA) (1984 Settlement Agreement), which released these lands
from exclusive aviation uses. The Project site encompasses a portion of the existing 8.3-acre
Airport Park, Donald Douglas Loop South, and two non-contiguous parcels on either side of the
existing Airport Park. The western parcel includes the aviation-related land uses of 3025 Airport
Avenue (i.e., small administration office buildings and airplane hangars, 48 aircraft tie-downs,
aircraft storage, and the Proteus Air Service flight school; and Donald Douglas Loop South. The
eastern parcel previously supported approximately 78 airplane tie-down spaces, which were
removed in June 2017. Currently, the east parcel remains as a vacant paved surface area, with
public access for unprogrammed recreational use, including roller-blading and bicycle training for
families.
3.2 CONSTRUCTION EFFECTS
3.2-2 Airport Park Expansion Project
Final EIR – January 2018
Land uses directly north of the Project site across Donald Douglas Loop South include the Airport
Administration Building, airplane hangars, taxiways, airplane tie-down areas, and Runway 3/21.
Directly west and south of the Project site are non-aviation uses on SMO property, and include the
existing Airport Park (which is part of the Project site), various commercial uses, such as the
Spitfire Grill, the Museum of Flying, Santa Monica Art Studios, the Barker Hangar, and several
parking lots. Further south of the non-aviation uses on SMO property and within the City of Los
Angeles, land uses include the Santa Monica College Bundy Campus and single-family residential
neighborhoods. Low-density housing including single-family homes are also located east of the
Project site across South Bundy Drive (Table 3.2-1).
Table 3.2-1. Development in the Immediate Project Vicinity
Surrounding Land Use and Development
North (across Donald Douglas Loop
South)
SMO Runway 3/21, General Aviation Facility Specialty Hangar (3100
Donald Douglas), SMO Administration Building (3147-3165 Donald
Douglas), SMO Parking Lot # 1 (3223 Donald Douglas), Typhoon
Restaurant (3221 Donald Douglas), hangars, and airport aprons.
South
Existing Airport Park. Across Airport Avenue, land uses include SMO
Parking Lot # 3 (3400 Airport), single- and two-story office buildings
(3200-3400 Airport), Spitfire Grill (3300 Airport), SMO Parking Lot # 4
(3200-3300 Airport), the Museum of Flying (3100 Airport), and the
Santa Monica College-Bundy Campus (3171 S. Bundy). Single-family
homes in the City of Los Angeles are located southwest of the Project
site.
East (across South Bundy Drive) One- and two-story office buildings (3010-3030 S. Bundy), and single-
family residential uses
West Barker Hanger (3021 Airport) and airport aprons
Sensitive Land Uses
Some land uses are considered more sensitive to construction effects, such as air pollution and
noise, than others due to the types of population groups or activities involved. Sensitive population
groups include children, the elderly, the acutely ill, and the chronically ill, particularly those with
cardio-respiratory diseases. Residential uses are also considered to be sensitive to construction
impacts because residents (including children and the elderly) tend to be at home for extended
periods of time, resulting in sustained exposure to any pollutants present. Commercial and light-
industrial uses, on the other hand, are considered to be much less sensitive to construction impacts
because employees tend to avoid the outdoors and do not typically reside for extended periods of
time (e.g., overnight), thereby reducing their exposure to harmful effects. Thus, the commercial
and cultural uses (i.e., office, retail, restaurant, and event venues) immediately adjacent to the
3.2 CONSTRUCTION EFFECTS
Airport Park Expansion Project 3.2-3
Final EIR – January 2018
Project site are not considered to be sensitive uses. The sensitive land uses nearest to the Project
site are listed below:
• Grand View Boulevard residential neighborhood, located east of the Project site across
South Bundy Drive — apartment buildings located at 3051 Grand View Boulevard and
single-family residences located along Grand View Avenue and side streets.
• Santa Monica College South Bundy Campus, 3171 South Bundy Drive, located southeast
of the Project site across Airport Avenue — a community college which provides
additional special classes for children and teens. The Santa Monica College South Bundy
Campus is located within the City of Los Angeles.
• Dewey Street residential neighborhood, located south of the Project site across Airport
Avenue — a residential street with single-family residences.
Existing Setting by Issue Area
This section provides a summary of the existing setting of each issue area as it pertains to
construction effects. For more in-depth descriptions of the existing setting, please see individual
impact sections: Section 3.1, Air Quality, Section 3.4, Hazards and Hazardous Materials, Section
3.6, Noise, and Section 3.7, Transportation and Traffic. For discussion of visual and aesthetic
impacts, see Section 4.0, Other CEQA Considerations.
Aesthetics
Except for a portion of the existing Airport Park, the Project site is presently improved with large
paved surface areas and functionally designed buildings in varying states of repair. The Project
site is generally void of vegetation. Adjacent land uses, particularly the commercial and cultural
uses adjacent to the south side of Airport Avenue are well maintained with attractive landscaping,
lawn areas, demonstration gardens, well-designed streetscaping, and aviation-themed art
installations. Where parking lots are present, landscaped planters and perimeter landscaping is
present. The exception to the visual character of the Project vicinity is the adjacent Barkar Hangar
and Santa Monica Arts Studio (located adjacent to the south side of Airport Avenue), which consist
of functionally designed buildings, surface parking lots that are void of landscaping, and poorly
developed streetscapes.
Air Quality
The City of Santa Monica is located in the western coastal portion of Los Angeles County, which
is within the South Coast Air Basin (Basin). The Basin is bounded by mountains to the north and
3.2 CONSTRUCTION EFFECTS
3.2-4 Airport Park Expansion Project
Final EIR – January 2018
east that trap air and its pollutants in the valleys below, making the Basin an area of high air
pollution potential. The entire Basin is designated as a federal- and/or state-level nonattainment
area for ozone (O3), fine particulate matter (PM2.5), and suspended or respirable particulate matter
(PM10). The Basin is in attainment of federal standards for carbon monoxide (CO), sulfur dioxide
(SO2), and nitrogen dioxide (NO2), a subcategory of nitrogen oxides (NOx). The Basin is in
attainment for the state ambient air quality standards for CO, NO2, and SO2, and the Los Angeles
County portion of the Basin is designated as attainment for lead (Pb) (South Coast Air Quality
Management District [SCAQMD] 2016).
Local measurements for air pollutants indicate that Santa Monica exceeds the state and federal
standards for many of the same pollutants. Since 2012, exceedances have occurred for the state
1-hour standards for ozone, the state and federal 8-hour ozone standard, the federal 24-hour
standard for PM10, and the federal 24-hour PM2.5 standard. The state standards for CO, PM10, NO2,
and SO2, and the federal standards for CO, NO2, and SO2 were not exceeded from 2012 through
2015. A summary of the local area air pollutant measurements and the related national and state
ambient air quality standards are summarized in Table 3.1-2 of Section 3.1, Air Quality.
Mobile sources, including motor vehicles, aircraft, trains, and construction equipment, account for
most of the air pollutant emissions within the Basin. In the immediate Project vicinity, motor
vehicles and aircraft are the primary source of criteria air pollutants. Commercial airports have the
potential for localized high levels of volatile organic compounds (VOCs), SO2, NOx, and PM.
Traffic-congested streets and intersections have the potential for localized high levels of CO.
Localized areas where ambient concentrations exceed national and/or state standards for CO are
termed CO “hotspots.” The SCAQMD considers CO as a localized problem that could adversely
affect sensitive receptors. Based on the Project’s Transportation Impact Analysis (Transportation
Study) prepared by Fehr & Peers in June 2017 (Appendix F), there are 5 intersections in the Project
area that experience congested conditions (i.e., LOS E or F): 23rd Street & Ocean Park Boulevard,
Walgrove Avenue & Rose Avenue, Centinela Avenue & Ocean Park Boulevard, Bundy Drive &
Ocean Park Boulevard, and Bundy Drive & National Boulevard. A CO hotspot analysis was
prepared for the Project, assessing peak traffic volumes at intersections studied in the
Transportation Impact Analysis and comparing to the SCAQMD standards for CO hotspot
analysis. Based on existing measured intersection volumes and the Project’s anticipated increase
in peak hour vehicle trips within the area, no intersections would have peak traffic volumes even
approaching the threshold of 100,000 vehicles and implementation of the Project would not
contribute towards localized high levels of CO; impacts are considered negligible (see also,
Section 3.1, Air Quality).
3.2 CONSTRUCTION EFFECTS
Airport Park Expansion Project 3.2-5
Final EIR – January 2018
Hazards and Hazardous Materials
Both a Phase I Environmental Site Assessment (ESA) (Appendix D.1) and Phase II ESA was
prepared to assess potential hazardous conditions at the Project site (Appendix D.2 and Appendix
D.3). The Phase I ESA identified conditions indicative of a previous release of hazardous materials
and recommendations for remediation of recognized environmental conditions (RECs) were
provided (Appendix D.1). The Phase II ESA found two isolated concentrations of arsenic above
accepted background levels in shallow soil within the east paved surface area, both in the
approximate location of the new east sports field (Appendix D.2). The Phase II ESA also found
two isolated occurrences of lead in the area of the former ramp (just north of the existing dog park)
(Appendix D.2). Based on these findings, the Phase II ESA recommended removal of the identified
Contaminants of Concern (COCs) and for a Human Health Risk Assessment (HHRA) to be
conducted for future recreational use of the Project site. The HHRA concluded that there is no
elevated health risk on site from lead and arsenic (Appendix D.6).
A review of federal and state databases determined that the Project site is not identified as a known
hazardous site, indicating there are no current or historical occurrences of hazardous chemical
generation, storage, or release on the site. A review of Federal and State contaminated site
inventories identified a total of 28 sites with hazardous releases or hazardous waste generators
within the Project vicinity (Table 3.4-3). Of these sites, only one active cleanup site is located at
an equal or greater elevation within 0.5 mile of the Project site; however, soil remediation is
currently being implemented to address potential soil or groundwater contamination at this site.
No other active cleanup sites are located within close proximity to the Project site, and as such,
the risk of soil and water contamination or migration is low (see Section 3.4, Hazards and
Hazardous Materials; Table 3.4-3). Therefore, it is unlikely that existing contaminants identified
in other nearby sites would have an impact on the Project site, due to the distance, hydraulic
gradient in relation to the Project, or due to past and ongoing cleanup efforts.
Noise
Land uses within the City include a range of residential, commercial, institutional, and recreational
open space areas. At the Project site, the primary source of noise is aircraft operations from SMO,
sporting events and users of Airport Park, and vehicular noise from the local road network. Noise
in the vicinity may also occur from various stationary sources, such as mechanical equipment
associated with buildings, loading/delivery/garbage truck operations, and the operation of various
types of businesses. The majority of the Project site is located within the 60 CNEL noise contour
of runway 3/21, and areas of the western portion of the Project site where vehicle parking areas
are proposed overlap the 65 CNEL noise contour.
3.2 CONSTRUCTION EFFECTS
3.2-6 Airport Park Expansion Project
Final EIR – January 2018
Measurements of ambient noise, taken 25 feet from roadway noise source, of the existing noise
environment indicate that average noise levels range from 60 dB – 68 dB (see also, Section 3.6,
Noise).
Transportation and Traffic
The Project site is bound by South Bundy Drive to the east, Airport Avenue to the south, and is
bisected from west to east by Donald Douglas Loop South. South Bundy Drive is a four-lane
primary north/south roadway that provides surface street access to the Project site from the east.
Bundy Drive intersects with I-10 less than one mile north of the Project site. Immediately south of
Airport Avenue, South Bundy Drive becomes Centinela Avenue. The intersection of Airport
Avenue and South Bundy Drive is signalized with left-turn pockets and pedestrian crosswalks. No
on-street parking is available along South Bundy Drive.
Airport Avenue is a minor east/west street running east from 23rd Street & Walgrove Avenue to
South Bundy Drive, and providing direct access to the southern parking lot for the existing Airport
Park. The narrow road provides one travel lane in each direction with no on-street parking and no
center-turn lane. Airport Avenue east of Donald Douglas Loop South is lined with landscaping,
including trees and large palms and supports public sidewalks on both sides. The portion of Airport
Avenue west of Donald Douglas Loop South—where the Project site’s west paved surface area
fronts Airport Avenue—is void of landscaping and does not provide a formal sidewalk, although
a wide area of pavement used for vehicle parking can accommodate pedestrian movement.
Donald Douglas Loop South is a two-lane access road that intersects with Airport Avenue and
provides vehicular access to the existing park’s northern 58-space parking lot, to the SMO
Administration Building, and to the airport itself. The road provides a sidewalk on the east side
and is landscaped with large palm trees and provides one lane of travel in each direction with no
on-street parking. Donald Douglas Loop South leads to the airfield and is gated just beyond the
existing Airport Park parking lot, restricting access to this area for official vehicles only. The
intersection of Airport Avenue and Donald Douglas Loop South is served by a four-way stop with
pedestrian crosswalks. No dedicated left-turn lanes on Airport Avenue at the intersection of
Donald Douglas Loop South.
3.2.2 Regulatory Framework
Applicable regulatory framework discussion is incorporated by reference from the individual and
associated environmental issue areas and is not repeated here. Please see the following sections
for specific regulations pertaining to the issue areas: Section 3.1, Air Quality, Section 3.4, Hazards
3.2 CONSTRUCTION EFFECTS
Airport Park Expansion Project 3.2-7
Final EIR – January 2018
and Hazardous Materials, Section 3.6, Noise, Section 3.7, Transportation and Traffic, and Section
4.0, Other CEQA Considerations.
3.2.3 Impact Assessment and Methodology
Thresholds for Determining Significance
Construction of the proposed project would result in significant impacts if
• The project would have considerable construction-period impacts due to the scope or
location of construction activities.
Methodology
The following impact analysis summarizes the potential construction effects of the Project. The
major impacts associated with construction analyzed in this section include aesthetics, air quality,
hazards and hazardous materials, noise, and transportation and traffic. Some of the analyses are
based on Project-specific modeling prepared for air quality and traffic (Appendix C and Appendix
F). Applicable federal, state, and local regulations were also considered. The construction-specific
methodologies and significance criteria for each of these specific environmental issues are
discussed in their respective sections in this EIR: Section 3.1, Air Quality, Section 3.4, Hazards
and Hazardous Materials, Section 3.6, Noise, and Section 3.7, Transportation and Traffic, and
Section 4.0, Other CEQA Considerations.
3.2.4 Project Impacts and Mitigation Measures
Would construction of the proposed project result in considerable construction-period impacts
due to the scope, or location of construction activities?
Impact Description (CE-1)
CE-1 Implementation of the Project would have considerable construction-period
impacts due to the scope, or location of construction activities. The
implementation of identified mitigation measures would reduce all
construction-related impacts to a less than significant level, with the exception
of short-term noise impacts, which would remain significant and unavoidable
when compared to City of Los Angeles thresholds. When compared to City of
Santa Monica thresholds for construction noise, these impacts would be less
than significant.
3.2 CONSTRUCTION EFFECTS
3.2-8 Airport Park Expansion Project
Final EIR – January 2018
Construction for the Project would occur over three phases; demolition, excavation, and building
construction. The building construction phase includes three sub phases; building construction,
paving, and architectural coating (i.e., painting). The precise construction timeline for the Project
depends on the timing of City approvals. For the purposes of studying the worst-case emissions
for this EIR, construction activity for the Project is assumed to begin in 2019, with occupancy and
operation commencing in 2020. The Project’s construction activities and estimated durations are
as follows:
• Demolition – 1 month
• Excavation/Grading – 1 month 1
• Building construction – 9.5 months
• Paving – 1 month
• Architectural coating – 0.5 month.
As described throughout this EIR, construction impacts related to air quality, noise, and
transportation and traffic have the potential to affect sensitive uses during construction; however,
with the exception of short-term noise impacts, with mitigation identified as applicable, these
impacts would be less than significant.
Aesthetics
Construction of the Project would require demolition of the existing on-site uses. After demolition
activities, grading and excavation of the site would occur followed by construction of the proposed
acoustical berm and recreational amenities. Visual effects associated with construction activities
would include construction fencing, staging areas for grading, and presence of construction
equipment. Such impacts would primarily affect the viewers adjacent to the Project site, which
include residences to the east and visitors of the SMO and Airport Park. However, this effect would
constitute a temporary visual distraction typically associated with construction activities and
equipment. In addition, with the application of standard City conditions related to construction
area barriers, this temporary visual effect associated with the Project’s construction phase would
be less than significant.
Air Quality
As discussed in Section 3.1 Air Quality, construction of the Project would not exceed SCAQMD
standards for construction activities. Project construction activities would include demolition,
1 As discussed in Section 2.0, Project Description, of this Draft EIR, Project excavation and grading could occur over a
period of 1-2 months. However, the evaluation of air quality impacts assumes that excavation and grading would be
completed within one month because it presents a conservative analysis (i.e., compressing equipment usage into one
month increases air emissions).
3.2 CONSTRUCTION EFFECTS
Airport Park Expansion Project 3.2-9
Final EIR – January 2018
grading and excavation, and construction. Construction emissions associated with the proposed
Project were estimated using CalEEMod emission model Version 2016.3.1, and results are
summarized in Table 3.1-2 and Table 3.1-3. Model results indicate that onsite construction activity
would generate air pollutant emissions, but emissions of CO, VOCs, NOx, SOx, PM10, and PM2.5
would all be below the SCAQMD regional thresholds for construction emissions and this impact
would be less than significant.
The Project site is located within 100 feet of uses that qualify as sensitive receptors (i.e., existing
Airport Park, residences east across South Bundy Drive). Construction of the Project would have
the potential to expose these sensitive receptors to substantial pollutant concentrations. For
example, fugitive dust (PM) would be generated due to the earthwork required to excavate soils
and grade the Project site, and by diesel trucks and construction equipment. As discussed in
Section 3.1, Air Quality, Project construction would occur in compliance with California Air
Resource Board (ARB) regulations and SCAQMD rules to control fugitive dust and emissions
from off-road construction equipment and haul trucks. Construction occurring on the eastern
portion of the site would have the greatest likelihood to adversely affect sensitive receptors given
closer proximity. With construction that occurs within the center and western portions of the
Project site, the distance between emissions sources and sensitive receptors would be substantially
increased and the pollutant emissions that reach the adjacent residences would be substantially
less. When the worst-case scenario was modeled for the nearest sensitive receptors, construction
emissions were found to be below Localized Significance Thresholds (LSTs) for CO, NOx, PM10,
and PM2.5, as described in Table 3.1-5, therefore, construction generated air quality impacts to
nearby sensitive receptors would be less than significant.
Construction of the Project would not create objectionable odors affecting a substantial number of
people. Standard construction requirements would be imposed to minimize odors from
construction. Any construction-related odor emissions would be temporary, short-term, and
intermittent in nature, and impacts associated with construction-generated odors are expected to
be less than significant.
Hazards and Hazardous Materials
As further discussed in Section 3.4, Hazards and Hazardous Materials, hazardous materials could
potentially be released from construction activity at the Project site. The Project would involve the
demolition of the existing onsite aviation-related structures, miscellaneous commercial buildings,
and paved surfaces. As such, the potential exists for workers or the public to be potentially exposed
to lead-based paint (LBP) and asbestos-containing materials (ACMs) during demolition of the
onsite building and hauling of debris materials. In addition, as identified in the Phase I and II ESAs
3.2 CONSTRUCTION EFFECTS
3.2-10 Airport Park Expansion Project
Final EIR – January 2018
prepared for the Project, the site contains several RECs and COCs that may be released or become
exposed to workers and equipment during construction of the Project. To address impacts
associated with release of known hazardous materials during construction of the Project, MM
HAZ-1 and MM HAZ-2 are required. These measures require a comprehensive survey for LBP
and ACMs prior to the start of demolition, and appropriate remediation of these materials if
discovered. The measures further the implementation of a Soils Management Plan to be
implemented during excavation and/or grading in areas of known soil contamination, which
includes the screening of materials to confirm any presence of soil contamination and outlines
procedures for the proper handling of contaminated materials if discovered. The Soils Management
Plan to be approved by the Los Angeles Regional Water Quality Control Board (LARWQCB),
California Department of Toxic Substances Control (DTSC), and the Santa Monica Fire
Department (SMFD). With the implementation of identified mitigation measures, impacts would
be reduced less than significant level.
Noise
As discussed in Section 3.6, Noise, all phases of construction would involve the use of heavy
equipment that would produce noise. Construction activities would also involve the use of smaller
power tools, generators, and other equipment that are sources of noise. Haul trucks using the local
streets would generate noise as they move along the street. Each stage of 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. During Project construction,
without the implementation of any mitigation measures, maximum noise levels could reach as high
as 98 dBA at the existing Airport Park and 93 dBA at the exterior of nearby residential uses during
the demolition and grading phases of the Project.
Although construction activities for the Project would generate noise levels that may exceed the
established exterior noise limit of 85 dBA for parks and open spaces, Section 4.12.110(d) of the
City’s Noise Ordinance states that construction noise levels can exceed those standards discussed
above so long as it occurs between the hours of 10:00 A.M. and 3:00 P.M. MM NOI-1 would require
that the noisiest activities be limited to between the hours of 10:00 A.M. and 3:00 P.M., consistent
with Section 4.12.110(d) of the City’s Noise Ordinance. Under mitigation measure MM NOI-1,
the implementation of noise attenuation measures may include the use of noise barriers (e.g., sound
walls) or noise blankets. In addition, mitigation measure MM NOI-1 would serve to further reduce
these impacts as it would ensure that haul trucks associated with construction activities are routed
away from residential streets. Therefore, when compared to City of Santa Monica thresholds,
short-term construction noise impacts would be less than significant.
3.2 CONSTRUCTION EFFECTS
Airport Park Expansion Project 3.2-11
Final EIR – January 2018
As a general rule, a sound wall is able to reduce noise by 5 dBA, which would reduce construction
noise levels to residences across South Cundy Drive (in the City of Los Angeles) to approximately
88 dBA. The City of Los Angeles considers any construction activity that would exceed existing
ambient noise levels by 5 dBA or more at a sensitive receptor to result in a significant noise impact.
Thus, even with the noise attenuation measures implemented under MM NOI-1, the residences
across South Bundy Drive could experience temporary construction-related noise levels of
88 dBA, which is greater than 5 dBA above ambient noise levels. The highest noise levels would
occur during construction along the Project site’s eastern boundary, primarily from construction
of the proposed noise berm/wall, which involves earthmoving equipment. Construction noise
levels would decrease rapidly as construction activities moves toward the center of the Project site.
Nonetheless, even with the implementation of identified mitigation measures, noise impacts to the
residences along South Bundy Drive are conservatively considered to be significant and
unavoidable when compared against City of Los Angeles thresholds.
Table 3.6-11, Estimated Peak Vibration Levels at Sensitive Receptors, identifies various vibration
velocity levels for the types of construction equipment that would operate at the Project site during
construction. As identified in Section 4.12.070 of the City’s Municipal Code, vibration associated
with construction is considered exempt from City regulation; however, vibration is regulated under
CEQA. Ground-borne vibration levels during construction would be temporary and would not
exceed the 0.1 in/s threshold as referenced by the 2013 Caltrans Transportation and Construction
Vibration Guidance Manual. Therefore, groundborne vibration and construction noise would be
less than significant.
Transportation and Traffic
Construction activities associated with development of the Project would result in additional
construction traffic in the Project vicinity. Increased construction traffic on streets, particularly
large haul trucks and other heavy equipment (e.g., cement trucks and cranes), may disrupt traffic
flows, reduce lane capacities, and generally slow traffic movement. In addition, such traffic could
interfere with or delay transit operations and disrupt pedestrian and bicycle circulation. Demolition
of Donald Douglas Loop South would occur in a manner to provide continued access to airport
uses north of Airport Park. The construction haul route would be determined in coordination with
City staff and residential streets would be avoided. Project construction may also require the
temporary or extended closure of adjacent traffic lanes and sidewalks on surrounding streets (i.e.,
Airport Avenue) to accommodate excavation for utility installation, operation of construction
equipment, installation of Project improvements, etc. Depending on final construction plan details,
such lane and sidewalk closures could extend from a single day to several weeks. Project
3.2 CONSTRUCTION EFFECTS
3.2-12 Airport Park Expansion Project
Final EIR – January 2018
construction activities (e.g., lane closures) could also cause delays or rerouting of existing transit
service.
However, implementation of Mitigation Measure MM T-1 would reduce this impact to a less than
significant level by requiring the preparation of a Construction Impact Mitigation Plan, which
would include provisional measures to address construction traffic routing and control, vehicular
and pedestrian safety, pedestrian/bicycle access and parking, street closures, and construction
parking. This Plan would be prepared to address traffic impacts that could occur during Project
construction. See Section 3.7, Transportation and Traffic.
Cumulative Impacts
Would construction of the proposed project result in cumulatively considerable construction-
period impacts due to the scope, or location of construction activities?
Table 3.0-1 in Section 3.0 provides a list of past, approved, and pending development projects
located throughout the City. Construction activities associated with development projects would
create temporary aesthetic (visual), air quality, noise, vibration, and traffic impacts generally
similar to those described for the proposed Project. Construction of the Project would potentially
overlap with other future projects in the immediate vicinity, including the Airport Avenue
Improvement Project.
With regard to aesthetics, construction of the Airport Avenue Improvement Project would also
constitute a temporary visual distraction typically associated with construction activities and
equipment. As with construction of the Project, with the application of standard City conditions
related to construction area barriers, this temporary visual effect associated with the Project’s
construction phase would ensure that the Project does not result in a cumulatively considerable
short-term construction impact to aesthetics and cumulative impacts are less than significant.
With regard to air quality, construction-period emissions for the Project and each future
development project (that has not yet been approved or built) would be localized. It should be
noted that the City has limited control over the timing or sequencing of many of the future
development projects that may occur within the Project vicinity. However, the Airport Avenue
Improvement Project is immediately adjacent to the Project site and would result in temporary
cumulative increases in construction emission levels at the same sensitive receptors as the Project,
as its construction schedule is programmed to overlap with the Project’s. Temporary construction
emissions are discussed above and under Impacts AQ-2 and AQ-4 (see Section 3.1, Air Quality).
The Project’s NOx emissions from construction are close enough to the regional threshold
3.2 CONSTRUCTION EFFECTS
Airport Park Expansion Project 3.2-13
Final EIR – January 2018
(i.e., 63.84 pounds per day verses a regional threshold of 100 pounds per day) that it is possible
that the construction of these two projects concurrently could constitute a significant impact related
to regional NOx emissions. However, regional emission thresholds are designed to account for
numerous construction projects occurring throughout the Basin, and the Project’s construction
emissions would not exceed SCAQMD maximum emissions thresholds or LSTs. Therefore, the
Project’s contribution to cumulative construction emissions impacts would be less than significant.
With regard to hazards and hazardous materials, hazardous materials conditions are generally site-
specific and there are no sites with identified hazardous materials concerns that are also related
projects and in close enough proximity to the Project site to result in cumulatively considerable
impacts to hazard materials.
With regard to noise, it is expected that only the construction of the Airport Avenue Improvement
Project would overlap with Project construction. During this time, the Project vicinity would
experience increases in daytime noise levels. Like the Project, it is assumed that construction of
the Airport Avenue Improvement Project would be limited to daytime hours, consistent with the
restrictions of the Santa Monica Municipal Code. As noted above, with MM NOI-1, the Project’s
contribution to cumulative construction impacts are less than significant when compared to City
of Santa Monica thresholds and significant and unavoidable when compared to City of Los
Angeles thresholds. It is reasonable to assume that the simultaneous construction of these two
projects would generate noise levels that are higher than the noise levels generated by the
independent construction of each of the projects. Even so, because the City of Santa Monica allows
for construction noise to exceed ambient noise levels by 20 dBA from 10:00 A.M. to 3:00 P.M.,
impacts are expected to remain less than significant when compared to City of Santa Monica
thresholds. However, as construction of the Project alone would exceed ambient noise levels by
more than 5 dBA at the residences across South Bundy Drive, impacts would continue to be
significant and unavoidable when compared to City of Los Angeles thresholds. Because the
Airport Avenue Improvement Project extends from South Bundy Drive east to 23rd Street, the
City has options to further reduce cumulative noise impacts on sensitive receptors, such as phasing
construction of the two projects so that construction activities do not occur in the same area
simultaneously.
With regard to traffic, construction workers are anticipated to arrive and depart the individual
construction sites during off-peak hours (i.e., arrive prior to 7:00 A.M. and depart between 3:00 to
4:00 P.M.), thereby avoiding construction related trips during the A.M. and P.M. peak traffic periods.
In addition, the haul truck routes for the related Projects would be approved by the City’s
Transportation Management Division. The City’s established process would take into
3.2 CONSTRUCTION EFFECTS
3.2-14 Airport Park Expansion Project
Final EIR – January 2018
consideration overlapping construction Projects and would balance haul routes to minimize the
impacts of cumulative hauling on any particular roadway. Specifically, construction of the Airport
Avenue Improvement Project would occur in accordance with a standard City Temporary Traffic
Control Plan, which prepared based on the most recent edition of the California Manual on
Uniform Traffic Control Devices and accommodate applicable modes of transportation including
pedestrians, bicycles, motor vehicles and public transportation. The Temporary Traffic Control
Plan would maintain two lanes of travel and access to all businesses during construction of the
related project through the use of flagmen and appropriate signage. Therefore, cumulative
construction impacts would be less than significant.
3.3 GREENHOUSE GAS EMISSIONS
This section analyzes the potential impacts of the proposed Airport Park Expansion Project
(Project) related to greenhouse gas (GHG) emissions. The section estimates the GHG emissions
that would result from construction and operation of the Project, including generation of vehicle
trips; energy demands for building heating, cooling, and power; and construction of new buildings
and infrastructure. Project-related GHG emissions are estimated using the California Emission
Estimator Model (CalEEMod) Version 2016.3.1 to assess conformance with defined thresholds
(Appendix C). The analysis focuses on the major GHGs generated by human activities, including
carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and chlorofluorocarbons (CFCs).
There are several unique challenges to analyzing GHG emissions and climate change, largely
because of climate change’s “global” nature. Most environmental analyses examine the “project-
specific” impacts that a particular project is likely to generate. Typical CEQA analyses address
local actions that have local – or, at most, regional – impacts, whereas climate change presents the
considerable challenge of analyzing the relationship between local activities and the resulting
potential, if any, for global environmental impacts. With regard to global warming, it is generally
accepted that while the magnitude of global warming effects is substantial, the contribution of an
individual general development project is so small that direct project-specific significant impacts
(albeit not cumulative significant impacts) are highly unlikely.
Global climate change is also fundamentally different from other types of air quality impact
analyses under CEQA in which the impacts are all measured within, and are linked to, a discrete
region or area. Instead, a climate change analysis must be considered on a global level, rather than
the local or regional setting, and requires consideration of not only emissions from the project
under consideration, but also the extent of the displacement, translocation, and redistribution of
emissions. As air quality impacts are linked to a particular location or area, it is appropriate to
consider the creation of new emissions in that specific area to be an environmental impact whether
or not the emissions are truly “new” emissions to the overall globe. When the impact is a global
one, however, it makes more sense to consider whether the emissions are new emissions, or are
actually being moved from one place to another. For example, the approval of a new
developmental plan or project does not necessarily create new automobile drivers - the primary
source of a land use project’s emissions. Rather, due to the “relocation” factor, new land use
projects sometimes merely redistribute existing mobile emissions; accordingly, the use of models
that measure overall emissions increases without accounting for existing emissions will
substantially overstate the impact of the development project on global warming. This makes an
accurate analysis of GHG emissions substantially different from other air quality impacts, where
Airport Park Expansion Project 3.3-1
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
the “addition” of redistributed emissions to a new locale can make a substantial difference to
overall air quality.
3.3.1 Environmental Setting
Overview of Global Climate Change
The United States Environmental Protection Agency (U.S. EPA) defines climate change as any
significant change in the measures of earth’s climate lasting for an extended period. In other words,
climate change includes major changes in temperature, precipitation, or wind patterns, among
other conditions, that occur over several decades or longer. These changes are caused by a number
of natural factors—oceanic processes, variations in solar radiation received by earth, plate
tectonics and volcanic eruptions—as well as human-induced alterations. The primary
anthropogenic driver of climate change is the release of GHGs into the atmosphere.
The earth’s natural warming process is known as the “greenhouse effect”. The earth’s atmosphere
consists of a variety of gases that regulate the earth’s temperature by trapping solar energy; these
gases are cumulatively referred to as GHGs because they trap heat like glass of a greenhouse.
Relying on decades of research, the overwhelming majority of the scientific community agrees
that human activities, which include the burning of fossil fuels to produce energy and
deforestation, have contributed to elevated concentration of GHGs in the atmosphere beginning
with the Industrial Revolution and continuing today. The human production and release of GHGs
to the atmosphere is causing an increase in the average global temperature. While the increase in
global temperature is known as “global warming,” the resulting change in weather patterns is
known as “global climate change.”
Potential Effects of Global Climate Change
Global climate change could result in several potential adverse physical and environmental effects,
including sea level rise due to the melting of polar ice caps, flooding with increased weather
variability and intensified storm events, reduced reliability of water supplies, reduced quality of
water supplies, and increased stress on ecosystems that would reduce biodiversity. Additionally,
climate change may have impacts to human health due to heat waves and extreme weather events,
reduced air quality, and increased climate-sensitive diseases, including food-borne, water-borne,
and animal-borne diseases.
Adverse effects from climate change are distributed all across the globe. Sensitive communities,
such as low-lying and coastal areas that are more susceptible to impacts from flooding and sea
level rise, may be more heavily impacted than communities in other regions; however, climate
3.3-2 Airport Park Expansion Project
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
change would not have clearly definable impacts to a specific region or community. In other words,
the effects of climate change would have global consequences.
Greenhouse Gases
GHGs consist of a variety of gases that have the potential to trap heat, mainly water vapor, CO2,
CH4, N2O, ozone (O3), sulfur hexafluoride (SF6), other types of perfluorocarbons (PFCs), and
hydrofluorocarbons (HFCs). Water vapor and ozone, and their relationship to climate change are
not clearly understood and defined, so these GHGs are not currently regulated. Therefore,
methodologies and regulations approved by the Intergovernmental Panel on Climate Change
(IPCC), U.S. EPA, and the California Air Resources Board (ARB) focus on CO2, CH4, N2O, SF6,
PFCs, and HFCs. The following provides a brief description of each of the relevant GHGs and
their sources:
CO2 The natural production and absorption of CO2 occurs through the burning of fossil fuels
(e.g., oil, natural gas, and coal), solid waste, trees and wood products, and as a result of
other chemical reactions, such as those required to manufacture cement. Globally, the
largest source of CO2 emissions is the combustion of fossil fuels such as coal, oil, and gas
in power plants, automobiles, and industrial facilities. Since the Industrial Revolution in
the 1700s, human activities have increased CO2 concentrations in the atmosphere by
31 percent as of 2013 (IPCC et al. 2013). CO2 is removed from the atmosphere (or
sequestered) when it is absorbed by plants as part of the biological carbon cycle. When in
balance, total CO2 emissions and removals from the entire carbon cycle are roughly equal.
CH4 Methane is emitted from a variety of both human-related (anthropogenic) and natural
sources. Anthropogenic sources include the production and transport of coal, natural gas,
and oil, livestock and other agricultural practices, and the decay of organic waste in
municipal solid waste landfills. It is estimated that 50 to 65 percent of global methane
emissions are related to human activities. Natural sources of methane include wetlands, gas
hydrates, permafrost, termites, oceans, freshwater bodies, non-wetland soils, and wildfires
(IPCC et al. 2013).
N2O Concentrations of nitrous oxide also began to rise at the beginning of the Industrial
Revolution, reaching 324.2 parts per billion (ppb) by 2011. Microbial processes in soil and
water, including those reactions that occur in fertilizer containing nitrogen, produce nitrous
oxide. In addition to agricultural sources, some industrial processes (fossil fuel-fired power
plants, nylon production, nitric acid production, and vehicle emissions) also contribute to
the atmospheric load of N2O (IPCC et al. 2013).
Airport Park Expansion Project 3.3-3
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
SF6 SF6 is a fluorinated compound consisting of sulfur and fluoride. It is a colorless, odorless,
nontoxic, nonflammable gas. It is most commonly used as an electrical insulator in high
voltage equipment that transmits and distributes electricity. SF6 has a GWP of 23,900 in
the IPCC SAR and 22,800 in the IPCC AR4.
HFCs HFCs are fluorinated compounds consisting of hydrogen, carbon, and fluorine. They are
typically used as refrigerants in both stationary refrigeration and mobile air conditioning
systems. The GWPs of HFCs ranges from 140 for HFC-152a to 11,700 for HFC-23 in the
IPCC SAR and 124 for HFC-152a to 14,800 for HFC-23 in the IPCC AR4.
PFCs PFCs are fluorinated compounds consisting of carbon and fluorine. They are primarily
created as a byproduct of aluminum production and semiconductor manufacturing. The
GWPs of PFCs range from 6,500 to 9,200 in the IPCC SAR and 7,390 to 17,700 in the
IPCC AR4.
Global warming potentials are one type of simplified index based upon radiative properties that
can be used to estimate the potential future impacts of emissions of different gases upon the climate
system in a relative sense. Because the impact each GHG has on climate change varies, the
common metric of Carbon Dioxide Equivalents (CO2e) is used to report a combined impact from
all of the GHGs. This metric scales the global warming potential of each GHG to that of CO2.
GHG emissions are typically expressed in metric tons (MT CO2e), millions of metric tons (Tg
CO2e), or billions of metric tons (Gt CO2e) (IPCC et al. 2014; U.S. EPA 2015).
Existing GHG Emissions from Human Activity
The burning of fossil fuels, such as coal and oil, especially for the generation of electricity and
powering of motor vehicles, has led to substantial increases in CO2 emissions (and thus substantial
increases in atmospheric concentrations). In 2011, the most recent year comprehensive data is
available, atmospheric CO2 concentrations were found to have increased by over 31 percent above
the pre-industrial concentrations that were present prior to 1750 (IPCC et al. 2013).
Global GHG Emissions
As of 2014, global GHG emissions were estimated at 49 Gt CO2e per year, with CO2 making up
76 percent of the total anthropogenic GHG emissions. This is an overall increase in GHG emissions
of 71 percent from the 28.7 Gt CO2e of emissions in 1970 (IPCC et al. 2014). Annual
anthropogenic GHG emissions have increased by 10 Gt CO2e between 2000 and 2010, the most
recent years for which comprehensive data is available, with this increase coming directly from
energy supply (47 percent), industry (30 percent), transportation (11 percent), and buildings (3
3.3-4 Airport Park Expansion Project
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
percent) sectors. About half of cumulative anthropogenic CO2 emissions between 1750 and 2010
have occurred in the last 40 years. In 1970, cumulative CO2 emissions from fossil fuel combustion,
cement production, and flaring since 1750 were 420 Gt CO2e, since 1970 to 2010, that cumulative
total tripled to 1,300 Gt CO2e (IPCC et al. 2014).
U.S. GHG Emissions
Based on U.S. EPA data published in 2016, the U.S. emitted 6,870.5 MMT CO2e. Total U.S.
emissions have increased by 7.4 percent from 1990 to 2014, and emissions increased from 2013
to 2014 by 1.0 percent (70.5 MMT CO2e). The increase from 2013 to 2014 was due to relatively
cool winter conditions, which led to an increase in fuels for the residential and commercial sectors
for heating. Additionally, transportation emissions increased as a result of a small increase in
vehicle miles traveled (VMT) and fuel use across on-road transportation modes. Industrial sector
emissions also slightly increased due to an increase in industrial production across multiple sectors.
Since 1990, U.S. GHG emissions have increased at an average annual rate of 0.3 percent. Overall,
net emissions in 2014 were 8.6 percent below 2005 levels.
Overall, from 1990 to 2014, total emissions of CO2 increased by 440.9 MMT CO2e (8.6 percent),
while total emissions of CH4 decreased by 43.0 MMT CO2e (5.6 percent), and N2O decreased by
2.7 MMT CO2e (0.7 percent). Fossil fuel combustion accounted for 93.7 percent of CO2 emissions
and 80.9 percent of total U.S. GHG emissions in 2014. CH4 emissions, which have decreased by
5.6 percent since 1990, resulted primarily from decomposition of wastes in landfills, enteric
fermentation associated with domestic livestock, and natural gas systems. Agricultural soil
management, manure management, mobile source fuel combustion and stationary fuel combustion
were the major sources of N2O emissions.
Since the Industrial Revolution (i.e., about 1750), global atmospheric concentrations of CO2 have
risen approximately 43 percent, principally due to the combustion of fossil fuels. Within the U.S.,
fossil fuel combustion accounted for 93.7 percent of CO2 emissions in 2014. Globally,
approximately 32,190 MMT of CO2 were added to the atmosphere through the combustion of
fossil fuels in 2013, of which the U.S. accounted for approximately 16 percent. Of the five major
sectors generating emissions through direct fossil fuel combustion – electricity generation,
transportation, industrial, residential, and commercial – electricity generation accounts for
approximately 39 percent and transportation accounts for 33.4 percent of these emissions. In 2014,
approximately 82 percent of the energy consumed in the U.S. was produced through combustion
of fossil fuels, while the remaining 18 percent came from other energy sources such as
hydropower, biomass, nuclear, wind, and solar energy. Overall, total U.S. GHG emissions by
sector were 83.6 percent for the energy sector, including fossil fuel and transportation combustion,
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5.5 percent for industrial processes, 8.3 percent for agriculture, 0.4 percent for land use and
forestry, and 2.5 percent for waste, including landfills and wastewater treatment (USEPA 2016).
State of California GHG Emissions
In 2015, California generated approximately 440.5 MMT CO2e. California’s GHG emissions have
followed a declining trend since 2007. During the 2000 to 2015 period, per capita GHG emissions
in California have continued to drop from a peak in 2001 of 14.0 tonnes per person to 11.3 tonnes
per person in 2015, a 19 percent decrease.
Transportation is the source of approximately 37 percent of the state’s GHG emissions, followed
by electricity generation (both in-state and out-of-state) at 19 percent, and industrial sources at 21
percent. Residential and commercial sources account for 9 percent, agriculture accounts for 8
percent, High Global Warming Potential Gases (high-GWP) comprise 4 percent, and recycling
and waste accounts for 2 percent (CARB 2016).
City of Santa Monica Emissions
The GHG emissions inventory for the City accounts for transportation, electricity, natural gas,
gasoline, and diesel consumption, as well as solid waste generation within the City. Total
emissions in 2015 were estimated at approximately 1,110,315 metric tons CO2e, approximately
19.9 percent below the City’s 1990 emission total of 1,386,640 MT CO2e.1 Transportation
emissions were 64 percent of total GHG emissions while commercial, residential, industrial, and
solid waste, and aviation represented 14 percent, 12 percent, 5 percent, 3 percent, and 2 percent,
respectively. Total per capita GHG emissions from the City in 2015 were 11.9 MT CO2e per person
(City of Santa Monica 2016).
Project Site Emissions
The Project site is located within the southeast corner of the Santa Monica Municipal Airport
(SMO) property, at the southeastern limits of the City. The City is located in west Los Angeles
County, and is bounded by the City of Los Angeles to the north, south, and east, and the Pacific
Ocean to the west. The City is located within the South Coast Air Basin (Basin), with GHGs
generated by a wide range of emission sources, including utilities, vehicular traffic, and industry.
The Basin is an area of high air pollution potential as it is bounded by the Pacific Ocean to the
1 The City is working on the Climate Action Plan update. As part of the effort and in order to establish a consistent
methodology for quantifying GHG emissions from the transportation sector, a re-inventory of 1990 and 2011
transportation emissions was conducted using California Air Resources Board EMFAC2011 and EMFAC2014 Web
Databases. The difference in the originally reported GHG emissions inventory for prior years was due to differences in
models used and methodology.
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west and the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east. This
topography traps the air and its pollutants in the valleys or basins below. The regional climate
within the Basin is considered semi-arid and is characterized by warm summers, mild winters,
infrequent seasonal rainfall, moderate daytime onshore breezes, and moderate humidity.
In the Project vicinity, sources of GHG emissions include exhaust emissions from motor vehicles
and both private and commercial aircraft. Automobiles, motorcycles, trucks, and aircraft are the
primary source of GHG emissions. Other sources of GHG emissions include building energy
needs, as well as the construction and maintenance of buildings, and typical airport operations.
GHG emissions in the Project area also occur from various stationary sources, such as mechanical
equipment (e.g., HVAC systems) associated with buildings, the operation of various types of
businesses, and sources at residential locations.
The Project site is currently developed with
portions of the existing Airport Park and
paved surfaces for vehicle parking and aircraft
tie-down areas, as well as with aviation-
related, single-story structures and airplane
hangars on the west paved surface area. These
uses generate operational GHG emissions
associated with the operation of aircraft,
building energy needs, park lighting, and
vehicle trips generated by employees, visitors,
and pilots to the Project site. As described in
Section 3.1, Air Quality, the west paved
surface area is currently occupied by aviation-related businesses (e.g., Proteus Air) that generate
emissions of GHGs. While these businesses would be removed from the Project site to
accommodate the Project, both the City and businesses have expressed a desire to continue their
operation at another location at SMO. Therefore, the CalEEMod estimates conservatively do not
take credit for any reduction in emissions that would occur if these businesses were to cease
operation as a result of the Project.
3.3.2 Regulatory Framework
Global climate change is addressed through the efforts of various federal, state, regional, and local
government agencies, as well as national and international scientific and governmental conventions
and programs. These agencies work jointly and individually to understand and regulate the effects
of GHG emissions and resulting climate change through legislation, regulations, planning,
Greenhouse gas emissions generated in the project
vicinity are associated with the operation of private and
commercial aircraft, including exhaust emissions.
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policymaking, education, and a variety of additional programs. The significant agencies,
conventions, and programs focused on global climate change are discussed below.
International/Federal Regulations
International Protocols
In 1988, the United Nations established the IPCC to evaluate the impacts of global warming and to
develop strategies that nations could implement to curtail global climate change. In June 1992, the
U.S. joined other countries in the United Nations Framework Convention on Climate Change
(UNFCCC) agreement with the goal of stabilizing GHG emissions. The treaty itself set no binding
limits on GHG emissions for individual countries and contains no enforcement mechanisms. In that
sense, the treaty is considered legally non-binding. Instead, the treaty provides a framework for
negotiating specific international treaties (called "protocols") that may set binding limits on GHGs.
The Kyoto Protocol was the first treaty made under the UNFCCC on December 1, 1997 and was the
first international agreement that commits signatories to reduce GHG emissions. The Protocol sets
emissions targets for developed countries which are binding under international law. The Kyoto
Protocol has had two commitment periods, the first of which lasted from 2005-2012, and the second
2012-2020. The U.S. has not ratified the Kyoto Protocol. It has been estimated that if the
commitments outlined in the Kyoto Protocol were met, global GHG emissions could have been
reduced by an estimated 5 percent from 1990 levels during the first commitment period of 2008–
2012.
In December 2009, international leaders from 192 nations met in Copenhagen to address the future
of international climate change commitments post-Kyoto, but no binding agreements were
reached. Many of the industrialized countries that ratified the Kyoto Protocol have not and/or are
not expected to meet their targets. However, countries did ratify the Copenhagen Accord, a
nonbinding agreement. The Copenhagen Accord, a voluntary agreement between the U.S., China,
India, and Brazil, recognizes the need to keep global temperature rise to below 2°C and obligates
signatories to establish measures to reduce GHG emissions and to prepare to provide help to poorer
countries in adapting to climate change.
Representatives from 194 U.N. member states, including business leaders and nongovernment
organizations, met in Cancun, Mexico in December 2010 to participate in the United Nations
Climate Change Conference (COP-16). In all, approximately 12,000 participants met to work out
the language and reduction targets of a new agreement. The result was the Cancun Agreements, a
voluntary agreement similar to the Copenhagen Accord, but with broader U.N. member nation
support. Under the Cancun Agreements, countries agree to keep temperature rise below 2°C above
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pre-industrial levels and developed countries are urged to make more aggressive emission cut
pledges.
The UNFCCC met again in December 2011 in Durban, South Africa to continue deliberating on a
treaty to replace the Kyoto Protocol, which ended in 2012. The conference agreed to a legally
binding agreement comprising all countries, which will take effect in 2020. There was also
progress regarding the creation of a Green Climate Fund (GCF) for which a management
framework was adopted.
The UNFCCC Paris Agreement brings nations into a common cause to combat climate change and
adapt to its effects, with enhanced support to assist developing countries to do so. The Paris
Agreement’s central aim is to strengthen the global response to the threat of climate change by
keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial
levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius.
Additionally, the agreement aims to strengthen the ability of countries to deal with the impacts of
climate change (UNFCCC 2017). After joining the Paris Agreement in September 2016, the U.S.
left the Paris Agreement in June 2017.
U.S. Environmental Protection Agency (U.S. EPA)
The U.S. EPA is responsible for implementing federal policy to address global climate change.
The federal government administers a wide array of public-private partnerships to reduce U.S.
GHG emissions. These programs focus on energy efficiency, renewable energy, methane and other
non-CO2 gases, agricultural practices, and implementation of technologies to achieve GHG
reductions.
In Massachusetts v. Environmental Protection Agency et al. (2007) 549 U.S. 497, the U.S.
Supreme Court held that GHGs are pollutants under the Clean Air Act (CAA) and directed the
U.S. EPA to decide whether the gases endangered public health or welfare. On December 7, 2009,
the U.S. EPA issued an Endangerment Finding under Section 202(a) of the CAA, opening the door
to federal regulation of GHGs. The Endangerment Finding notes that GHGs threaten public health
and welfare and are subject to regulation under the CAA.
On May 13, 2010, the U.S. EPA issued a Final Rule that took effect on January 2, 2011, setting a
threshold of 75,000 MT CO2e per year for GHG emissions from major industrial facilities. The
U.S. EPA has not yet adopted thresholds for other GHG sources, although carbon pollution
standards have been proposed to cut carbon pollution from existing and new power plants, the
largest source of GHG emissions in the U.S.
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To date, Congress has not enacted any legislation requiring economy-wide mandatory reductions
in GHG emissions. Several different “cap-and-trade” proposals, which would require such
reductions, have been introduced in Congress, but none of them have been passed by either branch
of Congress, let alone become law. All such plans would place caps on the total amount of GHG
which can be emitted during future years, and allow emitters to buy and sell emission credits.
However, such plans vary widely on what caps they would place on emissions and how quickly
such caps would come into effect, as well as how their specific mechanisms would work.
State Policies and Regulations
California Air Resources Board
The California ARB, a part of the California Environmental Protection Agency (Cal EPA), is
responsible for the coordination and administration of both federal and state air pollution control
programs within California. In this capacity, ARB conducts research, sets state ambient air quality
standards (AAQS), compiles emission inventories, develops suggested control measures, and
provides oversight of local programs. ARB has primary responsibility for the development of
California’s State Implementation Plan (SIP), for which it works closely with the federal
government and the local air districts. ARB has also recently adopted a statewide GHG emissions
limit for 2020 (427 million metric tons of CO2e), an emissions inventory, and requirements to
measure, track, and report GHG emissions by major industries (OPR 2016).
Executive Order S-30-15
California Governor Brown announced on April 29, 2015 through Executive Order B-30-15 a new
statewide policy goal to reduce GHG emissions 40 percent below their 1990 levels by 2030. This
order acts as an intermediate goal to achieving 80 percent reductions by 2050 as outlined in
Executive Order S-3-05 below.
Executive Order S-3-05
California Governor Arnold Schwarzenegger announced on June 1, 2005, through Executive Order
S-3-05, the following GHG emission reduction targets:
• By 2010, California shall reduce GHG emissions to 2000 levels.
• By 2020, California shall reduce GHG emissions to 1990 levels.
• By 2050, California shall reduce GHG emissions to 80 percent below 1990 levels.
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Based on recent case law, the GHG reduction targets of Executive Order S-30-15 are not required
to be utilized as thresholds of significance for determining environmental impacts from a Project’s
GHG emissions (Cleveland National Forest Foundation v. San Diego Association of
Governments, July 13, 2017)
Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006
The California Global Warming Solutions Act of 2006 (AB 32) recognizes that California is a
major contributor to U.S. GHG emissions. AB 32 acknowledges that such emissions cause
significant adverse impacts to human health and the environment, and therefore must be identified
and mitigated where appropriate. AB 32 also establishes a state goal of reducing GHG emissions
to 1990 levels by 2020 – a reduction of approximately 30 percent from projected state emission
levels and 15 percent from current state levels, with even more substantial reductions required in
the future (OPR 2016).
California ARB has adopted the Climate Change Scoping Plan, which outlines the state’s strategy
to achieve the 2020 GHG limit set by AB 32. This Scoping Plan proposes a comprehensive set of
actions designed to reduce overall GHG emissions in California, improve the environment, reduce
dependence on oil, diversify energy sources, save energy, create new jobs, and enhance public
health.
Senate Bill (SB) 375
The passage of SB 375 (Steinberg, Chapter 728, Statutes of 2008) on September 30, 2008 created
a process whereby local governments and other stakeholders must work together within their
region to achieve the GHG reductions specified in AB 32 through integrated development patterns,
improved transportation planning, and other transportation measures and policies. Under SB 375,
the California ARB is required to set regional vehicular GHG reduction targets for 2020 and 2035.
On September 23, 2010, the California ARB adopted the vehicular GHG emissions reduction
targets that require a 7 to 8 percent reduction by 2020 and between 13 to 16 percent reduction by
2035 relative to emissions in 2005 for each metropolitan planning organization (MPO).
Additionally, SB 375 required that those targets be incorporated within a Sustainable Communities
Strategy (SCS), a newly required element within the MPO’s Regional Transportation Plan (RTP).
Southern California Association of Governments (SCAG) is the MPO for the southern California
region, which includes the City of Santa Monica. California ARB has determined SCAG’s
reduction target for per capital vehicular emissions to be 8 percent by 2020 and 13 percent by
2035. SCAG recently completed and adopted the 2016-2040 Regional Transportation
Plan/Sustainable Communities Strategy (RTP/SCS), which provides measures to achieve the GHG
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3.3 GREENHOUSE GAS EMISSIONS
reduction goals of AB 32. With the recently adopted RTP/SCS, SCAG’s per capita reduction target
is 8 percent by 2020, 18 percent by 2035, and 21 percent by 2040 and thus, would exceed ARB’s
GHG’s established targets.
Senate Bill 226
SB 226 was passed in 2012 for the purpose of streamlining the CEQA environmental review
process for eligible infill projects that promote a specific set of environmental policy objectives.
Stated broadly, SB 226 promotes infill development in two ways. First, it provides flexibility in
project design by basing eligibility on environmental performance rather than prescribing specific
project characteristics. Second, it allows infill projects to avoid repeating analysis of
environmental effects that have already been analyzed at a programmatic level. In addition to
establishing a streamlined process for infill projects, SB 226 directs the Office of Planning and
Research to develop performance standards for infill projects seeking to use the streamlined
process. Pursuant to SB 226, new Section 15183.3 of the CEQA Guidelines was adopted in June
2012, which established the guidance for streamlining of infill projects.
Senate Bill 97
SB 97, passed in 2007, amends CEQA to establish that GHG emissions and their effects are
appropriate subjects for CEQA analysis, and directs the OPR to develop draft CEQA Guidelines
for evaluating and mitigating GHG emissions and global climate change effects. In March 2010,
the California Office of Administrative Law codified into law CEQA amendments that provide
regulatory guidance with respect to the analysis and mitigation of the potential effects of GHG
emissions, as found in CEQA Guidelines Section 15183.5. The California Natural Resources
Agency adopted the Guidelines in January 2009 (OPR 2016).
However, neither a threshold of significance nor any specific mitigation measures are included or
provided in these CEQA Guidelines Amendments. The Guidelines require a lead agency to make
a good-faith effort based on the extent possible on scientific and factual data, to describe, calculate,
or estimate the amount of GHG emissions resulting from a project. The Guidelines give discretion
to the lead agency whether to: 1) use a model or methodology to quantify GHG emissions resulting
from a project, and which model or methodology to use; and/or 2) rely on a quantitative analysis
or performance-based standards. Further, the Guidelines identify three factors that should be
considered in the evaluation of the significance of GHG emissions:
1. The extent to which a project may increase or reduce GHG emissions as compared to the
existing environmental setting;
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3.3 GREENHOUSE GAS EMISSIONS
2. Whether the project emissions exceed a threshold of significance that the lead agency
determines applies to the project;
3. The extent to which the project complies with regulations or requirements adopted to
implement a statewide, regional, or local plan for the reduction or mitigation of GHG
emissions
Executive Order S-13-08
Executive Order S-13-08, the Climate Adaptation and Sea Level Rise Planning Directive, provides
clear direction for how the state should plan for future climate impacts. The first result is the 2009
California Adaptation Strategy (CAS) report which summarizes the best known science on climate
change impacts in the state to assess vulnerability and outlines possible solutions that can be
implemented within and across state agencies to promote resiliency.
California Code of Regulations (CCR) Title 24
Title 24 of the CCR is known as the California Building Standards Code. The 2016 California
Building Standards Code went into effect January 1, 2017 and includes the following:
CCR Title 24, Part 6 comprises the California Energy Code, which was first established in 1978
in response to a legislative mandate to reduce California’s energy consumption. The standards are
updated periodically to increase the baseline energy efficiency requirements. Although it was not
originally intended to reduce GHG emissions, electricity production by fossil fuels results in GHG
emissions and energy efficient buildings require less electricity. Therefore, increased energy
efficiency results in decreased GHG emissions.
CCR Title 24, Part 11 comprises the California’s Green Building Standards Code (CALGreen),
which establishes mandatory green building code requirements as well as voluntary measures (Tier
1 and Tier 2) for new buildings in California. The mandatory provisions in CALGreen will reduce
the use of VOC-emitting materials, strengthen water efficiency conservation, increase construction
waste recycling, and increase energy efficiency. Tier 1 and Tier 2 are intended to further encourage
building practices that minimize the building’s impact on the environment and promote a more
sustainable design.
SB 32 and AB 197
SB 32 and AB 197 were both approved by Governor Jerry Brown on September 8, 2016 and
became effective on January 1, 2017. SB 32 establishes a new target for GHG emissions reductions
at 40 percent of 1990 levels by 2030. AB 197 is paired with SB 32, and is a measure that increases
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legislative oversight over the California ARB, in order to ensure strategies to lower emissions
favor those most impacted by climate change.
Regional Policies and Regulations
South Coast Air Quality Management District
The South Coast Air Quality Management District (SCAQMD) is the agency principally
responsible for comprehensive air pollution control in the Basin, which includes all of Orange
County and the urban portions of Los Angeles, Riverside and San Bernardino counties. The
SCAQMD is directly responsible for reducing emissions from stationary (area and point), mobile,
and indirect sources to meet federal and state ambient air quality standards. In order to provide
GHG emissions guidance to local jurisdictions within the Basin, the SCAQMD organized a
Working Group to develop GHG emission analysis guidance and thresholds. On December 5,
2008, the SCAQMD Governing Board adopted the staff proposal for an interim GHG significance
threshold for stationary sources (i.e., industrial projects) where the SCAQMD is lead agency.
Presently, this 10,000 MT CO2e per year screening level threshold of significance for
stationary/source/industrial projects is the only GHG threshold adopted by the SCAQMD. In
October 2008, SCAQMD released a draft guidance document regarding interim CEQA GHG
significance thresholds. SCAQMD proposed a tiered approach, whereby the level of detail and
refinement needed to determine significance increases with a project’s total GHG emissions. The
tiered approach defines projects that are exempt under CEQA and projects that are within the
jurisdiction of, and subject to the policies of, a GHG Reduction Plan as less than significant. This
tiered approach is discussed in Section 3.3.3, Impact Assessment and Methodology.
Southern California Association of Governments (SCAG) Regional Transportation Plan/
Sustainable Communities Strategy (RTP/SCS)
As required by SB 375, SCAG has adopted the RTP/SCS, which is the culmination of a multi-year
effort involving stakeholders from across the SCAG region. The SCS is a required element of the
RTP that provides a plan for meeting GHG emissions reduction targets set forth by the California
ARB. SCAG’s 2016–2040 RTP/SCS provides growth forecasts that are used in the development
of air quality-related land use and transportation control strategies by the SCAQMD. The
RTP/SCS includes a strong commitment to reducing GHG emissions from transportation sources
and emphasizes the crucial linkages and interrelationships between the economy, the regional
transportation system, and land use. Strategies for achieving goals of available, safe, sustainable,
and affordable transportation include: 1) investing in bus, light rail, and heavy rail transit;
passenger and high-speed rail; pedestrian and bicycle transportation corridors; and infrastructure
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and transportation demand management (ex. carpooling to reduce demand for individual
transport); 2) encouraging public participation in the planning processes; and 3) educating the
public about available transportation methods available in the region. As discussed above, ARB
has determined SCAG’s reduction target for per capital vehicular GHG emissions to be 8 percent
by 2020 and 13 percent by 2035 relative to the 2005 baseline. In June 2016, ARB determined that
SCAG’s 2016–2040 RTP/SCS is consistent with their GHG reduction targets (ARB 2016b).
Specifically, SCAG’s plan is expected to help California meet and exceed its GHG reduction goals,
with estimated reductions in per capita transportation emissions of 8 percent by 2020, \ 18 percent
by 2035, and 21 percent by 2040.
Local Policies and Regulations
Sustainable City Plan (Updated 2014)
The Santa Monica Sustainable City Plan sets GHG emissions reduction targets for the City in order
to address climate change impacts; these targets, if achieved, would result in greater GHG
emissions reductions than those set by the state, at least in the short-term. The Sustainable City
Plan includes targets of reducing community GHG emissions by at least 20 percent below 1990
levels by 2020, and corporate GHG emissions by at least 30 percent below 1990 levels by 2020.
The Sustainable City Plan anticipated most reductions would come from increased energy
efficiency, increased renewable energy production, and reduced transportation-related emissions
through increased use of alternative transportation. The following City programs and policies
support or were developed to support the achievement of targeted reductions in GHG emissions
listed in the Sustainable City Plan.
• Resource Conservation Goal 1: Significantly decrease overall community consumption,
specifically the consumption of non-local, non-renewable, non-recyclable and non-
recycled materials, water, energy, and fuels.
• Transportation Goal 2: Facilitate a reduction in automobile dependency in favor of
affordable alternative, sustainable modes of travel.
• Open Space and Land Use Goal 2: Implement land use and transportation planning and
policies to create compact, mixed use projects, forming urban villages designed to
maximize affordable housing and encourage walking, bicycling, and the use of existing
and future public transit systems.
One of the key measures included in the Sustainable City Plan increases the percent of new and
substantially-rehabilitated housing that achieves Leadership in Energy and Environmental Design
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(LEED®) certification at LEED Silver or higher. The City also adopted a policy for new municipal
buildings to achieve at least a Gold rating by the U.S. Green Building Council’s LEED rating
system.
Green Building Ordinance
The City’s Green Building Ordinance (Santa Monica Municipal Code Chapters 8.106 and 8.108)
adopts by reference the 2016 California Green Building Standards Code with local amendments.
The local amendments address electric vehicle charging capacity for electrical services and
installation of dedicated multi-meter enclosures for electric vehicle charging in new multi-family
buildings. Additionally, Chapter 8.108 address construction and demolition (C&D) waste
recycling, with a required diversion rate for C&D waste of 70 percent.
City of Santa Monica Land Use and Circulation Element (LUCE)
The LUCE is intended to achieve a sustainable and integrated system of land use and transportation
in the City of Santa Monica within the larger context of the greater Los Angeles metropolitan area.
An important principle of the LUCE is to create a more sustainable Santa Monica by providing the
framework to achieve the GHG reduction goals of the Sustainable City Plan. The LUCE addresses
GHG emissions through its land use and transportation decisions such as focusing new land uses
near transit, creating complete neighborhoods, supporting infill mixed-use projects, and providing
affordable and diverse housing near jobs and transit. The LUCE includes a variety of strategies to
reduce GHG emissions, energy use, water use, and solid waste generation. The following are
selected LUCE sustainability policies that are applicable to the Project.
Goal LU4: Complete Sustainable Neighborhoods. Create complete neighborhoods that
exemplify sustainable living practices with open spaces, green connections, diverse
housing, local employment, and local-serving businesses that meet the daily needs of
residents and reduce vehicle trips and GHG emissions.
Policy LU4.6 Open Space. Provide open space and green connections near
residences that are part of an expanding and comprehensive system of passive and
active open space and complete street design emphasizing inter-connectivity,
recreation, and gathering spaces.
Goal S2: Reduce GHG emissions from land use and transportation decisions.
Policy S2.1 Implement the VMT (vehicle miles traveled) reducing policies of the
Land Use and Circulation Element of the General Plan including, but not limited
to: focusing new growth in higher density, mixed use, transit-oriented districts;
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focusing new growth along existing corridors and nodes; creating complete,
walkable neighborhoods with goods and services within walking distance of most
homes; and, implementing and supporting a wide range of pedestrian, bicycle and
transit improvements in the City.
Goal S3: Reduce overall energy use in the City.
Policy S3.1 Actively strive to implement the City’s “zero net” electricity
consumption goal by 2020 through a wide variety of programs and measures,
including the generation of renewable energy in the city and energy efficiency
measures.
Goal S5: Improve the environmental performance of buildings.
Policy S5.1 Continue to maintain a Building Code and prescriptive compliance
options that meet or exceed state requirements for energy, water and other
sustainability standards. Specifically, pursue California Energy Commission goals
to achieve net zero energy buildings by 2020 for low-rise residential buildings and
2030 for commercial buildings and achieve a LEED-equivalent local building code
by 2020.
Policy S5.8 Encourage installation of electrical outlets in loading zones and on the
exterior of new buildings to reduce emissions from gas-powered landscape
maintenance and operating refrigeration for delivery trucks.
Goal S6: Promote water conservation and increase the use of reclaimed and recycled
water.
Policy S6.3 Implement landscape water conservation requirements for new
construction projects.
City of Santa Monica 15x15 Climate Action Plan
In 2013, the City adopted the 15x15 Climate Action Plan to help the City meet its goal of reducing
community-wide GHG emissions to 15 percent below 1990 levels by 2015 and GHG emissions
from municipal operations to 30 percent below 1990 levels by 2015. The City made substantial
progress towards these goals through the Sustainable City Plan, the LUCE, and green building
requirements. The City is currently working on the update of the 15x15 Climate Action Plan with
the goal of achieving carbon neutrality. The 15 x 15 Climate Action Plan identifies 15 measures
that, if completed by the end of 2015, would achieve the City’s GHG emissions reduction goal.
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These measures are grouped in the following eight categories: Energy Use and Generation, Waste
Reduction and Recycling, Transportation and Mobility, Water Conservation and Efficiency, Open
Space and Land Use, Local Food and Agriculture, Municipal Operations, and Climate Mitigation
and Adaptation. Measures relevant to the Project include:
Measure 9: Expand the age, diversity, and number of trees in the urban forest.
Measure 10: Reduce water demand by 200,000 gallons per day.
3.3.3 Impact Assessment and Methodology
Thresholds of Significance
Due to its global effects, GHG analysis is typically based on the cumulative impact of emissions.
Appendix G of the 2017 CEQA Guidelines provides a set of screening questions that address
impacts with regard to GHG emissions. Specifically, the Guidelines state that a proposed project
may have a significant adverse impact related to GHG if the project would:
a) Generate GHG emissions, either directly or indirectly, that may have a significant impact
on the environment; and/or
b) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing
the emissions of GHGs.
Generally, the evaluation of an impact under CEQA requires comparing the project’s effects
against a threshold of significance. The CEQA Guidelines clarify that “when adopting thresholds
of significance, a lead agency may consider thresholds of significance previously adopted or
recommended by other public agencies or recommended by experts, provided the decision of the
lead agency to adopt such thresholds is supported by substantial evidence.” For GHG emissions
and global warming, there is not, at this time, one established, universally agreed-upon quantified
threshold of significance for GHG impacts. The 2017 CEQA Guidelines do not establish a
threshold of significance for GHG impacts. Instead, lead agencies have the discretion to establish
significance thresholds for their respective jurisdictions. A lead agency may look to thresholds
developed by other public agencies or other expert entities, so long as the threshold chosen is
supported by substantial evidence. SCAG, SCAQMD, and the City of Santa Monica have not
adopted a GHG significance threshold applicable to the development of this Project. Therefore,
related guidance documents and CEQA were evaluated for determining an appropriate significance
threshold.
3.3-18 Airport Park Expansion Project
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3.3 GREENHOUSE GAS EMISSIONS
The significance threshold used for this EIR is based on methodologies proposed by the SCAQMD
and methodologies adopted by other AQMDs. The SCAQMD has been evaluating GHG
significance thresholds since April 2008. In December 2008, the SCAQMD adopted an interim
10,000 MT CO2e per year screening level threshold for stationary source/industrial projects for
which the SCAQMD is the lead agency. The SCAQMD has continued to consider adoption of
significance thresholds for residential and general development projects. The most recent proposal
issued in September 2010 uses the following tiered approach to evaluate potential GHG impacts
from various uses:
• Tier 1 Determine if CEQA categorical exemptions are applicable. If not, move to Tier 2.
• Tier 2 Consider whether or not the proposed project is consistent with a locally adopted
GHG reduction plan that has gone through public hearings and CEQA review, that has an
approved inventory, includes monitoring, etc. If not, move to Tier 3.
• Tier 3 Consider whether the project generates GHG emissions in excess of screening
thresholds for individual land uses. The 10,000 MT CO2e/year screening threshold for
industrial uses would be recommended for use by all lead agencies. Under option 1,
separate screening thresholds are proposed for residential projects (3,500 MT CO2e/year),
commercial projects (1,400 MT CO2e/year), and mixed use projects
(3,000 MT CO2e/year). Under option 2, a single numerical screening threshold of
3,000 MT CO2e/year would be used for all non-industrial projects. If the project generates
emissions in excess of the applicable screening threshold, move to Tier 4.
• Tier 4 For residential, commercial, or mixed use projects with net new GHG emissions
that generate more than the Tier 3 screening threshold of 3,000 CO2e/year, consider
whether the project generates GHG emissions in excess of applicable performance
standards for the project service population (population plus employment). The efficiency
targets were established based on the goal of AB 32 to reduce statewide GHG emissions to
1990 levels by 2020. The 2020 efficiency targets are 4.8 MT CO2e/year per service
population for project level analyses and 6.6 MT CO2e/year per service population for plan
level analyses. If the project generates emissions in excess of the applicable efficiency
targets, move to Tier 5.
• Tier 5 Consider the implementation of CEQA mitigation (including the purchase of GHG
offsets) to reduce the project efficiency target to Tier 4 levels.
The thresholds identified above have not been adopted by the SCAQMD or distributed for
widespread public review and comment, and the working group tasked with developing the
Airport Park Expansion Project 3.3-19
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
thresholds has not met since September 2010. The future schedule and likelihood of threshold
adoption is uncertain. However, while not officially adopted by SCAQMD, the City has elected to
use the SCAQMD proposed tiered approach.
Additionally, with regard to the second criteria in the 2017 CEQA Guidelines that address GHG
emissions, the City analyzes whether a project would be consistent with local plans and regulations
that address GHG reduction. These plans and regulations include those set forth by the City’s
LUCE, Sustainable City Plan, and Climate Action Plan. As discussed above, based on recent case
law, the GHG reduction targets of Executive Order S-30-15 are not utilized as thresholds of
significance for determining environmental impacts from a Project’s GHG emissions.
The September 2010 SCAQMD proposal did not include screening thresholds for parks and open
space uses under its Tier 3 recommendations. For the purposes of this analysis, the Option 2 single
numerical screening threshold is applied to the Project. Therefore, the Project’s contribution to
cumulative impacts to global climate change would be significant if the Project would:
• Generate more than 3,000 MT CO2e/year, or
• Be inconsistent with any of the GHG reduction strategies set forth by the City’s LUCE and
Sustainable City Plan; AB32 and SB 375; and the State Attorney General, Office of
Planning and Research and Climate Action Team recommendations.
Methodology
GHG emissions associated with the construction and operation of the Project were estimated using
CalEEMod, and then compared to the SCAQMD thresholds of significance defined above.
CalEEMod is a statewide land use emissions computer model designed to provide a uniform
platform for government agencies, land use planners, and environmental professionals to quantify
potential criteria pollutant and GHG emissions associated with both construction and operations
from a variety of land use projects, including City parks. The model quantifies direct emissions
from construction and operations (including vehicle use), as well as indirect emissions, such as
GHG emissions from energy use, solid waste disposal, vegetation planting and/or removal, and
water use. The methodology and assumptions used in this analysis are detailed below for the
Project’s construction and operation activities. Refer to Appendix C for model output and detailed
calculations.
Construction GHG Emissions
Construction equipment generates GHGs such as CO2, CH4, and N2O through the combustion of
fossil fuels. CH4 may also be emitted during the fueling of heavy equipment. The raw materials
3.3-20 Airport Park Expansion Project
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
used to construct the new recreational amenities and the waste material from demolished buildings
can sequester and release carbon, respectively. However, since the exact nature of the origin or
make-up of the construction materials is unknown, only operation of construction vehicles and
equipment is considered in the analysis of construction GHG emissions.
The construction GHG analysis considers the Project’s anticipated construction schedule as well
as construction equipment mix. Construction-related GHG emissions are amortized over 30 years
per current SCAQMD methodology.
Operational GHG Emissions
The following activities are typically associated with the operation of park land uses that will
contribute to the generation of GHG emissions:
Vehicular trips. New vehicle trips generated by the Project would result in GHG emissions
through combustion of fossil fuels. GHG emissions were estimated using the total vehicle miles
traveled as determined by CalEEMod and U.S. EPA emissions factors for on-road vehicles.
Electricity use. Electricity is generated by a combination of methods, which include combustion
of fossil fuels. Use of electricity for operation of the Project would contribute to the indirect
emissions associated with electricity production. Estimated emissions from the consumption of
electricity are based on the net new acreage of the park and square footage of park structures, using
the standard electrical consumption rates from the CalEEMod software model.
Water use and Wastewater generation. The additional amount of water used and wastewater
generated by a Project has indirect GHG emissions as a result of the energy used to supply,
distribute, and treat water and wastewater. In addition to the indirect GHG emissions associated
with energy use, wastewater treatment can directly emit both CH4 and N2O depending on the
treatment method. Estimated emissions from the consumption of potable water and the generation
of wastewater is based on the acreage of the park and square footage of park structures and water
consumption rates as presented in the CalEEMod modeling output.
Solid waste. Emissions calculated for solid waste reflect the indirect GHG emissions associated
with waste that is disposed of at a landfill. Disposal rates from the California Department of
Resources Recycling and Recovery (CalRecycle) are used to estimate amount of disposal for
individual land uses. GHG emissions associated with the decomposition of waste are quantified
based on amount of degradable organic carbon generated by the acreage of the park and square
footage of park structures proposed by the Project. CO2 emissions are also quantified based on
associated methane, if applicable.
Airport Park Expansion Project 3.3-21
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
3.3.4 Project Impacts and Mitigation Measures
Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
GHG-1 The Project would generate GHG emissions from mobile and operational
sources, as well as short-term GHG emissions during construction, but
emissions would not exceed the 3,000 MT CO2e/year threshold. Therefore, this
impact would be less than significant.
Impact Description (GHG-1)
Total annual GHG emissions for construction and operational of all activities associated with the
Project were estimated using CalEEMod (Table 3.3-1 and Table 3.3-2; Appendix C).
Table 3.3-1. GHG Emissions from Construction of the Project
Construction Phase GHGs (MT CO2e)
Demolition 113
Grading 134
Building Construction 1,199
Paving 27
Architectural Coating 2
Total 1,475
Amortized over 30 years 49
Source: Annual Emissions Calculations in MT/Year for Proposed Project - CalEEMod – Appendix C.
Table 3.3-2. Combined Annual GHG Emissions for the Project
Annual Emissions by Category GHGs (MT CO2e)
Area 0
Energy 51
Mobile 664
Waste 0
Water 40
Construction (amortized) 49
Total 804
Source: Annual Emissions Calculations in MT/Year for Proposed Project - CalEEMod – Appendix C.
Construction activities for the Project would result in temporary generation of GHG emissions
totaling 1,475 MT CO2e. Construction-related GHG emissions were further divided into the main
3.3-22 Airport Park Expansion Project
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
phases of activity and amortized over an anticipated 30-year period to provide an average annual
estimate for a total of 49 MT CO2e annually.
Operational emissions for the Project would arise from motor vehicles, natural gas and electricity
consumption, as well as solid waste handling and electricity generation to provide water. Total
operational GHG emissions of 756 MT CO2e per year would be generated by the Project.
As discussed above, the SCAQMD has continued to consider adoption of significance thresholds
for residential and general development projects. The most recent proposal issued in September
2010 uses the tiered approach to evaluate potential GHG impacts from various uses. When the
Project’s amortized construction impacts are considered, the maximum annual GHG emissions for
the construction and operation of the Project are estimated to be 804 MT CO2e, which is well
below the SCAQMD Tier 3 screening threshold of 3,000 MT CO2e. Therefore, this is considered
a less than significant impact.
Would the project be inconsistent with any applicable plan, policy, or regulation of an agency that
has been adopted for the purpose of reducing GHG emissions?
GHG-2 The Project would not conflict with any applicable plan, policy, or regulation
of an agency that has been adopted for the purpose of reducing GHG
emissions. Therefore, this impact would be less than significant.
Impact Description (GHG-2)
The Project would support the City’s GHG reduction goals and policies established in the LUCE,
Sustainable City Plan, and Climate Action Plan (see Table 3.3-3). The Project includes several
characteristics and sustainable measures intended to reduce overall GHG impacts.
Transportation‐related GHG emissions are the largest sector of emissions from the Project. This is
recognized in regional plans, such as the SCAG RTP/SCS, which focuses on an integrated land
and transportation strategy to reduce GHG emissions. The purpose of the SCAG RTP/SCS is to
achieve the regional per capita GHG reduction targets for the passenger vehicle and light‐duty
truck sector established by CARB pursuant to SB 375. SCAG’s Program EIR for the RTP/SCS,
released in December 2015, states that “[e]ach [Metropolitan Planning Organization] is required
to prepare an SCS in conjunction to [sic] with the RTP in order to meet these GHG emissions
reduction targets by aligning transportation, land use, and housing strategies with respect to
[Senate Bill] 375.” SCAG’s RTP/SCS plans for regional population growth using smart land use
strategies. As part of the SCS/RTP, “transportation network improvements would be included, and
Airport Park Expansion Project 3.3-23
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
Table 3.3-3. LUCE, Sustainable City Plan, and Climate Action Plan Policy Consistency
Summary
Policy Relationship to Project
Policy LU4.6 Open Space. Provide open space and
green connections near residences that are part of an
expanding and comprehensive system of passive and
active open space and complete street design
emphasizing inter-connectivity, recreation, and
gathering spaces.
Consistent. The Project would expand Airport Park
with recreational amenities, including two new sports
fields, a large, natural turf multi-purpose area,
landscaped areas, and community garden plots that
would serve surrounding residential neighborhoods.
The Project would improve pedestrian connectivity by
providing two new pedestrian entranceways along
South Bundy Drive and a continuous loop network of
pedestrian pathways through the park.
Policy S2.1 Implement the VMT (vehicle miles
traveled) reducing policies of the Land Use and
Circulation Element of the General Plan including, but
not limited to: focusing new growth in higher density,
mixed use, transit-oriented districts; focusing new
growth along existing corridors and nodes; creating
complete, walkable neighborhoods with goods and
services within walking distance of most homes; and,
implementing and supporting a wide range of
pedestrian, bicycle and transit improvements in the City.
Consistent. The Project is an infill Project located
along established transportation routes (i.e., Bundy
Drive). The Project has been designed to engage
pedestrians and emphasize bicycle and pedestrian
access. The Project would include a continuous loop
network of pedestrian pathways around and
throughout the park to provide a variety of options for
traversing through the park. The Project would
provide high-quality recreational facilities within
walking distance to residences. In addition, regional
bus access would continue to be provided via Big
Blue Bus Routes 14 and 44, with Route 14
maintaining bus stops at the intersection of South
Bundy Drive and Airport Avenue. Bicycle racks to
accommodate approximately 45 bicycles would be
placed adjacent to the relocated Donald Douglas Loop
South, new restroom facilities and the main Bundy
Entry. The Breeze Bike Share station at the current
intersection of Airport Avenue and Donald Douglas
Loop South would be temporarily relocated during
Project construction, and placed at the new
intersection upon Project completion. The Project
would provide new pedestrian access points to the
Project site from South Bundy Drive.
Policy S3.1 Actively strive to implement the City’s
“zero net” electricity consumption goal by 2020 through
a wide variety of programs and measures, including the
generation of renewable energy in the city and energy
efficiency measures.
Consistent. See Policy S2.1 discussion above. In
addition, the Project would include energy efficiency
measures and would incorporate water saving features
in its landscaping by using drought-tolerant plants.
Policy S6.3 Implement landscape water conservation
requirements for new construction projects.
Consistent. Drought-tolerant species would be utilized
in less active areas of the park, and the Project would
use water-efficient equipment and plumbing
infrastructure.
3.3-24 Airport Park Expansion Project
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
Table 3.3-3. LUCE, Sustainable City Plan, and Climate Action Plan Policy Consistency
Summary (Continued)
Policy Relationship to Project
Sustainable City Plan
Resource Conservation Goal 1
Significantly decrease overall community consumption,
specifically the consumption of non-local, non-
renewable, non-recyclable and non-recycled materials,
water, energy, and fuels.
Consistent. The Project would include onsite
recycling containers to support the City’s recycling
goal. In addition, the Project would comply with
Section 8.108.010.c of the Santa Monica Municipal
Code, which requires that demolition and/or
construction projects over 1,000 sf divert at least
70 percent of construction and demolition material
from landfills.
Transportation Goal 2
Facilitate a reduction in automobile dependency in favor
of affordable alternative, sustainable modes of travel.
Consistent. The Project would provide bicycle racks
and new bicycle pathways. Big Blue Bus Routes 14
and 44 would provide regional bus access to the
Project site, with bus stops at the intersection of
Bundy Drive and Airport Avenue, and at the Museum
of Flying. Expansion of an existing Airport Park in an
urban location would promote more pedestrian trips
and biking trips rather than automobiles. A more
detailed discussion of trip generation, traffic and
circulation plans regarding the project can be found in
Section 3.7, Transportation and Traffic.
Open Space and Land Use Goal 2
Implement land use and transportation planning and
policies to create compact mixed use projects, forming
urban villages designed to maximize affordable housing
and encourage walking, bicycling, and the use of
existing and future public transit systems.
Consistent. The Project would include a continuous
multi-use pathway around the park allowing
pedestrians and bicyclists to traverse around the park.
In addition, the Project would provide bicycle racks to
promote bicycling. The Project would be accessible
by public transit and is walking distance from the
surrounding neighborhoods.
Climate Action Plan 15x15
Measure 9: Expand the age, diversity, and number of
trees in the urban forest.
Consistent. The majority of the Project site is
developed with paved surface areas that are void of
vegetation. The Project would include planting of
trees in naturally landscaped areas throughout the
park. The Project also includes streetscape
improvements along the relocated Donald Douglas
Loop South and Bundy Drive, which would include
landscaped slopes with new trees. When completed,
the Project would substantially increase the number of
trees on the Project site, thus contributing to the City’s
urban forest.
Measure 10: Reduce water demand by 200,000 gallons
per day.
Consistent. The Project would include drought-
tolerant plant species in less active areas of the park,
and water-efficient equipment and plumbing
infrastructure.
Airport Park Expansion Project 3.3-25
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
more compact, infill, walkable and mixed‐use development strategies to accommodate new
region’s growth would be encouraged to accommodate increases in population, households,
employment, and travel demand.”80 Moreover, the RTP/SCS states that while “[p]opulation and
job growth would induce land use change (development projects) and increase VMT, and would
result in direct and indirect GHG emissions,” the RTP/SCS “supports sustainable growth through
a more compact, infill, and walkable development pattern.”
Consistent with SCAG’s RTP/SCS alignment of transportation, land use, and housing strategies,
the Project Site is an infill location and would provide recreational/open space uses in walking
distance to existing residential and commercial uses, which would result in reduced VMT, as
compared to a project of similar size and land uses at a more suburban location.
The Project’s expansion of Airport Park would help fulfill LUCE Goal LU4, which calls for the
creation of complete sustainable neighborhoods that exemplify sustainable living practices to
reduce GHGs by providing uses such as open spaces and green connections that meet the daily
needs of residents and reduce vehicle trips and GHG emissions. The Project would provide
increased open space near residences and would contribute to inter-connectivity, recreation, and
gathering spaces, as emphasized in Policy LU4.6. This LUCE Goal also relates to the goals of the
SCAG RTP/SCS, which seeks improved “mobility and access by placing destinations closer
together and decreasing the time and cost of traveling between them.” The Project would be
consistent with this goal of the SCAG RTP/SCS as it has been designed to engage pedestrians and
emphasize bicycle and pedestrian access, decreasing reliance on individual mobile trips.
The Project is also designed to comply with green design requirements, which would help fulfill
LUCE Goal LU16, related to ensuring that buildings are sustainable and environmentally sound.
This would reduce the energy needs for operation of the Project, reducing annual GHG emissions.
Additional sustainability features of the Project include using synthetic turf on the sports fields
and drought-tolerant plan species in less active areas of the park, as well as water-efficient
equipment and plumbing infrastructure. An onsite stormwater treatment system and proposed
BMPs would pre-treat runoff and slow down stormwater flow rates. This LUCE goal also relates
to the SCAG RTP/SCS strategy to implement sustainability policies related to energy and water
conservation.
Based on all of the above, the Project would be consistent with applicable plans, policies, and
regulations and impacts would be less than significant.
3.3-26 Airport Park Expansion Project
Final EIR – January 2018
3.3 GREENHOUSE GAS EMISSIONS
Cumulative Impacts
Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
Would the project be inconsistent with any applicable plan, policy, or regulation of an agency that
has been adopted for the purpose of reducing GHG emissions?
Analysis of GHG emissions is cumulative in nature because impacts are caused by cumulative
global emissions. Additionally, climate change impacts related to GHG emissions do not
necessarily occur in the same area as the Project is located. Therefore, the preceding analysis is
related to cumulative impacts of GHG emissions, and in this analysis the Project was found to have
less than significant impacts.
Airport Park Expansion Project 3.3-27
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3.3-28 Airport Park Expansion Project
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Airport Park Expansion Project 3.4-1
Final EIR – January 2018
3.4 HAZARDS AND HAZARDOUS MATERIALS
This section of the EIR describes the existing conditions related to hazards and hazardous materials
and analyzes the potential for impacts to occur from Project implementation. The evaluation of
potential impacts is informed in part by the Los Angeles County Airport Land Use Plan (ALUP),
a Phase I Environmental Site Assessment (ESA) prepared by Parsons in February 2016, a Phase
II ESA prepared by ES Engineering Services, LLC in September 2016, a Supplemental Site
Assessment Report for the West Parcel, a Supplemental Site Assessment Report for the East Parcel
prepared by ES Engineering in July 2017, and a Screening Level Risk Assessment for the East
Parcel prepared by Parsons in August 2017 (all hazardous materials investigations are included as
Appendix D).
Although the Project site is located outside of the Santa Monica Municipal Airport (SMO) runway
approach paths, it does lie within the general operations area of the airport. As a result, existing
hazards may also include accidents and the release of hazardous materials associated with the
maintenance and operation of aircraft, or exposure to the historic and/or potential release of
hazardous materials into the surrounding environment.
Hazardous materials are defined
as substances with physical and
chemical properties of
flammability, corrosivity,
reactivity, or toxicity, which may
pose a threat to human health or
the environment. The term
“hazardous materials” is used in
this section to describe chemicals
such as petroleum products,
solvents, pesticides, herbicides,
paints, metals, asbestos, and other
regulated materials. Additionally, the term “release” as used in this section includes known
historical spills, leaks, illegal dumping, or other methods of release of hazardous materials to soil,
sediment, groundwater, or surface water. Areas where historical releases of hazardous materials
have occurred could pose a risk to public health and the environment. Potential future releases of
The Project site is within SMO’s general operations area, which
historically has been associated with handling, use, disposal, and
accidental release of hazardous materials. The Project also has potential
to introduce safety hazards to regulated air space.
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-2 Airport Park Expansion Project
Final EIR – January 2018
hazardous materials that could occur during construction or operation of the Project also are
included in the analysis.
A range of other types of hazards are addressed in other sections of this EIR. The potential for the
Project to result in hazardous air quality impacts are addressed in Section 3.1, Air Quality.
Temporary construction hazards, such as the ability of emergency response vehicles to access the
Project site, are addressed in Section 3.2, Construction Effects, and Section 3.7, Transportation
and Traffic. Noise hazards, such as the effects of airport are discussed in Section 3.6, Noise.
3.4.1 Environmental Setting
Region
The Project site is located along the
southeastern edge of the City of
Santa Monica (City) boundary with
the City of Los Angeles.
Surrounding land uses include
aviation-related uses on other
portions of the SMO property north
of the Project site (including
Runway 3/21) to the north; the
Museum of Flying, Santa Monica
College Bundy Campus, offices,
surface parking lots, restaurants,
and cultural land uses to the south;
the Mar Vista residential
neighborhood to the east; and the
Barker Hanger and commercial aircraft operations (Proteus Air Service) to the west (Figures 2-1
and 2-2).
The nearest schools to the Project site are the Bundy Campus for Santa Monica College,
(approximately 0.1 mile south), Mar Vista Elementary (approximately 0.6 mile southeast), and
Walgrove Avenue Elementary (approximately 0.6 mile southwest).
Surrounding land uses include airport-related commercial uses,
such as Proteus Air Services, which operates a flight school and
utilizes limited quantities of commercially available hazardous
materials.
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-3
Final EIR – January 2018
Project Site
The 15.8-acre Project site is located at the southeast corner of SMO property. The Project site is
located within the SMO planning boundary/airport influence area (AIA) as designated in the
ALUP.
Approximately 12 acres of the Project site is currently improved with non-contiguous paved
surface areas located roughly east and west of the existing Airport Park, small administration office
buildings (including Proteus Air Service), and airplane hangars. The remaining 2.2 acres of the
Project site consist of portions of the approximately 8.3-acre existing Airport Park that would be
renovated to accommodate the Project; the renovated portions of the existing park include
approximately 1.5 acres of the lawn area adjacent to the south parking lot, which would be
renovated as new lawn area and community garden plots, and the existing, 0.7 acre, 58-space north
parking lot, which would be removed to accommodate various park amenities. The existing Airport
Park is approximately 8.3 acres and is currently developed with recreational uses, including a
FIFA-regulation sized synthetic turf sports field, an off-leash dog park, picnic and BBQ facilities,
a 0.6-mile walking loop, and a restroom. Existing Airport Park facilities are heavily used and
approximately 2.2 acres of existing facilities would be incorporated into the Project’s proposed
park expansion.
Project improvements would occur primarily within the 12 acres of the two paved surface areas
(Figure 3.4-1). These two paved surface areas have historically been subject to a variety of uses,
ranging from a golf course to airport related and commercial activities. The west paved surface
area is roughly rectangular, of approximately 6 acres in size, and provides for existing SMO
facilities, including 12 small corrugated metal airplane hangars, approximately 48 airplane tie-
down spaces, small administration offices buildings, including Proteus Air Service, an art studio,
storage areas, and parking for vehicles. The east paved surface area is trapezoidal in shape and is
approximately 6 acres in size. Approximately 5.2 acres of the east surface area is paved and
recently supported approximately 78 airplane tie-down spaces, although airplanes are no longer
stored on this apron. The remainder of this surface area consists of a vegetated slope adjacent to
Bundy Drive.
SMO Operations
SMO recorded approximately 87,904 flight operations (i.e., departures, arrivals) in 2016. Propeller
and jet aircraft typically approach from the east and depart toward the west. Helicopters depart to
the north from a helipad at the center of the airport. The SMO air traffic control tower is manned
from 7:00 A.M. to 9:00 P.M. Although arrivals are permitted 24 hours a day, pilots are requested to
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-4 Airport Park Expansion Project
Final EIR – January 2018
avoid all operations between 11:00 P.M. and 7:00 A.M. Monday through Friday, or until 8 A.M. on
weekends. Exceptions are allowed for medical or public safety flights.
Current operations of SMO involve the routine use, storage, and transport of hazardous materials,
including airplane and jet fuel, cleaning solvents, lubricants and degreasers, and other routine
materials such as commercially available cleaning products and herbicides. As noted in Section
1.0, Introduction, the Federal Aviation Administration (FAA) reached an agreement (2017 consent
decree) with the City to allow closure of SMO and cessation of all operations of the airport in
2028. Additionally, shortening of the airport runway to 3,500 feet was approved by City Council
and is anticipated to be completed by early 2018.
SMO Operational Hazards
To minimize operational hazards, the FAA, California Department of Transportation (Caltrans)
Division of Aeronautics, and Los Angeles County Airport Land Use Commission (ALUC) have
standard policies and criteria for local agencies to apply to airport land use planning efforts and
development projects near an airport (refer to Section 3.4.2, Regulatory Framework, below).
Proper safety standards and airspace protection regulations minimize the number of people in the
vicinity of the airport that are exposed to the risks associated with potential aircraft accidents and
avoids flight hazards that interfere with aircraft navigation (Caltrans 2011). At SMO, there is a
designated Runway Protection Zone (RPZ) extending 150 feet from either end of the runway
center line.1 The Project site is not located within the designated RPZ (Figure 3.4-1). At its closest
point, the Project site is approximately 570 feet away from the closest designated RPZ at the
northeast end of the runway. Both the FAA and Caltrans Division of Aeronautics establish flight
path and adjacent use regulations to prevent obstructions from being constructed in the airport’s
navigable air space. Section VI of the ALUC’s ALUP establishes procedures for determining if
planning efforts or substantial changes to zoning and building ordinance are consistent with the
ALUP.
Accident and crash locations at SMO are well documented. Accidents typically occur during
takeoff or landing and occur on the runway or within a short radius of the airport. Over the 25-year
period beginning in 1992, a total of 28 accidents were reported for SMO, nine of them fatal.
(National Transportation Safety Board 2017). Many of the accidents resulted from a pilot error of
student pilots. Most of the accidents occurred on or just off the end of the runway centerline,
although seven aircraft landed in residential areas (including golf courses) within a two-mile radius
of SMO. While two painters were injured while working at one of the residences, no other injuries
1 As defined by the FAA, a Runway Protection Zone is an area off the runway end to enhance the protection of people
and property on the ground.
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-5
Final EIR – January 2018
occurred to people on the ground. In September 2013, a jet also veered off the runway during
landing and collided with an airplane hangar on the north side of the runway. No accidents have
occurred in the immediate vicinity of Airport Park. The SMO Administration Building and
airplane hangars form a physical barrier between the runway and the Project site.
Hazardous Materials Conditions
Historic Land Uses with Potential for Hazardous Materials Impacts
Previous uses on the Project site include a golf course, unpaved dirt roads for access to nearby
aircraft support facilities, aircraft parking, aircraft tie-down, developed structures, and storage
units, including storage for the adjacent Barker Hangar (Table 3.4-2, Parsons 2016).
A review of land use history and historic aerial photographs indicate that the Project site and
surrounding vicinity was undeveloped from an unknown period (earliest records of the
undeveloped site start in 1894) until the airport began operations in the early 1920s (the City
assumed ownership of SMO in 1926). By 1928, aerial photographs show the Project site developed
as a golf course. Aerial photographs indicate the Project site was occupied by a golf course through
1938, which potentially may have remained through subsequent years; however, the historic photo
record is incomplete and the next available record of aerial photographs indicate the golf course
was reestablished as vacant land by 1947 for aircraft parking (Parsons 2016)
In 1953, the first aircraft support structures appear on the east paved surface area. Records indicate
the buildings on the west paved surface area and the adjacent Barker Hangar were constructed in
1954 (Parsons 2016). By the late 1950s, the structures on the west paved surface area and the
adjacent Barker Hangar were present mostly as they are today. The existing aircraft-related
commercial uses at 3025 Airport Avenue (now occupied by Proteus Air Service) were in place
since at least 1967. By the 1960s, the east paved surface area was used as an aircraft tie-down area,
which has mostly remained until the airplane tie-downs were removed in 2016, and land in the
Project vicinity was highly developed. The Airport Administration Building north of the Project
site appears to have been replaced or improved in the 1980s (Parsons 2016).
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3.4-6
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-7
Final EIR – January 2018
Table 3.4-1. Previous Site Use
Location Previous Uses Year
3223 Donald
Douglas Loop
South (east paved
surface area)
Golf Course circa 1928–1938
Unpaved Property with Dirt Roads 1947
Unpaved Property, Dirt Roads, and Aircraft Parking 1953
Aircraft Tie-Down 1964–1983
Paved Aircraft Tie-Down with Small Unpaved Ramp 1989
Paved Aircraft Tie-Down 2002–2016
3025 Airport
Avenue (west
paved surface
area)
Golf Course circa 1928–1938
Unpaved Property with Dirt Roads 1947
Unpaved Property, Dirt Roads, and Aircraft Parking 1953
Developed Buildings with Aircraft Tie-Down 1964
Developed Buildings with Aircraft Tie-Down and Vehicle
Parking
1967–1983
Developed Buildings, Aircraft Tie-Down, Vehicle Parking
and Storage Units
1989–Present
Source: Parsons (2016).
Hazardous conditions associated with these former uses may include the past use of chlorinated
herbicides and pesticides for the golf course, and the use, and potential release of, various
hazardous materials associated with the maintenance and operation of aircraft. The portion of the
west paved surface area addressed as 3025 Airport Avenue has supported land uses related to SMO
since the mid-1950s, including a former aircraft wash area, former parts assembly/repair area, and
a former propeller shop, which may have involved the handling and potential release of hazardous
materials, including cleaning solvents and aircraft fluids. The other portion of the west paved
surface area currently and historically has been used for aircraft parking and tie-down since around
the same period (mid-1950s).
Presently, uses on the west paved surface area include the storage of commercially available
hazardous materials for Proteus Air Service and the adjacent Barker Hangar, including cleaning
materials and supplies, glues, oil, solvents, pesticides and degreasers. The portion of the east paved
surface area addressed as 3223 Donald Douglas Loop South currently and historically supported
land uses related to SMO, including aircraft tie-down areas, which involves the handling and
potential release of hazardous materials, including aircraft fluids. The aircraft tie-down areas on
both paved surface areas of the Project site were also used for fuel sumping, in which aircraft parts
were emptied of fuel by dumping it on the ground prior to long-term aircraft storage. Although the
areas are now paved, the historic maintenance and operation of aircraft, and potential release of
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-8 Airport Park Expansion Project
Final EIR – January 2018
hazardous materials may have caused soil contamination before existing paved areas were
developed.
Businesses of environmental concern (e.g., gasoline stations, manufacturing operations) were also
identified adjacent to the Project site and include a gas station adjacent to the northeast corner of
the Project site. The gas station has two records on Envirostor for leaking underground storage
tanks (LUSTs), however, the two LUST sites completed cleanup with a “Case Closed” status on
January 23, 1995 and May 4, 2009, respectively.
Site Investigations
Given the potential for the undocumented release of hazardous materials to have occurred from
the former aircraft cleaning, assembly, and manufacturing activities that have historically occurred
at the Project site and vicinity, a Phase I ESA and Phase II ESA was completed for the Project
site’s two paved surface areas and adjacent properties associated with the Barker Hangar
(Appendix D). The existing Airport Park area was not surveyed for the presence of hazardous
materials concerns. Further, supplemental site investigations were completed in July 2017 for the
two paved surface areas within the Project site to evaluate deeper soils in addition to the Phase I
and II ESA investigations (Appendix D). The results of these investigations are summarized
herein.
Historic aerial taken in 1938 (left) indicates that the Project site was developed as a golf course. By 1964 (right), the
Project site was heavily developed for airport-related uses.
Source: EDR (2015).
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-9
Final EIR – January 2018
West Paved Surface Area
On the west paved surface area, the site investigations identified storage units containing personal
items or that are used as art studios, etc. (Parsons 2016). The farthest north storage unit on the
Project site is the general storage room for the adjacent Barker Hangar, where small quantities of
various paints, weed killers, and cleaning materials were found to be properly stored. Within the
storage room, there is a yellow-painted metal closet approximately 3 feet by 6 feet for storage of
flammable items. The floor in the storage room was observed to be in generally good condition,
no major cracks or holes were observed, other than minor staining from years of use.
The site investigations also identified a metal outdoor storage container that contains paints and
other supplies for the existing commercial businesses on the west paved surface area. A trash bin
enclosure also exists on the west paved surface area; minimal staining was observed on the
pavement beneath the trash bins in this area. On the paved driveway adjacent to the outside of the
trash bin enclosure is a 2-foot by 3-foot area drain that was indicated as a storm drain during the
site investigation; there were some cracks on the asphalt around the drain.
Additionally, the site investigation found a remnant wash-rack area on the west paved surface area
from former airport-related operations that used chemicals as part of cleaning and manufacturing
of aircraft materials. The former wash-rack area has an outdoor floor drain on the pavement, which
is in fair condition with some cracks. Staining was observed on the pavement around the drain.
There is also a large metal shipping container where painting equipment and supplies are stored.
The interior metal roof of the building at 3025 Airport Avenue was observed to have some flakey
paint. The roof of the building was not accessed but observed from the ground, and several pipes
likely related to the Heating, Ventilation, and Air Conditioning (HVAC) systems have insulation
on them; the age, material type, and condition of the insulation is unknown.
The supplemental site investigation for the west paved surface area involved 16 soil vapor samples
to evaluate potential for VOC exposure. The results showed that VOC concentrations were low
and detected below minimum screening values and no further investigations are recommended.
Given this information, there is de minimus risk above background concentrations at this site.
East Paved Surface Area
On the east paved surface area, the site investigations identified the pavement beneath the aircraft
tie-down area as primarily asphalt with the common taxiway areas leading to the airport runway
consisting of concrete. In general, the concrete is in good condition with little to no cracks, and the
asphalt has few cracks as well. Minor staining on the pavement was observed at many of the
aircraft tie-down locations – presumably due to dripping of fluids associated with the aircraft.
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-10 Airport Park Expansion Project
Final EIR – January 2018
Additionally, some of the stains are likely related to the former practice of emptying aircraft parts
of fuel prior to long-term storage; some plane owners would toss a few ounces of fuel onto the
ground (a process called fuel sumping) so the fuel would not weather over time in the aircraft and
damage aircraft parts (Parsons 2016). During the site investigation, one aircraft was observed to
have an active minor fuel leak which was degrading the asphalt in an approximately 1-foot by 5-
foot area.
The supplemental site investigation for the east paved surface area involved 12 soil vapor samples
to evaluate potential for exposure to a range of hazardous materials. The testing did not identify
any concentrations of contaminants at or above regulatory guidelines; however, arsenic levels in
soil exceeded accepted background concentrations, though detections were anomalous and limited
in area. As such, a Human Health Risk Assessment (HHRA) was prepared for the Project site in
August 2017 (Appendix D). The HHRA assess the risk of exposure to concentrations of arsenic
and lead in soils on site, and concluded that the arsenic concentrations observed at the site appear
to be consistent with background concentrations and elevated lead concentrations at 1 and 3 feet
in the eastern portion of the site will be removed via future excavation activities. Given this
information, there is de minimus risk above background concentrations at this site.
Recognized Environmental Conditions (RECs)
Based on the site investigations
and hazardous materials
identified on the Project site, the
Phase I ESA identified
conditions indicative of a
previous release of hazardous
materials. Seven recognized
environmental conditions
(RECs) associated with the
historic land uses of the Project
site were identified and
recommendations for remediation of these RECs were provided (Parsons 2016).
There is potential for historic undocumented waste releases to have occurred, and the potential
exists for subsurface soil to have been impacted by the former activities (REC 1). The likelihood
of the subsurface being adversely impacted by former operations is possibly minimized, but not
eliminated, due to the reported thickness of the concrete and pavement in certain areas of the
Project site. Soils could also have been impacted by undocumented waste handling and disposal
Existing onsite commercial business and storage units do not generate
notable quantities of hazardous materials; however, small amounts of
paints, cleaners, solvents, and chemicals are typically stored and used
at the Project site.
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-11
Final EIR – January 2018
practices associated with nearby historic and current aircraft manufacturing operations.
Additionally, the potential presence of unknown compounds in fill or native soil associated with
former golf course use (REC 2) exists at the Project site, however, the Project site is covered with
concrete and asphalt, thereby a direct soil exposure pathway does not currently exist. Within the
east paved surface area, an unpaved dirt ramp near the eastern boundary of the Project site was
created with fill soil where some fill soil on an adjacent site was previously documented to be
impacted with volatile organic compounds (VOCs), metals, and petroleum hydrocarbons. All
Contaminants of Concern (COCs) were removed from the soil adjacent to the Project site,
however, the former ramp portion within the Project site (REC 3) has not been characterized or
removed. Additionally, the aircraft tie-down area was previously used for fuel sumping in which
aircraft parts were emptied of fuel by dumping it on the ground (REC 4).
A former wash area on the west paved surface area was historically associated with the use of
chlorinated solvents (REC 5). Additionally, records indicate a spray booth existed on the north
side of the same building, between at least 1980 and 1988 (REC 6). The existing buildings have
the potential to contain lead-based paint (LBP) or asbestos-containing materials (ACMs), based
on the age of the buildings (REC 7). The existing buildings at 3223 Donald Douglas Loop South
(east paved surface area) and 3025 Airport Avenue (west paved surface area) were constructed
around 1954 (Parsons 2016). Based on the age of the buildings, the following hazardous materials
are of concern:
• Asbestos-Containing Materials (ACMs) – Asbestos is a carcinogenic mineral fiber that
was widely used in a variety of building construction materials for insulation, as well as in
friction and heat-resistant products. The use and manufacturing of ACMs was banned in
1977 in California. Older buildings constructed prior to 1978 may contain ACMs. Asbestos
release can occur after ACMs are disturbed by cutting, sanding or other remodeling
activities. Improper attempts to remove ACMs can release asbestos fibers into the air,
increasing asbestos levels and affecting human respiratory health. At the Project site, ACM
may be present in pipe insulation, floor tile mastic, roof and insulation materials of the
building. There are no records pertaining to the presence, maintenance, or removal of
ACMs on the Project site and suspect structures that may contain ACM were not sampled
for asbestos content at the time of the assessment (Parsons 2016); and
• Lead-Based Paint (LBP) - Lead is a recognized harmful environmental pollutant exposed
through air, drinking water, food, contaminated soil, deteriorating paint, and dust. Before
the dangers of lead were documented, it was widely used in paint. In 1978, the State of
California banned the use of LBP. Older buildings constructed prior to 1978 may contain
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-12 Airport Park Expansion Project
Final EIR – January 2018
LBP. If LBP is improperly removed from surfaces by dry scraping or sanding, LBP can be
absorbed into the body and could pose a potential public health risk. All painted building
surfaces at the Project site could potentially be lead-based due to the age of the buildings.
There are no records regarding the presence or disposition of potential LBP on building
structures and suspect structures containing LBP or lead-containing material were not
sampled for content at the time of the assessment. It should be noted that the painted lines
on the aircraft tie-down areas are FAA compliant paint which is repainted every six months
(Parsons 2016).
When ACMs or LBP are disturbed during renovation or demolition activities, there is a risk of
release of these hazardous materials, which can be harmful to human health.
A portion of the existing Airport Park immediately adjacent to the south side of the east paved
surface area (reported as 3301 and 3401 Airport Avenue) has record of contaminated soil
excavation and soil confirmation sampling in eight areas. Removal of soil was completed based
on agency-approved site-specific cleanup criteria; based on this information, the existing park is
considered to be a Controlled REC (CREC) requiring no further action (Parsons 2016).
In order to remediate and further analyze the identified RECs, the Phase I ESA recommended
comprehensive LBP and ACM surveys, and soil and gas sampling through preparation of a
Phase II ESA to characterize the potential for remaining subsurface soil and soil gas contamination
at the former wash area, around the building located at 3021 Airport Avenue, and in all areas where
surface pavement is to be removed.
A Phase II ESA and two Supplemental Site Assessment Reports, each for the east (Area A-1) and
west (Area A-2) paved surface areas, were subsequently conducted for further examination of
RECs and hazardous materials within the Project site. The Phase II ESA and Supplemental Site
Assessment Reports conducted soil sampling and field observations to analyze for the presence of
COCs. A total of 57 soil samples were collected and analyzed (30 in the east paved surface area,
27 in the west paved surface area). Twenty-five soil borings (12 in the east paved surface area, 13
in the west paved surface area) were also advanced to a depth of five feet below ground surface
(bgs). The soil samples were analyzed and compared to soil cleanup screening levels established
by the Los Angeles Regional Water Quality Control Board (LARWQCB), United States
Environmental Protection Agency (U.S. EPA), and California Environmental Protection Agency
(CalEPA) California Human Health Screening Levels (CHHSLs). The Phase II ESA and
Supplemental Site Assessment Report for Area A-1 found two isolated concentrations of arsenic
above accepted background levels in shallow soil within the east paved surface area, both in the
approximate location of the new east sports field (ES Engineering Services, LLC 2016a). The
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-13
Final EIR – January 2018
Phase II ESA and Supplemental Site Assessment Reports also found two isolated occurrences of
lead in the area of the former ramp (just north of the existing dog park) (ES Engineering Services,
LLC 2016b). Based on these findings, the Phase II ESA and Supplemental Site Assessment Report
for Area A-1 recommended removal of the identified COCs and for a HHRA to be conducted for
future recreational use of the Project site. In August 2017, the Project’s HHRA concluded that the
Project can be developed as currently planned without any predicted unacceptable health effects.
The Supplemental Site Assessment Report for Area A-2 concluded that no further investigations
are recommended for the west paved surface area.
Records Search (Hazardous Materials Site Listing)
Federal and state databases were searched to determine if the Project site is listed as a known
hazardous or contaminated site. None of the federal or state government databases searched
identified the Project site as hazardous or contaminated as a result of a current or past hazardous
material release (Table 3.4-2).
Table 3.4-2. Summary of Database Search for Project Site
Database Jurisdiction Level Records Found
Biennial Report Federal None
Comprehensive Environmental Response Compensation, and
Liability Act Information System (CERCLIS)
Federal None
Enviromapper Federal None
Envirostor State None
Emergency Response Notification System List (ERNS) Federal None
Geotracker State None
National Priority List (NPL) Federal None
RADInfo Federal None
Toxic Release Inventory (TRI) Federal None
Toxmap Federal None
Toxic Substances Control Act Search Federal None
Sources: EDR (2015) and DTSC (2017).
Additionally, based on a review of Santa Monica Fire Department (SMFD) records, there are no
documented occurrences of hazardous materials spills or hazardous materials storage on the
Project site. No environmental permits or notices of violation, records of underground storage
tanks (UST), aboveground storage tanks (AST) or releases of hazardous materials were identified
onsite based on a review of state and local environmental regulatory agency and fire department
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-14 Airport Park Expansion Project
Final EIR – January 2018
files. In summary, the Project site has not been identified on any list indicating current or historical
occurrences of hazardous materials storage, releases and remediation.
Potential Migration of Contaminants onto the Project site from an Offsite Source
Offsite hazardous waste sites that are located adjacent to the Project site or hydraulically up-
gradient could be a concern if contaminants migrate to the Project site. For the Project site, the
measured groundwater gradient based on hydrogeological data is in a southerly direction, cross-
gradient of the current Project site, with groundwater occurring approximately 70 feet bgs (ES
Engineering Services, LLC 2016a; Parsons 2016). Hazardous sites located hydraulically down-
gradient or cross-gradient are unlikely to impact the Project site since the predominate movement
of the contaminated ground water or chemical plume is away from the Project site along the
hydraulic gradient of the area.
The Phase I ESA identified several offsite properties in the immediate or nearby vicinity of the
Project site that are upgradient and may present concerns for the Project site. However, all
identified sites within 0.25-mile of the Project site have been remediated with a “Case Closed”
status and are identified as CRECs. The LARWQCB maintains files for the Airport Administration
Building directly adjacent to the Project site at 3223 Donald Douglas Loop South. Specifically,
hydrocarbon-impacted soil was encountered during the removal of an UST (related to a former
fueling station) in 1986. Assessment and remediation of soil and groundwater occurred, and the
LARWQCB issued a “Case Closed” status on January 29, 2003. Based on this information the
property nearby the Project site is considered a CREC (Parsons 2016).
A former Shell service station is located at 3010 South Bundy Drive, approximately 230 feet
northeast of the Project site across Bundy Drive. The site was identified has having a former LUST
site, which was closed by the LARWQCB on May 4, 2009. The groundwater monitoring wells at
the Shell site went dry several years prior to being granted closure; the shallowest depth to water
readings from the mid-2000s was approximately 60 feet bgs. Based on the fact this former LUST
case was granted closure by the RWQCB this site is considered a CREC in the vicinity of the
Project site (Parsons 2016).
Records indicate at least four operators occupied 3021 Airport Avenue (the adjacent Barker
Hangar) that involved handling of hazardous materials: 1) Singlar Lear, 2) Pac Aero Engineering,
3) Pacific Airmotive and 4) Purex. Information of past activities include the cleaning and repairing
of airplanes and aircraft parts, which generated solvents and oil as a hazardous waste by-product.
It is unknown what hazardous waste management practices were used for solvents; the toxic
chemicals coordinator for the City previously investigated the Project site (Department of Toxic
3.4 HAZARDS AND HAZARDOUS MATERIALS
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Final EIR – January 2018
Substances Control [DTSC] records) and concluded solvents were disposed in the sewer (Parsons
2016).
Evidence of the storage and use of commercially available hazardous materials were observed to
be stored properly at the adjacent Barker Hangar during Phase I ESA reconnaissance (Parsons
2016). No evidence was observed of spill or other release of these hazardous materials into the
surrounding environment.
A review of federal, state, and local contaminated site inventories identified a total of 61 sites with
79 records of hazardous releases or hazardous waste generators within the Project vicinity (Table
3.4-1). Several of these sites are adjacent to the Project site, however, based on the regulatory
status, the sites are not expected to present environmental concerns. Out of the 61 identified sites,
one active cleanup site is at an equal or higher elevation located 0.5 mile north of the Project site,
containing potential soil or groundwater contaminants that include VOCs. Boeing is currently
implementing soil remediation, which consist of one inactive and two active Soil Vapor Extraction
(SVE) systems, to remove mobile VOC mass, to mitigate potential indoor air vapor intrusion, and
to reduce the potential mass flux of VOCs to groundwater; groundwater monitoring is currently
ongoing (DTSC 2017). Five inactive sites within a one-mile radius of the Project site require
further evaluation as of July 1, 2005, however these sites are governed by military evaluation
(DTSC 2017) and were not identified as RECs in the Phase I and Phase II ESAs. The remaining
sites are archived cases, completed action sites, or hazardous materials generators with no
identified hazardous releases.
3.4.2 Regulatory Framework
Several federal, state, and local laws and regulations have been enacted to regulate the safe
operation of airports, hazardous materials, and hazardous wastes, as well as to manage and
remediate sites contaminated by hazardous substances. These regulations limit the risk of harm
from accident during the operation of aircraft, as well as regulate the upset during the use,
transport, handling, storage, and disposal of hazardous materials.
Airport operations and hazardous materials management is subject to multiple laws, policies, and
regulations at all levels of government. The FAA is the primary agency that regulates the safe
operation of airports and publishes standards for general aviation airport safety, runway safety,
and safety management systems. Caltrans Division of Aeronautics provides for the integration of
aviation into transportation system planning with noise regulation and land use planning laws that
foster compatible land use around airports and minimize incompatible land use development
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3.4-16 Airport Park Expansion Project
Final EIR – January 2018
Table 3.4-1. Regulatory Database Search Summary
Regulatory List Search
Radius Potential for Contaminant Migration from Identified Sites
CERCLIS-Active Sites 0.5 mile 1 record; site located at 3000 Ocean Park Boulevard (Boeing Co.).
Based on the regulatory status, the site is an open case for
assessment and interim remedial action as of 03/08/2011. The
contaminant of concern is VOCs.
CERCLIS-No Further
Remedial Action Planned
Sites (NFRAP)
0.5 mile 2 records; including 1 site on target property and 1 site located down
gradient (3021 Airport Avenue). Based on the regulatory status, the
sites are not expected to present environmental concerns.
EnviroStor 1.0 mile 6 records; including 1 complete voluntary cleanup sites requiring no
further action on target property and 5 inactive cleanup sites
requiring further evaluation, governed by military evaluation.
Leaking Underground
Storage Tanks (LUST) and
Spills, Leaks,
Investigations, and Cleanup
(SLIC)
0.5 mile 10 records; 9 sites, including 1 on target property, that are completed
action “Case Closed” status sites that would unlikely present
environmental concern. One SLIC site is classified as Open –
Assessment & Interim Remedial Action as of March 8, 2011
RCRA Generators 0.25 mile 8 records; including 1 on target property. Listed sites do not indicate
a release of hazardous material. Their identification as generators
requires that they must comply with specific regulations concerning
waste storage and disposal.
Registered
Underground/Above
ground Storage Tank
Facilities (UST/AST)
0.25 mile 3 records; including 1 site on target property and 2 sites down
gradient. The listed sites do not indicate a release of hazardous
material. Their identification indicates the presence of under- or
above-ground storage tanks.
Local Lists of
Landfill/Solid Waste
Disposal Sites
0.5 mile 1 record identified by Waste Management Unit Database
(WMUDS/SWAT). Listed site does not indicate release of hazardous
material. The site is not expected to present environmental concerns.
Local Lists of Registered
Storage Tanks
0.25 mile 13 records; including 11 on target property. Listed sites do not
indicate release of hazardous material.
Local Historic CORTESE 0.5 mile 7 records; including 1 on target property that were historically listed
as Hazardous Waste and Substance Sites.
Records of Emergency
Release Reports
TP 1 record identified by California Hazardous Material Incident Report
System (CHMIRS). Record indicates accidental release or spill.
Other Local Ascertainable
Records
TP 15 records; 2 sites (FINDS), 3 sites (EMI), 6 sites (HAZNET), 1 site
(NPDES), 1 site (Notify 65), 1 site (LA Co. Site Mitigation), and 1
site (WDS). Records indicate sites have other database listings.
EDR Exclusive Records 0.125 mile 6 records; 1 site identified as a Historic Cleaners and 5 sites
identified as Historic Auto Stations. The sites are not expected to
present environmental concerns.
Exclusive Recorded
Government Archives
TP 6 records identified Recovered Government Archive Leaking
Underground Storage Tanks (RGA LUST) for historic records.
Source: EDR (2015).
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Final EIR – January 2018
around airports. The Los Angeles County ALUC prepares the ALUP and ensures that County and
City plans are consistent with the ALUP. The City also has a responsibility to ensure the orderly
development of the airports within their local jurisdiction and make sure all applicable City
planning documents, and zoning and building ordinances are consistent with the ALUP.
Similarly, multiple agencies are responsible for enforcing applicable laws and regulations for the
handling and cleanup of specific materials determined to pose a risk to human health or the
environment. The enforcing agency is the Certified Unified Program Agency (CUPA). The SMFD
is the CUPA at the local level for the City. Enforcement agencies at the state level include two
branches of the CalEPA: the DTSC, and the LARWQCB). The federal enforcement agency is the
U.S. EPA.
Federal Regulations
Operational Hazards
To maintain the operational safety of airports, Code of Federal Regulation (CFR) Title 14 Part 77
(FAA Part 77) establishes standards for determining obstructions that cause substantial adverse
effect on air navigation. This includes the establishment of a RPZ (formerly called Clear Zones),
which is an area at ground level that provides for the unobstructed passage of landing aircraft
through the above airspace. The RPZ begins at the end of the runway and is sized base on the
operational variables of each airport. The RPZ is the most critical safety area under the approach
path and should be kept free of all obstructions. No structures or the congregation of people are
typically allowed within a RPZ, however, single-family homes that were built prior to the
establishment of RPZs are within the RPZs at both ends of SMO’s runway.
FAA Part 777 also establishes standards and notification requirements for objects affecting
navigable airspace, such as new structures or lighting standards. This notification serves as the
basis for evaluating the effect of the construction or alteration on operating procedures;
determining the potential hazardous effect of the proposed construction on air navigation;
identifying mitigating measures to enhance safe air navigation; and charting of new objects.
Notification also allows the FAA to identify potential aeronautical hazards in advance to prevent
or minimize the adverse impacts to the safe and efficient use of navigable airspace. The FAA is
notified about development projects through the filing of FAA Form 7460-1 (Notice of Proposed
Construction or Alteration).
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Final EIR – January 2018
Hazardous Materials
Several federal agencies regulate hazardous materials. These include the U.S. EPA, Department
of Labor (Federal OSHA), and the Department of Transportation (DOT). Applicable federal
regulations are contained primarily in Titles 10, 29, 40, and 49 of the CFR. In particular, Title 49
of the CFR governs the manufacture of packaging and transport containers, packing and repacking,
labeling, and the marking of hazardous material transport. Some of the major federal laws include
the following statutes (and regulations promulgated there under):
• Asbestos Hazard Emergency Response Act (AHERA) (1986).
• Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) (1980)
• Clean Water Act (1977).
• Federal OSHA - Process Safety Management Standard (29 CFR 1910.119).
• National Emission Standard for Hazardous Air Pollutants 40 CFR 61 Subpart M
(NESHAP).
• Residential Lead-Based Paint Hazard Reduction Act of (1992), also known as
Title X.
State Policies and Regulations
Operational Hazards
California Public Utilities Code Sections 21670–21679 designate the power to regulate the orderly
development of California’s airports and surrounding areas to the counties. Regulatory authority
is the responsibility of an established ALUC. Public Utilities Code Section 21675 requires that
each County’s ALUC prepare a comprehensive land use plan for the orderly growth of each public
airport and the area surrounding the airport within the jurisdiction of the commission. The Los
Angeles ALUC and ALUP are discussed under regional policies below.
The Caltrans Division of Aeronautics is responsible for performing safety functions that are not
the FAA’s responsibility. The State Aeronautics Act, Public Utilities Code Section 21001 et seq.,
is the foundation for these policies. The Division of Aeronautics issues permits for and annually
inspects hospital heliports and public-use airports; makes recommendations regarding proposed
school sites within two miles of an airport runway; and authorizes helicopter landing sites at or
near schools. The Division of Aeronautics also administers noise regulation and land use planning
laws that foster compatible land use around airports and encourages environmental mitigation
measures to lessen aircraft noise, air pollution, and other impacts caused by aviation. Further, the
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Division of Aeronautics provides grants and loans at airports for safety, maintenance and capital
improvement projects.
In October 2011, the Caltrans Division of Aeronautics approved the current California Airport
Land Use Planning Handbook. The purpose of the Handbook is to provide guidance for conducting
airport land use compatibility planning as required by PUC, Article 3.5, Airport Land Use
Commissions. Article 3.5 outlines the statutory requirements for ALUCs including the preparation
of an Airport Land Use Plan (ALUP). Article 3.5 mandates that the Division of Aeronautics create
a Handbook that contains the identification of essential elements for the preparation of an ALUP.
This Handbook is intended to (1) provide information to ALUCs, their staffs, airport proprietors,
cities, counties, consultants, and the public, (2) to identify the requirements and procedures for
preparing effective compatibility planning documents, and (3) define exemptions where
applicable. The 2004 Los Angeles County ALUP has not yet been revised to the 2011 Handbook,
and is instead based on its 2002 predecessor.
The Handbook also establishes six Safety Zones to reduce airport hazards to nearby uses. Safety
zones are based, in general, on historical accident location patterns for all airports, together with
consideration for where aircraft fly and how they are being operated during takeoff departures and
landing approaches. Compatible land uses and development standards are then established for each
Safety Zone, with the goal of protecting people on the ground and in the air from accidents.
According to the Handbook, Runway 3/21 at SMO is considered a Medium General Aviation
Runway (runway length of 4,000–5,999). Based on dimensions established in the Handbook,
portions of the Project site are currently within the Sideline Safety Zone (Zone 5), which extends
500 feet from the runway edge for a Medium General Aviation Runway. The risk level is
considered low to moderate in Zone 5, with the most common accident type being aircraft losing
directional control and veering off the side of the runway. The basic compatibility standards
recommend prohibiting stadiums and group recreational uses in Zone 5, although neither the
Handbook or FAA guidelines specifically define what is considered a group recreational use.
Following completion of the Runway Shortening Project, Runway 3/21 at SMO would 3,500 feet
in length, and therefore, classified as a Short General Aviation Runway (runway length less than
4,000 feet) by the Handbook. Although the size and location of safety zones following the Runway
Shortening Project would ultimately be determined through coordination between the City and
ALUC, in general, Zone 5 extends 250 feet from the runway edge for a Short General Aviation
Runway. No portion of the Project site is located within 250 feet of the runway edge.
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-20 Airport Park Expansion Project
Final EIR – January 2018
Hazardous Materials
Primary state agencies with jurisdiction over hazardous chemical materials management include
the DTSC and the RWQCB. Other state agencies involved in hazardous materials management are
the Department of Industrial Relations (State OSHA implementation), state Office of Emergency
Services (OES—California Accidental Release Prevention implementation), Air Resources Board
(ARB), Caltrans, State Office of Environmental Health Hazard Assessment (OEHHA—
Proposition 65 implementation), and the California Integrated Waste Management Board
(CIWMB). The enforcement agencies for hazardous materials transportation regulations are the
California Highway Patrol (CHP) and Caltrans. Hazardous materials waste transporters are
responsible for complying with all applicable packaging, labeling, and shipping regulations.
Hazardous chemical and biohazardous materials management laws in California include the
following statutes (and regulations promulgated thereunder):
• Hazardous Materials Management Act—business plan reporting
• Hazardous Waste Control Act—hazardous waste management
• Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65)—release
of and exposure to carcinogenic chemicals
• Hazardous Substances Act—cleanup of contamination
• Hazardous Waste Management Planning and Facility Siting (Tanner Act)—
preparation of hazardous waste management plans and the siting of hazardous
waste facilities
• Hazardous Materials Storage and Emergency Response—including response to
hazardous materials incidents
DTSC EnviroStor Database: DTSC maintains a database that contains information on properties
in California where hazardous substances have been released, or where the potential for a release
exists. This database is known as EnviroStor (formerly CalSites) and is one of a number of
databases that comprise the Cortese List and Spills, Leaks, Investigations, and Cleanups (SLIC)
List. EnviroStor provides a brief history of cleanup activities, contaminants of concern, and
scheduled future cleanup activities. The EnviroStor database also includes properties that have
been remediated and certified by DTSC.
State Water Resources Control Board (SWRCB) Geotracker Database: The GeoTracker is the
SWRCB’s online database that 1) provides access to statewide environmental data, and 2) tracks
regulatory data for the following types of sites:
• Leaking Underground Fuel Tank (LUFT) cleanup sites;
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Final EIR – January 2018
• Cleanup Program Sites (CPS; also known as Site Cleanups [SC] and formerly known as
Spills, Leaks, Investigations, and Cleanups [SLIC] sites);
• Military sites (consisting of: Military UST sites; Military Privatized sites;
• Military Cleanup sites (formerly known as DoD non UST);
• Land Disposal sites (Landfills); and
• Permitted UST facilities.
Certified Unified Program Agency (CUPA): Senate Bill 1082, passed in 1993, created the CUPA.
The Unified Program consolidates 6 state environmental programs under one program, under the
authority of a CUPA. The SMFD was certified by CalEPA as the CUPA for the City in 1997.
Designed to protect the public, worker safety, first responders and the environment, the Santa
Monica Fire Prevention Division has oversight responsible for hazardous waste, underground
storage tanks, above ground tanks, hazardous materials, community right-to-know, and accidental
release prevention programs. The Division conducts both CUPA regulatory inspections and Fire
Code inspections for all program elements, with the exception of the hazardous waste program.
The Division contracts with the Los Angeles County Fire Department (LACFD) Health Hazardous
Materials for hazardous waste inspection and enforcement of the hazardous waste program.
2010 State of California Multi-Hazard Mitigation Plan (SHMP): The SHMP is the official
statement of the state's hazard identification, vulnerability analysis, and hazard mitigation strategy.
The goal of the SHMP is to guide implementation activities to achieve the greatest reduction of
vulnerability, which results in saved lives, reduced injuries, reduced property damages, and
protection for the environment. In particular, the SHMP helps administer the Local Hazard
Mitigation Plan (LHMP) program for the state. The California Emergency Management Agency
(Cal-EMA) supports and assists local governments in the development of LHMPs and tracks the
progress and effectiveness of plan updates and projects. It provides local governments with
information on integrating hazard identification, risk assessment, risk management, and loss
prevention into a comprehensive approach to hazard mitigation and helps them identify cost-
effective mitigation measures and projects.
Regional and Local Policies and Regulations
Operational Hazards
Los Angeles County ALUP: The Project site is located within SMO’s AIA. As such, the planning
of airport operations and nearby land uses are subject to the coordinated efforts of Los Angeles
County ALUC. The purpose of the ALUC is to protect the public health, safety, and welfare by
ensuring the orderly expansion of airports and the adoption of land use measures that would
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-22 Airport Park Expansion Project
Final EIR – January 2018
minimize public exposure to adverse noise and safety impacts within areas around public use
airports. As introduced above, state law mandates that the ALUC prepare a comprehensive land
use plan for airports in its jurisdiction. The ALUP establishes a set of land use planning standards
that local agencies should incorporate into planning and zoning efforts within the AIA. As
discussed above, changes to a general plan or specific plan, or a substantial modification of zoning
or building ordinances are subject to review by the ALUC for compliance to the adopted ALUP.
In 2004, the Los Angeles County ALUC adopted the ALUP for all airports in Los Angeles County
in accordance with the 2002 Caltrans California Airport Land Use Planning Handbook. The ALUP
establishes airport planning boundaries and levels of land use compatibility associated with FAA
and Caltrans standards and guidelines, as well as provides a framework to guide future
development and strengthen existing safety and noise regulations in areas within proximity to all
airports in the County. The policies that are applicable to the Project are listed below:
Policy S-1. Establish “runway protection zones” contiguous to the ends of each runway.
These RPZs shall be identical to the FAA’s Runway Protection Zone (formally called Clear
Zones).
Policy S-2. Prohibit above ground storage of more than 100 gallons of flammable liquids
or toxic materials on any one net acre in a designated RPZ. It is recommended that these
materials be stored underground.
Policy S-4. Prohibit within a designated RPZ, the erection or growth of objects which rise
above an approach surface unless supported by evidence that it does not create a safety
hazard and is approved by the FAA.
Policy S-6. Prohibit uses which would generate electrical interference that may be
detrimental to the operation of aircraft and/or aircraft instrumentation.
Policy S-7. Comply with the height restriction standards and procedures set forth in FAA
Part 77.
Despite the goals of the ACLUP, the ALUC’s jurisdiction and power are limited. The ALUC does
not have jurisdiction over airport operations, nor does the ALUC have the authority to zone
property or apply other land use controls. Recommendations made by the ALUC are advisory to
local jurisdictions. The City has sole responsibility to specify which compatible land use at SMO
and surrounding SMO property is appropriate through its planning and zoning powers.
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-23
Final EIR – January 2018
Hazardous Materials
South Coast Air Quality Management District (SCAQMD). The SCAQMD regulates asbestos
through Rule 1403, Asbestos Emissions from Renovation/Demolition Activities. Rule 1403
defines asbestos as a toxic material and controls the emissions of asbestos from demolition and
renovation activities by specifying agency notifications, appropriate removal procedures, and
handling and cleanup procedures. Rule 1403 applies to owners and operators involved in the
demolition or renovation of asbestos-containing structures, asbestos storage facilities, and waste
disposal sites.
CUPA. As the designated CUPA for the City, the SMFD is the primary local agency with
responsibility for implementing federal and state laws and regulations pertaining to hazardous
materials management. The SMFD maintains the records regarding location and status of
hazardous materials sites in the City and administers programs that regulate and enforce the
transport, use, storage, manufacturing, and remediation of hazardous materials.
City of Santa Monica General Plan Safety Element. The Safety Element of the General Plan
contains several policies regarding hazardous materials, fire hazards and emergency management.
Specifically, it provides assessment of natural and manmade hazards, as well as providing a
framework and guiding policies to guide future development and strengthen existing regulations
within the City. The policies that are applicable to the Project and hazardous materials are listed
below:
Policy 5.1. The use, storage, and transportation of toxic, explosive, and other hazardous
and extremely hazardous materials shall be strictly controlled to prevent unauthorized
discharges.
Policy 5.1.2. The City shall continue to manage the Hazardous Materials Disclosure
Program to identify and regulate business handling types and quantities of extremely
hazardous materials, or hazardous materials in greater than consumer types and quantities.
Policy 5.1.3. The City shall continue to require annual reporting by businesses to the
Environmental Programs Division of the use, storage or manufacture of hazardous or
extremely hazardous materials in any quantity. The City shall continue to require annual
submission or verification of business emergency plans by businesses that use, store or
manufacture any hazardous or extremely hazardous materials in quantities equal to or
greater than 55 gallons, 500 pounds or 200 cubic feet.
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-24 Airport Park Expansion Project
Final EIR – January 2018
City of Santa Monica Municipal Code (SMMC). Chapter 5.24 of the SMMC establishes Hazardous
Materials Reporting and Response Planning (HMRRP) and Hazardous Materials Management
Plans (HMMP) requirements. Section 5.24.010 requires all businesses to declare to the City if they
use, store, or manufacture any quantity of a hazardous or extremely hazardous material. An annual
business plan must be submitted if the business uses, stores, or manufactures hazardous materials
exceeding 55-gallons or more of liquid, 500-pounds or more of solid, and/or 200-cubic feet or
more of a gas, at stand temperature and pressure. In addition to inventorying the materials in
question, the business plan must describe emergency response plans and procedures to be used in
the event of an accident. The requirements are established to prevent or mitigate the damage to the
health and safety of persons and the environment from the release or threatened release of
hazardous materials into the workplace and environment.
3.4.3 Impact Assessment and Methodology
Thresholds for Determining Significance
The following thresholds of significance are based on Appendix G of the 2017 CEQA Guidelines.
For purposes of this EIR, implementation of the Project may have a significant adverse impact
related to hazards or hazardous materials if:
a) The Project would create a significant hazard to the public or the environment through the
routine transport, use, or disposal of hazardous materials;
b) The Project would 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) The Project would emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within one-quarter mile of an existing or proposed school;
d) The Project would be located on a site which is included on a list of hazardous materials
sites compiled pursuant of Government Code Section 65962.5, and as a result, it would
create a significant hazard to the public or the environment;
e) For a Project located within an airport land use plan or, where such a plan has not been
adopted, within 2 miles of a public airport or public use airport, the Project would result in
a safety hazard for people residing or working in the Project site;
f) For a Project within the vicinity of a private airstrip, the Project would result in a safety
hazard for people residing or working in the Project site;
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-25
Final EIR – January 2018
g) The Project would impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan; and/or
h) The Project would expose people or structures to a significant risk of loss, injury or death
involving wildland fires, including where wildlands are adjacent to urbanized areas or
where residences are intermixed with wildlands.
Non-Applicable Threshold(s):
• Threshold (d) Hazardous Materials Sites: As discussed above, the Project site is not
identified on either the proposed or final National Priority List or DTSC list of sites
pursuant of Government Code Section 65962.5 that require clean-up of toxic or hazardous
contamination. Accordingly, there would be no potentially significant adverse impact from
listed hazardous materials sites. Therefore, this issue is not analyzed further in this EIR.
• Thresholds (f) Private Air Strip: SMO is owned and operated by the City, and the Project
site is not located within the vicinity of any private airstrips. Accordingly, the Project
would not result in a safety hazard for people residing or working in the area due to
proximity to a private airstrip. Therefore, this issue is not analyzed further in this EIR.
Project impacts associated with a public airport or public use airport are evaluated in detail
below.
• Threshold (h) Wildfire: The Project vicinity is located in a highly urbanized area. The
southern extent of the Very High Fire Severity Zone designated within a Local
Responsibility Area (LRA) terminates approximately 3 miles north of the Project site and
the nearest Very High Fire Hazard Severity Zone designated within a State Responsibility
Area is approximately 5 miles north of the Project site. As such, the Project is not at risk
for wildfires and therefore, this issue will not be analyzed further in this EIR.
Methodology
The potential for airport operations to result in hazards at the Project site are evaluated for
consistency with federal, state, and local regulations that promote safe air space and reduce the
potential for operational hazards by regulating the size, height, and use of proposed development
projects in the vicinity of an airport, including within an established RPZ.
The potential for hazardous materials impacts to result from construction or operation of the
Project is based, in part, on the Phase I and Phase II ESAs prepared for the Project. As part of the
Phase I ESA environmental assessment, visual inspections of readily-accessed interior and exterior
areas of the premises were conducted. Records, photographs, and historic maps were reviewed to
evaluate property issues involving hazardous materials. A subsequent Phase II ESA advanced 25
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3.4-26 Airport Park Expansion Project
Final EIR – January 2018
soil borings and conducted soil sampling. On May 30, 2017, the Supplemental Site Assessment
Report collected a total of 12 soil vapor samples from the East Parcel. Each soil vapor sample
was analyzed for full‐scan VOCs, including tetrachloroethylene (PCE), trichloroethylene (TCE),
1,1 dichloroethene (1,1 DCE), cis‐1,2 DCE, vinyl chloride, trans‐1,2 DCE, chloroethane, 4‐
isoproplytoluene, benzene, toluene, ethylbenzene and xylenes (collectively BTEX), methyl‐tert‐
butyl ether (MTBE) and naphthalene.
3.4.4 Project Impacts and Mitigation Measures
Would the Project create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials?
HAZ-1 The Project would not create a hazard to the public or the environment
through the routine transport, use, or disposal of hazardous materials.
Compliance with local, state, and federal regulations would ensure that this
impact would be less than significant.
Impact Description (HAZ-1)
The Project would include redevelopment of non-aviation land into new recreational amenities as
described in Section 2.0, Project Description. Operation of these recreational uses would entail
routine cleaning and maintenance activities using commercially available hazardous materials,
such as cleaning fluids, detergents, and pesticides/herbicides, etc. In addition, construction of the
Project would involve the use of potentially hazardous materials, including vehicle fuels, oils, and
transmission fluids. However, use of such materials would likely be in limited (i.e., not
commercially reportable) quantities and would be handled in compliance with federal, state, and
local regulations pertaining to their transport, use, and disposal, such as those established by the
U.S. EPA, CalEPA, OSHA, Cal OSHA, and the DTSC. Implementation of standard good
housekeeping measures, best management practices (BMPs), site maintenance and security
precautions, as well as compliance with standards and regulations would ensure that the potential
impacts related to the routine transport, use, or disposal of hazardous materials to less than
significant.
Would the Project 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?
HAZ-2 Construction and operation of the Project could potentially create a hazard to
the public or the environment through reasonably foreseeable upset and
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Airport Park Expansion Project 3.4-27
Final EIR – January 2018
accidental conditions involving the release of hazardous materials into the
environment associated with past uses of the site and demolition of existing
buildings. However, compliance with all applicable regulations and
implementation of mitigation would reduce impacts to less than significant.
Impact Description (HAZ-2)
Construction
Lead-Based Paint (LBP) and Asbestos-Containing Materials (ACMs)
The Project would involve demolition of existing onsite aviation-related structures (e.g., airplane
hangars) and miscellaneous commercial buildings. Due to the age of the existing buildings (which
were constructed by at least 1954), the Phase I ESA identified that hazardous materials such as
LBPs and ACMs may be present in the structures. As such, the potential exists that workers or the
public could be exposed to these materials during demolition of the onsite buildings and hauling
of debris materials. As required by OSHA, Cal OSHA, DTSC and SCAQMD Rule 1403, if LBPs
or ACMs are detected during demolition or construction activities, standard regulatory practices
would be applied (development of a health and safety plan, protective equipment, fugitive dust
controls, BMPs, etc.). Existing state regulations require the abatement and control of asbestos and
lead in advance of demolishment or renovation activities, as regulated in SCAQMD Rule 1403
(Asbestos) and Title 8, Industrial Relations, of the CCR. If not properly abated, the accidental
release of asbestos and/or lead could pose a hazard to the environment and public health, which
could have a potentially significant impact. In order to reduce impacts associated with LBP and
ACM to less than significant, MM HAZ-1 and MM HAZ-2 are recommended.
Subsurface Soil Contamination
The Phase I and Phase II ESAs identified multiple RECs that could create a hazard to the public
or the environment through reasonably foreseeable upset and accidental conditions involving the
release of hazardous materials into the environment during removal of existing paving and site
preparation and grading. The unpaved dirt ramp on the far eastern side of the Project site was
identified as having isolated concentrations of lead. Two other isolated areas in the east paved
surface area were identified as containing arsenic. The average concentration for all arsenic
detections in the East Parcel is 7.56 mg/kg. Further, although not identified in the soil samples, the
former use of the Project site for airplane maintenance and the manufacture of aircraft components
may have resulted in remnant subsurface soil contamination of VOCs, metals, and petroleum
hydrocarbons that could be release into the surrounding environment during demolition and
excavation activities. For example, the aircraft tie-down area, which was previously used for fuel
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-28 Airport Park Expansion Project
Final EIR – January 2018
sumping, could potentially contribute to soil contamination caused by leaking fuels which
significantly erode the asphalt in localized areas. Additionally, there is potential presence of
unknown compounds in fill or native soil associated with the Project site’s former use as a golf
course.
The Project site is covered with concrete and asphalt, thereby a direct soil exposure pathway does
not currently exist and the likelihood of the subsurface being adversely impacted by former
operations is possibly minimized due to the thickness of concrete and pavement (Parsons 2016).
However, the Project involves demolition and removal of the paved areas, as well as excavation
to a depth of approximately five feet below existing grade, which has potential to uncover
contaminated subsurface soil which may be released into the environment as a result of soil
disturbance. If contamination is uncovered during grading or excavation of the Project site, these
activities could pose health and safety risks from exposure to contaminants in the soil. Such
contamination could cause various short-term or long-term adverse health effects in exposed
persons. In addition, exposure to contaminants could occur if the contaminants migrate from areas
of identified contamination to surrounding areas during grading activities. In order to reduce
potential impacts to a less than significant level, MM HAZ-1 and MM HAZ-2 are recommended.
Offsite Contaminated Sites
Several offsite properties were identified in the immediate Project vicinity, however, all identified
sites within 0.25-mile of the Project site have been cleaned up with a “Case Closed” status and are
identified as CRECs in the Phase I ESA. Although upgradient of the Project site, all six LUSTS
within 0.25-mile of the Project site, including the one cleanup site within the Project site identified
as SMO Administration Building, have been remediated and require no further action (DTSC
2017). Former uses of the Barker Hangar included the cleaning and repairing of airplanes and
aircraft parts, which generated solvents and oil as a hazardous waste by-product that was likely
disposed of in the sewer. Evidence of the storage and use of commercially available hazardous
materials was observed at the adjacent Barkar Hangar during Phase I ESA reconnaissance (Parsons
2016). However, these materials appeared to be stored properly with no evidence of spill or other
release into the surrounding environment. Further, these materials would be properly disposed of
prior to the demolition of the structures at 3025 Airport Avenue. As a result, these stored materials
are not expected to result in a significant hazard to the public. Therefore, this potential impact
would be less than significant.
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-29
Final EIR – January 2018
Operation
Operation of the proposed park would not result in a significant hazardous materials impact as the
types and amounts of potentially hazardous materials used and stored for operation of the Project
would be limited to commercially available products and used below reportable quantities (refer
to Impact HAZ-1). Users of such materials are required to follow manufacturer instructions and
dispose of excess solutions and empty containers properly. However, as discussed above, the Phase
I and Phase II ESA identified localized areas of subsurface soil contamination. While it is likely
that this contamination would be removed in accordance with the Soils Management Plan required
under MM HAZ-2, there is the potential that subsurface contaminants may remain in subsurface
soils below the depth of excavation. Although remote, there is the potential that remaining
contaminants could migrate upward through soils in areas without impervious surface (e.g.,
pavement) and become exposed to park visitors.
Mitigation Measures
MM HAZ-1 Prior to the start of construction, the contractor shall conduct a comprehensive
survey of lead based paint (LBP) and asbestos containing materials (ACM). If such
hazardous materials are found to be present, the contractor shall follow all
applicable local, state and federal regulations, including compliance with
SCAQMD Rule 1403 as well as best management practices related to the treatment,
handling, and disposal of LBP and ACM.
MM HAZ-2 Prior to the start of excavation or grading in areas of known soils contamination,
the construction contractor shall submit a Soils Management Plan and a
Transportation Plan to the appropriate cleanup agency (e.g., Los Angeles Regional
Water Quality Control Board [LARWQCB], Department of Toxic Substances
Control [DTSC], Santa Monica Fire Department [SMFD]) for review and
approval. The Soils Management Plan and Transportation Plan shall include the
following tasks.
Soils Management Plan
Affected soils shall be either directly loaded into awaiting trucks for immediate
offsite disposal or temporarily stockpiled on plastic sheeting prior to load-out and
offsite disposal. If temporarily stockpiled, soil removed from the excavations shall
be placed next to or as close as possible to the excavation from which it came.
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-30 Airport Park Expansion Project
Final EIR – January 2018
Prior to load-out, the construction contractor shall prepare waste profiles and
example waste manifests for approval by the receiving facilities. Soil and material
segregation, stockpile handling, truck loading, and storm water management
practices shall be followed during the remedial action according to the following.
Soil and Material Segregation
Overburden soils shall be screened with an organic vapor analyzer (OVA) in
accordance with South Coast Air Quality Management District (SCAQMD)
Rule 1166. Any affected soils shall be segregated and disposed of in accordance
with federal, state, and local regulations.
Stockpile Management
Any stockpiled soils for load-out shall be segregated by waste classification:
• Nonhazardous waste.
• Volatile Organic Compound (VOC)-contaminated
nonhazardous waste with OVA readings greater than 50 parts
per million (ppm) but less than 1,000 ppm.
• VOC-contaminated nonhazardous waste with OVA readings of
1,000 ppm or greater. These soils shall be immediately sprayed
with water or suppressant and placed in a sealed container (roll-
off bin) or directly loaded into a suitable transport truck,
moistened with water, and covered with a tarp for offsite
transportation to the appropriate disposal facility, as specified
in the SCAQMD Rule 1166 Mitigation Plan.
The temporary stockpiles containing affected soils shall be managed
as follows:
• The temporary stockpiles for non-VOC contaminants shall be
placed on plastic sheeting and kept moist during working hours
and covered with plastic sheeting at the end of the day to control
dust.
• The VOC-contaminated stockpiles shall be placed on plastic
sheeting and immediately covered with plastic sheeting. The
edges of the plastic shall have an overlap of at least 24 inches.
The plastic shall be secured at the base of the stockpile and
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-31
Final EIR – January 2018
along the seams of overlapping plastic sheeting with sandbags
or equivalent means. The stockpiles shall remain covered until
load-out.
• Daily inspections of the stockpiles shall be conducted to verify
the integrity of the stockpile covers. Any gaps, tears, or other
deficiencies shall be corrected immediately. Daily records shall
be kept of stockpile inspections and any repairs made.
• If necessary, commercial vapor suppressants and sealants shall
be prepared and applied to VOC-contaminated soil in
accordance with the manufacturer’s recommendations.
• During stockpile generation and removal, only the working face
of the stockpile shall be uncovered.
Decontamination Methods and Procedures
Each piece of equipment used for the excavation of affected soils shall have a clean-
out bucket or continuous edge across the cutting face of its bucket. No excavation
of affected soil shall be permitted with equipment utilizing teeth across the cutting
edge of its bucket.
Entry to the contaminated areas (i.e., work exclusion zones) shall be limited to
avoid unnecessary exposure and related transfer of contaminants. In unavoidable
circumstances, any equipment or truck(s) that come into direct contact with
affected soil shall be decontaminated to prevent the onsite and offsite distribution
of contaminated soil. The decontamination shall be conducted within a designated
area by brushing off equipment surfaces onto plastic sheeting. Trucks shall be
visually inspected before leaving the site, and any dirt adhering to the exterior
surfaces shall be brushed off and collected on plastic sheeting. The storage bins or
beds of the trucks shall be inspected to ensure the loads are properly covered and
secured. Excavation equipment surfaces shall also be brushed off prior to removing
the equipment from contaminated areas.
Movement of affected soils from the excavation area to temporary stockpiles shall
be conducted using enclosed transfer trucks, if possible. If affected soils must be
moved within an open receptacle (e.g., loader bucket), the travel path for the loader
shall be scraped following this activity, with scraped soils placed in the temporary
stockpile for load-out.
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-32 Airport Park Expansion Project
Final EIR – January 2018
Sampling equipment that comes into direct contact with potentially contaminated
soil or water shall be decontaminated to assure the quality of samples collected
and/or to avoid cross-contamination. Disposable sampling equipment intended for
one-time use shall not be decontaminated, but shall be packaged for appropriate
offsite disposal. Decontamination shall occur prior to and after each designated
use of a piece of sampling equipment, using the following procedures:
• Nonphosphate detergent and tap-water wash, using a brush if
necessary.
• Tap-water rinse.
• Initial deionized/distilled water rinse.
• Final deionized/distilled water rinse.
Truck Loading
Trucks may be loaded directly from the excavation or temporary stockpile based
on truck availability and excavation logistics. Trucks shall be routed and stockpile
areas shall be located so as to avoid having trucks pass through impacted areas.
The truckloads shall be wetted and tarped prior to exiting the site. All soil hauled
from the site shall comply with the following:
• Materials shall be transported to a Class II landfill in
accordance with applicable rules and regulations for the
handling and disposal of hazardous materials. If contamination
in the soils is at or above regulatory levels, the Department of
Toxic Substances Control (DTSC) shall be contacted and
notified to determine appropriate action.
• No excavated material shall extend above the sides or rear of
the truck/trailer.
• Trucks/trailers carrying affected soils shall be completely
tarped/covered to prevent particulate emissions to the
atmosphere. Prior to covering/tarping, the surface of the loaded
soil shall be moistened.
• The exterior of the trucks/trailers shall be cleaned off prior to
leaving the site to eliminate tracking of material offsite.
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-33
Final EIR – January 2018
Storm Water Management
The good housekeeping practices prescribed in the City’s Urban Runoff Mitigation
Plan (Municipal Code Section 7.10.060) shall be implemented during soil
excavation activities to contain and control storm water runoff that might convey
contaminated or excessive sediments. If rainfall is expected, the areas around open
excavations shall be graded and bermed to prevent storm water from flowing into
the excavation. Any standing water that collects in the bottom of the excavations
shall be removed and handled in accordance with federal, state, and local
regulations. The water shall be sampled and analyzed either as standing water in
the excavation or following containment in a temporary above-ground storage
tank. Depending on the volume of water and the sampling results, options for
handling the standing water could include:
• Pumping the standing water into temporary above-ground
storage tanks for reuse onsite for dust suppression.
• Pumping the standing water through filters and a carbon
adsorption filter (if required based on analytical results) prior
to discharge to a storm drain, subject to approval by the City of
Santa Monica Water Resources Protection Programs Division.
• Pumping the standing water into vacuum trucks for transport
and disposal at a recycling facility.
Transportation Plan
All affected soils shall be transported offsite for lawful management and disposal.
Prior to load-out, the construction contractor shall prepare waste profiles for the
receiving facility using analytical data from the previous environmental site
assessment.
On-Site Soils Remediation Plan
If remediation for contaminated soils remaining on site is required, all remediation
activities shall be accomplished in a manner that reduces risk to below applicable
standards and shall be completed prior to opening the park to the public. Closure
report or other reports regarding investigation and/or remediation activities
regarding contaminated soil shall be submitted to DTSC for review and approval.
Approved reports that document the successful completion of required remediation
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-34 Airport Park Expansion Project
Final EIR – January 2018
activities for contaminated soils shall be submitted to the DTSC prior to opening
the park to the public.
Residual Impacts
Implementation of the above-mentioned mitigation measures and standard regulatory measures
would reduce impacts related to hazards and hazardous materials to less than significant.
Would the Project would emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within one-quarter mile of an existing or proposed school?
HAZ-3 Short-term construction activities and operation of the Project could
potentially emit hazardous emissions or handle hazardous materials,
substances, or waste within one-quarter mile of a school. However, compliance
with local, state, and federal regulations and implementation of mitigation
would reduce impacts to less than significant.
Impact Description (HAZ-3)
As discussed above, the Santa Monica College Bundy Campus is located approximately 0.05-mile
south of the Project site. There are multiple RECs that could pose a hazard to this campus, and
potentially other nearby schools through accidental release of hazardous materials into the
environment during the demolition of existing structures that may contain ACMs or LBP or
through the grading and excavation of contaminated soils (refer to Impact HAZ-2). Project
construction activities may also cause short-term hazardous emissions related to the operation of
construction equipment and truck trips for hauling excavated soil away from the Project site.
However, demolition of the existing structures and other construction related activities would
adhere to regulatory standards and the above-identified mitigation measures to avoid release of
contaminants, such as ACMs or LBP, or contaminated soils, if present. In order to reduce potential
impacts to a less than significant level, MM HAZ-1 and MM HAZ-2 are required.
The Project would expand an existing park with associated recreational amenities, which would
not involve hazardous emissions or handling of abnormal or high quantities of hazardous materials.
Throughout Project operation, commercially available (limited) quantities of cleaning supplies,
detergents, and pesticides would be used for the maintenance of public restrooms, landscaping,
and other recreational amenities. Accordingly, there would be no potentially significant adverse
impact to nearby schools during Project operation.
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-35
Final EIR – January 2018
Mitigation Measures
Implementation of MM HAZ-1 and MM HAZ-2.
Residual Impacts
Implementation of the above-mentioned mitigation measures and standard regulatory measures
would reduce impacts related to hazards and hazardous materials to less than significant.
For a Project located within an airport land use plan or, where such a plan has not been adopted,
within 2 miles of a public airport or public use airport, would the Project result in a safety hazard
for people residing or working in the Project site?
HAZ-4 The Project is located within the SMO AIA and could potentially result in an
increased risk of safety hazard for people recreating or working at the Project
site. However, compliance with federal, state, and County regulations
regarding the construction of structures within navigable air space would
ensure that this impact would be less than significant.
Impact Description (HAZ-4)
The Project site is located within the SMO AIA and is subject to the regulations and standards
established in the Los Angeles County ALUC ACLUP, which are provided to avoid flight hazards
and minimize the number of people in the vicinity of the airport that are exposed to the risks
associated with potential aircraft accidents. Airport safety is primarily related to the potential for
accidents related to aircraft operations such as emergency landings or in rare cases - crashes, as
well as ensuring that land use development is carried out in manner that minimizes or avoids risks
associated with such aircraft incidents or accidents. As discussed above, FAA, Caltrans, and
ALUC standards seek to minimize or avoid risks to such land uses (e.g., parks, residential
neighborhoods) by requiring areas around the ends of runways to be free of objects or sensitive
land uses, limiting the height of new structures in the surrounding airspace, and understanding
historical accident patterns. Until SMO’s impending closure in 2028, the Project site’s proximity
to the SMO runway could present a potential airport-related safety issue for future park visitors in
the rare event of an aircraft emergency incident.
Regarding historical accident patterns, as discussed above, in the last 25 years, most of the
incidents reported at SMO occurred on or just off either end of the runway centerline, with
exception of seven crashes that occurred in residential areas (including gold courses) within two
miles of SMO and one jet that veered off the runway and into an adjacent hangar during landing.
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-36 Airport Park Expansion Project
Final EIR – January 2018
In this regard, data shows that in the last 25 years, no accidents have occurred adjacent to runway
or in the immediate vicinity of Airport Park. This is consistent with broader data on airport hazards.
For instance, according to the California Airport Land Use Planning Handbook Accident Study,
68 percent of aviation accidents occur over or within an airport, and accident sites tend to occur
fairly close to the extended runway centerline (Johnson Aviation 2014). The existing SMO Airport
Administration Building and hangars also serve as a physical barrier between the park and the
runway for out-of-control aircraft on the runway.
The Project site is outside of the general approach areas of the runway. Therefore, no resultant
substantial physical airport-related safety hazards would occur as result of Project implementation.
At SMO, there is an RPZ that encompasses an area of 150 feet on either side of the runway center
line. The northern boundary of the Project site is outside of this RPZ, and no structures, recreational
amenities, or sports fields associated with the Project fall within this RPZ. The Project is also
subject to policies regarding airport safety and development restrictions in RPZs. The Project
would not increase the number of structures within the flight path or RPZs. As discussed above,
portions of the Project site are located within the Sideline Safety Zone (Zone 5) based on the
current length of Runway 3/21. According to the Handbook, stadiums and group recreational uses
are generally prohibited within Zone 5. However, the Project has been designed to place non-
recreational features such as the parking lot, restrooms, and acoustical berm closest to the runway.
The Project’s proposed recreational uses such as the two sports fields would be located outside of
Zone 5, which extends 500 feet from the runway edge for a Medium General Aviation Runway.
Following completion of the Runway Shortening Project, SMO Runway 3/21 would be considered
a Short General Aviation Runway per the guidelines of the Handbook, and it is expected that all
safety zones would be reduced in size to match the Handbook’s guidelines for a Short General
Aviation Airport. For a Short General Aviation Airport, Zone 5 generally extends 250 feet from
the edge of the runway, under which no portion of the Project site would be located within the
runway’s Sideline Safety Zone. In addition, the Project would require a FAA Part 77 Clearance
Permit to be submitted and approved by the FAA to ensure airport land use compatibility; to avoid
new development that may cause airspace obstructions; and to reduce safety risks associated with
airport hazards and accidents. The worst-case scenarios for airport safety hazards would likely be
a busy weekend day when the park hosts sports events (large gatherings); and when SMO sees the
most recreational/training flying activity (most risky). Because of the Project’s proximity to SMO
but outside of the flight path, the potential for aircraft accidents to occur at the park that would
cause a safety hazard for people recreating or working within the Project site is considered remote.
SMO airport operations are from 7:00 A.M. to 9:00 P.M. Although arrivals are permitted 24 hours
a day, pilots are requested to avoid all operations between 11:00 P.M. and 7:00 A.M. Monday
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-37
Final EIR – January 2018
through Friday, or until 8 A.M. on weekends. Overlaps between night flying and park night lighting
may occur to a limited degree. However, the Project would generate minimal nighttime lighting
sufficient to ensure safety of both park visitors and overhead airspace traffic. Additionally, SMO
operations are planned to cease by 2028, therefore, any potential impacts resulting in increased
risk of safety hazards for people working or recreating in the Project vicinity would be limited to
a timespan of 11 years. Compliance with federal, state, and County standards and regulations on
the placement of structures and the operation of lighting within proximity of an airport would
ensure that potential impacts related to increased risk of safety hazards to less than significant.
Would the Project impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan?
HAZ-5 Construction of the Project would temporarily restrict access to Donald
Douglas Loop South. With implementation of a Construction Management
Plan to maintain access, impacts would be less than significant.
Impact Description (HAZ-5)
The City of Los Angeles General Plan identifies Bundy Drive/Centinela Avenue as a Selected
Disaster Route. The Project does not propose any changes to the alignment or roadway
configuration of Bundy Drive, nor does it propose any improvements to the intersection of Bundy
Drive and Airport Avenue. As discussed in Section 3.7, Transportation and Traffic, the Project
would not result in a significant increase in traffic at the intersection of Bundy Drive and Airport
Avenue. As a result, Project impacts to Selected Disaster Routes would be less than significant.
Airport Avenue and Donald Douglas Loop South serve as the primary access route to the south
side of SMO and the SMO Administration Building. The Project would relocate the southern
terminus of Donald Douglas Loop from its current location to the west side of the Project site.
While the realigned roadway segment is intended to prevent bifurcation of the park and promote
more efficient access to the SMO Administration Building, the relocation would temporarily
reduce the traffic capacity of the roadway and may restrict the movement of emergency vehicles.
To reduce the potential for these impacts to occur, construction activities would be phased to
maintain access from Airport Avenue to SMO at all times during construction. As discussed in
Section 3.7, Transportation and Traffic, a Construction Impact Mitigation Plan would be
implemented during Project construction. Among other things, this plan would identify staging
mechanisms to maintain access, procedures to accommodate emergency vehicle access, and
notification procedures for the SMFD and Santa Monica Police Department (SMPD). Further, the
Construction Impact Mitigation Plan would be subject to review and approval by the City Public
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-38 Airport Park Expansion Project
Final EIR – January 2018
Works Department, SMFD, and the SMPD. Emergency vehicles would continue to have
uninterrupted access to the Airport Administration Building and SMO from Donald Douglas Loop
North. With construction phased to maintain access and implementation of the Construction
Impact Mitigation Plan, construction impacts to emergency response to SMO and the
Administration Building would be less than significant.
Regarding operation, the realigned Donald Douglas South Loop would de designed in accordance
with City standards to provide adequate emergency access. Turnarounds would be provided at two
locations to accommodate the movement of emergency vehicles. One turnaround would be located
north of the multi-use area, the other would be located north of the east sports field. The realigned
Donald Douglas Loop South would have a minimum width of 24 feet at its intersection with
Donald Douglas Loop and a minimum design turning radius of 27 feet to accommodate the City’s
fleet of emergency vehicles. Therefore, operational impacts with adopted emergency response or
emergency evacuation plans would be less than significant.
Cumulative Impacts
The cumulative projects setting of the Project is described in Section 3.0 Cumulative Impacts and
a list of pending, approved, and recently constructed projects in the City that would contribute to
cumulative impacts can be found in Table 3.0-1. The potential for hazards and hazardous materials
impacts to result in cumulative impacts decreases with distance from the source of the contaminant
to the receptor, and between projects. There are two projects located in the immediate Project
vicinity that may result in a change in hazards associated with the Project site: The Airport Avenue
Improvement Project and the Airport Runway Shortening Project. Although not a “project” at this
time, it is anticipated that the closure of SMO will cumulatively result in decreased hazardous
effects related to airport hazards.
Would the Project create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials?
Cumulative development within the Project vicinity would have the potential to expose area
residents, employees, and visitors to hazardous materials through redevelopment of sites and
structures that may be contaminated from either historic or ongoing uses. During construction and
operation, future projects in the vicinity (including the three identified nearby projects) are
expected to transport, use, and store hazardous materials according to established federal, state,
and local regulations. Therefore, the Project would result in a less than significant cumulative
impact.
3.4 HAZARDS AND HAZARDOUS MATERIALS
Airport Park Expansion Project 3.4-39
Final EIR – January 2018
Would the Project 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?
Would the Project would emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within one-quarter mile of an existing or proposed school?
As with the Project, construction and operation of future projects in the vicinity could potentially
create a hazard to the public or the environment through reasonably foreseeable upset and
accidental conditions involving the release of hazardous materials into the environment associated
with past uses of the site and demolition of existing buildings. However, future projects would also
be required to comply with all applicable regulations to minimize the potential for accidental
release and emissions of hazardous materials into the environment. Therefore, the Project would
result in a less than significant cumulative impact.
For a Project located within an airport land use plan or, where such a plan has not been adopted,
within 2 miles of a public airport or public use airport, would the Project result in a safety hazard
for people residing or working in the Project site?
The Airport Avenue Improvement Project would make improvements to the existing right-of-way
and would not have the potential to increase airport hazards. Additionally, under the City’s
February 2017 consent decree with FAA, the City will: a) shorten the runway from feet in length
to 3,500 feet by December 7, 2017 and b) cease flight operations at SMO by December 31, 2028.
Since these projects are intended to reduce the number of flight operations at SMO, they would
also reduce flight hazards at Airport Park. Further, all objects, structures, and lighting at the park
would be designed and constructed in accordance with applicable regulations, including those of
the FAA, the Project would result in a less than significant cumulative impact with regard to airport
safety hazards.
Would the Project impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan?
The Airport Avenue Improvement Project has the potential to result in temporary construction-
related impacts to emergency access along Airport Avenue and Donald Douglas Loop South.
Although still in the preliminary design phase, the construction of this related project is tentatively
scheduled to overlap with construction of the Project to provide uniform improvements and
minimize the duration of construction impacts along Airport Avenue. Per standard City
requirements, both the Project and Airport Avenue Improvement Project would implement a
3.4 HAZARDS AND HAZARDOUS MATERIALS
3.4-40 Airport Park Expansion Project
Final EIR – January 2018
temporary traffic control plan to maintain general traffic flow and emergency vehicle access on
Airport Avenue. With the implementation of temporary traffic control plans, construction impacts
on emergency access would be less than significant. The construction of the Airport Runway
Shortening Project and the future closure of SMO would not overlap with the Project – and
therefore, no cumulative effects on emergency access would occur with these projects.
3.5 LAND USE AND PLANNING
This section evaluates the Airport Park Expansion Project’s (Project) consistency with adopted
goals, programs, and policies in the City of Santa Monica (City) General Plan, as well as federal,
state, and regional plans, and related planning policy documents. Sources utilized in the
development of this section include the City’s 2010 Land Use and Circulation Element (LUCE),
the City of Santa Monica Municipal Code (SMMC), applicable Federal Aviation Administration
(FAA) regulations, the Los Angeles County (County) Airport Land Use Commission (ALUC)
Comprehensive Land Use Plan (CLUP), and the February 2017 Consent Decree between the City
and the FAA (2017 Consent Decree). A discussion of compatibility with surrounding land uses,
such as residential and public lands, is also included in this section. This section focuses on land
use issues; for Airport-related hazards, please refer to Section 3.4, Hazards and Hazardous
Materials.
3.5.1 Environmental Setting
City of Santa Monica
The City is an urbanized incorporated
community located in west Los Angeles
County, approximately 15 miles west of
downtown Los Angeles. The City is
bounded on the north, south, and east by the
City of Los Angeles and on the west by the
Pacific Ocean. Surrounding communities
within the City of Los Angeles include
Pacific Palisades to the north, Brentwood
and West Los Angeles to the east, and Mar
Vista and Venice to the south. Santa
Monica is directly accessible via the
Interstate-10 freeway (I-10, Santa Monica
Freeway) and Interstate-405 (I-405). The I-10 freeway terminates at its western end at Pacific
Coast Highway (PCH) within the City, which links the City to Malibu and the Santa Monica
Mountains to the north.
The City occupies approximately 8.25 square miles, almost all of which is developed with
established residential, commercial, light industrial, and institutional uses. The City has a strong
recreational identity, tied to the availability of year-round activities (City of Santa Monica 1997).
The Project site (pictured above) is located within Santa
Monica Airport (SMO) property at the southeastern limits of
the City, approximately 2.25 miles southeast of Downtown
Santa Monica.
Project Site
Airport Park Expansion Project 3.5-1
Final EIR – January 2018
3.5 LAND USE AND PLANNING
The City’s recreation infrastructure includes 29 parks, spanning more than 130 acres, which are
primarily maintained by the Department of Public Works and include sports fields (natural and
synthetic turf), tennis courts, basketball courts, playgrounds, skate parks, exercise equipment, sand
volleyball courts, and off-leash dog areas (City of Santa Monica 2017). The beach is Santa
Monica’s most popular recreational attraction, allowing opportunities for walking, bicycling,
skating, exercising, surfing, and swimming. Many amenities enhance the beach area, such as the
addition of grassy lawns, picnic areas, children’s playgrounds, and sitting and viewing areas. The
City’s Parks and Recreation Master Plan outlines strategies to enhance the theme of the “City as a
Park” by improving pedestrian access, linking linear recreation opportunities and increasing social
interaction by creating enjoyable spaces along the streets. Throughout the City, recreational
opportunities also include school campuses, which offer the public opportunities to use swimming
pools, basketball courts, playing fields, and gymnasiums outside of school hours. Pathways and
pedestrian amenities along City streets play an important role in connecting various recreational
facilities and offering recreational users the ability to use the City itself for recreation, including
walking, jogging, and bicycling.
The City is organized around a grid system of streets providing a high level of connectivity within
the City and to adjacent communities. This grid street system is interrupted by the I-10 freeway
that bisects the City from east to west, dividing neighborhoods and districts north and south of the
freeway. The grid system is also bisected by Santa Monica Municipal Airport (SMO), which acts
as a barrier to north-south movement through the southeast portion of the city.
Residential neighborhoods are the predominant land use in the City, with a wide range of housing
types and densities. Commercial land uses include retail, restaurant, entertainment, office, and
service commercial (e.g., salons), which are concentrated within the Downtown and along
boulevards and avenues, such as Broadway, Wilshire Boulevard, Santa Monica Boulevard,
Lincoln Boulevard and Colorado Avenue, as well as Pico Boulevard, and Ocean Park Boulevard
adjacent to the Project site. Ocean Park Boulevard is the City’s southernmost boulevard and
extends from the eastern City limit at South Bundy Drive/Centinela Avenue to Neilson Way in the
Ocean Park neighborhood.
The Project site lies within the Santa Monica Airport and Business Park District as defined by the
LUCE, which is located adjacent to the south side of Ocean Park Boulevard, immediately east of
Clover Park. This district occupies contiguous parcels in the southeast corner of the City and is
bound by Ocean Park Boulevard on the north, educational uses and single-family neighborhoods
in the City of Los Angeles to the south, Clover Park and the Sunset Park neighborhood to the west,
and South Bundy Drive/Centinela Avenue and single family residential areas in the City of Los
3.5-2 Airport Park Expansion Project
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Angeles on the east. In addition to accommodating SMO, the district includes the Santa Monica
Business Park, a traditional self-contained office park with limited interface with the adjacent
streetscape on Ocean Park Boulevard (to the north of SMO). The LUCE recommends a specific
plan process for the district to identify the best use, configuration, and relationship with the
residential neighborhoods that surround this area (City of Santa Monica 2015).
Project Vicinity
The Project site is located within SMO property at the southeastern limits of the City,
approximately 2.25 miles southeast of Downtown Santa Monica, approximately 2.5 miles east of
the Pacific Ocean, approximately 0.75 miles south of the I-10 Freeway, and approximately
1.0 mile west of the I-405 Freeway (Figure 2-1). Land uses directly north of the Project site across
Donald Douglas Loop South include the Airport Administration Building, airplane hangars,
taxiways, airplane tie-down areas, and Runway 3/21. Directly west and south of the Project site
Land uses in the immediate project vicinity include museum and cultural uses, such as the Museum of Flying
(pictured upper left), and commercial and restaurant uses, such as the Spitfire Grill (pictured upper right), both
located south of Airport Avenue. Single-family homes are located across South Bundy Avenue across from the
Project site (pictured lower left). Barker Hangar, an event venue occupying a former airplane hangar, is located
directly west of the Project site (pictured lower right).
Airport Park Expansion Project 3.5-3
Final EIR – January 2018
3.5 LAND USE AND PLANNING
are non-aviation uses on SMO property. These non-aviation areas include the existing Airport Park
(which is part of the Project site), various commercial and cultural uses, such as the Spitfire Grill,
the Museum of Flying, Santa Monica Art Studios, the Barker Hangar, and several parking lots
(Table 3.5-1, Figure 2-2). Barker Hangar is an event venue within an approximately 35,000 square-
foot (sf) former airplane hangar that has been used as an event venue since 1969 (Figure 2-2).
Barker Hangar operates under a Master Lease with the City.
Table 3.5-1. Non-Aviation Uses on SMO Property in the Immediate Project Vicinity
Address Land Use
South of Airport Avenue
3050 Airport Ave Two-story former airplane hangar housing the Santa Monica Art Studio.
3050 Airport Ave SMO Parking Lot # 5, which primarily serves the Santa Monica Airport Outdoor
Antique & Collectable Market on the 1st and 4th Sunday of every month.
3100 Airport Ave Two-story building housing the Douglas DC-3 Monument and The Museum of Flying.
3200 Airport Ave One-story building containing office uses, art studios, the Ruskin Theater Group, and
the Airport Avenue Demonstration Garden.
3200-3300 Airport Ave SMO Parking Lot #4
3300 Airport Ave Two-story building with office uses above The Spitfire Grill.
3400 Airport Ave One-story office building.
3400 Airport Ave SMO Parking Lot #3
North of Airport Avenue
3013 Airport Ave SMO Parking Lot #7
3021 Airport Ave Existing Airport Park and Parking Lots
3021 Airport Ave Barker Hangar
3221 Donald Douglas
Loop South Typhoon Restaurant
3223 Donald Douglas
Loop South Airport Administration Building & Police Sub Station
Surface parking lots and aviation-related land uses are located to the west of Barker Hangar
(Figure 2-2). Further south of the non-aviation uses on SMO property and within the City of Los
Angeles, land uses include the Santa Monica College Bundy Campus and single-family residential
neighborhoods (Figure 2-2). Low density housing including single-family homes are also located
east of the Project site across South Bundy Drive in the City of Los Angeles (Figure 2-2). The
Project site is located 0.5-mile north of the Venice Reservoir site.
In a broader context, the SMO property on which the Project site is situated is located at the
southeast corner of the Santa Monica city limits, bordering and slightly overlapping with the City
3.5-4 Airport Park Expansion Project
Final EIR – January 2018
3.5 LAND USE AND PLANNING
of Los Angeles city limits. Land uses surrounding the southeast portion of SMO property
predominantly consist of residential neighborhoods, but also include park, recreation, and cultural
facilities, commercial/office uses, restaurants, event venues/cultural uses, and educational
facilities. SMO is bordered on the north by Donald Douglas Loop North, Clover Park, the Santa
Monica Business Park (an approximately one-million-sf office and retail business park), and the
residential communities of Sunset Park; on the south by Airport Avenue, Santa Monica College
Bundy Campus, and the Mar Vista residential neighborhood; on the west by 23rd Street; and on
the east by South Bundy Drive. (Figure 3.5-1).
SMO supports a single runway oriented
east-west (Runway 3/21). SMO has no
scheduled airline service. Aviation-related
commercial uses are located to the north of
the runway and include flying schools,
parking facilities, and fixed-based operator1
(FBO) maintenance and fueling operations.
Aviation-related uses are also located south
of the runway, particularly on the western
portion of SMO property, however, the
eastern portion of SMO property (both north
and south of Airport Avenue) supports the
existing Airport Park and the non-aviation
uses discussed above.
Existing Street Network in the Project Vicinity
Primary vehicle access to the Project site is via Airport Avenue, which in turn is accessed by South
Bundy Drive to the northeast. Airport Avenue is a two-lane, northeast-southwest-oriented local
collector road with 6-foot wide pedestrian sidewalks on either side east of Donald Douglas Loop
South, and serves as the primary access road to the Project site and other commercial developments
located between South Bundy Drive and Walgrove Avenue. South Bundy Drive is a four-lane,
north-south local arterial with 6-foot wide pedestrian sidewalks on either side, and serves as a key
arterial connection for vehicles traveling from the I-10 to the Project site and SMO uses south of the
1 A fixed-base operator (FBO) is an organization granted the right by an airport to operate at the airport and provide
aeronautical services such as fueling, hangaring, tie-down and parking, aircraft rental, aircraft maintenance, flight
instruction, and similar services.
Commercial airport operations are generally located north
of the Project site and Runway 3/21. These commercial
operations include several FBOs which provide valuable
aircraft operator and maintenance services.
Airport Park Expansion Project 3.5-5
Final EIR – January 2018
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LEGEND SANTA MONICA LUCE LAND USE DESIGNATIONSanta Monica Airport Existing Santa Monica Airport Park Project Site LUCE Airport and Business Park District City Boundary School Fire Station Fairview Branch Library Low Density Housing Medium Density Housing Single Family Housing Institutional/Public Lands Neighborhood Commercial Office Campus Parks and Open Space LOS ANGELES GENERAL PLAN LAND USE DESIGNATION General Commercial Neighborhood Commercial Limited Manufacturing Open Space Public Facilities Low Residential Low-Medium Residential Medium ResidentialFL
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3.5-1 FIGURE
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3.5-6
3.5 LAND USE AND PLANNING
runway.2 South Bundy Drive sits at a higher elevation than SMO and fronts the Project site for
approximately 550 feet. The Project site is partially screened from South Bundy Drive by a chain-
link fence and intermittent trees and vegetation; these features also prohibit pedestrian access to the
existing Airport Park from South Bundy Drive.
Donald Douglas Loop South is a two-lane local road without sidewalks that provides 8-foot wide
sidewalks and internal access through the Project site and to adjacent SMO uses (i.e., Airport
Administration Building). The roadway begins perpendicular to Airport Avenue, and continues just
past the Airport Administration Building, where a security gate restricts public access. Donald
Douglas Loop South continues around the runway, where it connects with Donald Douglas Loop
North, which provides access to commercial uses (e.g., Santa Monica Business Park) and the aviation
uses north of the runway. Refer to Section 3.7, Transportation and Traffic for more detailed
discussion of transportation movements and road features within the Project vicinity.
2 South Bundy Drive is named South Centinela Avenue south of Airport Avenue.
The existing Santa Monica Airport Park features several recreational amenities serving local residents, providing
for and attracting a broad range of park users engaging in many varying levels of activity. Such amenities include
open space and lawn areas, an off-leash dog park, children’s playgrounds, regulation size sports fields, and picnic
facilities.
Airport Park Expansion Project 3.5-7
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Project Site
Existing Land Uses
The approximately 15.8-acre Project site comprises all or a portion of three parcels (Assessor’s
Parcel Numbers [APN] 4272-026-902, 4272-027-901, and 4272-027-270) at the southeast corner of
SMO property. Historically, the Project site was utilized for aviation uses. However, under a 1984
Settlement Agreement between the City and the Federal Aviation Administration (which expired
in 2015), these aviation uses were relocated to the north of the runway (City of Santa Monica
1984). The Project site encompasses a 2.2-acre portion of the existing 8.3-acre Airport Park and
the adjacent 12-acre of land to the west and east (Figure 3.5-1).
The existing Airport Park opened to the public in 2003. The park is located at the southeast corner
of the Project site. At approximately 8.3 acres in size, the existing park provides an off-leash dog
park, playground, a Fédération Internationale de Football Association (FIFA)-regulation sized
synthetic turf sports field, a picnic area with 17 tables and 6 barbeque grills, a 0.6-mile walking
loop, and two parking lots. The remaining 12-acre portion of the Project site is improved with two
large, paved surface areas (i.e., the west and the east paved surface area). The west paved surface
area includes the aviation-related land uses of 3025 Airport Avenue (i.e., small administration
office buildings and airplane hangars, 48 aircraft tie-downs, aircraft storage, and the Proteus Air
Service flight school; and Donald Douglas Loop South (Table 3.5-2). The east paved surface area
previously supported approximately 78 airplane tie-down spaces, which were removed in June
2017. Currently, the east paved surface area remains vacant, with public access for unprogrammed
recreational use, including roller-blading and bicycle training for families.
Summary of Existing City Land Use Designation and Zoning
SMO operates within a complex framework of federal, state and local laws and regulations.
As described in Section 2.2.3 Land Use Designations, the LUCE designates the entirety of SMO,
including non-aviation uses south of the runway, as within the Airport and Business Park District,
with a land use designation of Institutional/Public Lands on the LUCE Land Use Designation Map
(Table 3.5-2, Figure 3.5-1). The Land Use Designation Map also identifies SMO as “Airport”.
3.5-8 Airport Park Expansion Project
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Table 3.5-2. Project Site Land Use Setting
Project Site Parcel(s) Jurisdiction Existing Onsite
Development
LUCE LU
Designation Zoning
Surface
Parking Lots,
Flight
Schools, and
Airport
Operations
4727-026-902 City of Santa
Monica
West Paved Surface
Area, 3025 Airport
Ave, Existing Airport
Park, Non-Aviation
Uses on SMO
Property South of
Airport Avenue
Institutional/Publ
ic Land OS/Airport*
4272-027-901 City of Santa
Monica
East Paved Surface
Area, Donald Douglas
Loop South, Existing
Airport Park
Institutional/Publ
ic Land OS/Airport*
4272-027-270 City of Los
Angeles
East Paved Surface
Area, Donald Douglas
Loop South
Low Residential R1-1
* Although not an official zoning designation, the LUCE Land Use Designation Map labels SMO as “Airport”.
The SMO property lies within the jurisdictional boundaries of the City of Santa Monica, with a
small eastern end (including a small portion of the Project site’s east paved surface area) located
within the City of Los Angeles boundaries.
Within the City of Santa Monica, the SMO property (including the Project sites’ west paved
surface area and most of the east paved surface area) does not have an existing zoning designation
- with the exception of Airport Park. The existing Airport Park is designated with the Park and
Open Space (OS) zoning designation consistent with the SMMC, although no official zoning
designation is applied to the remainder of SMO property. Due to its proximity to SMO Runway
3/21, the Project site falls within the Airport Influence Area (AIA) for SMO, as designated in the
2003 AIA Map for SMO prepared by the ALUC, however, the entirety of the Project site is located
outside of all runway protection zones (RPZ) designated for SMO by the 2003 AIA Map for SMO
by the ALUC (Figure 3.5-2).
The eastern end of SMO and a portion of the Project site’s east paved surface area (Parcel APN
4272-027-270) are within the jurisdictional boundaries of the City of Los Angeles and zoned R1-1
(One-Family Zone, Height District 1) by the Los Angeles Municipal Code. These parcels have
been owned in fee by the City (i.e. deeded to the City) since it assumed operation of SMO in 1926.
Los Angeles’ One-Family Zone permits the development of parks, playgrounds, owned and
operated by a governmental agency.3
3 The principle of intergovernmental immunity applies to the portion of the Project site located in the boundaries of
City of Los Angeles - as explained in Lawler v. City of Redding (1992) 7 Cal.App.4th 778, 783, this principle
means that Santa Monica need not comply with LA’s general plan or zoning and building codes.
Airport Park Expansion Project 3.5-9
Final EIR – January 2018
DONALD
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4272-027-2704272-027-270
4272-026-902
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AIRPORT
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AIRPORT
4272-027-2704272-027-270
4272-026-902
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4272-027-270
LEGEND
###
Existing Santa Monica
Airport Park
Project Site
Assessor’s Parcel Boundary
and Number
City Boundary
ZONING DESIGNATION
Note: Although not an official zoning designation,
the LUCE Land Use Designation Map
labels SMO as “Airport” and operates
within a complex framework of federal,
state and local laws and regulations.
SMMC Chapter 9.51.030.D.1, Airports and Heliports,
defines an airport as a “[facility] for the takeoff and
landing of airplanes and helicopters, including
runways, helipads, aircraft storage buildings, public
terminal buildings and parking, air freight terminals,
baggage handling facilities, aircraft hangar and
public transportation and related facilities, including
bus operations, servicing and storage. This
classification also includes support activities…
and other equipment and structures required by
the United States Government and/or the State
for the safety of aircraft operations.”
Airport
Open Space
One-Family Zone
AIRPORT
OS
R1-1
Note: Zoning change is in Santa Monica only;
no change in zoning in Los Angeles.
0 300
SCALE IN FEET
Existing and Proposed Zoning
Proposed Zoning
Existing Zoning
3.5-2FIGURE
N
3.5-10
3.5 LAND USE AND PLANNING
3.5.2 Regulatory Framework
This section summarizes relevant adopted federal, state, regional, and local land use plans,
regulations, and development standards that guide development on the Project site.
Federal
Federal Aviation Administration (FAA), Federal Aviation Regulation, Part 77 Objects Affecting
Navigable Airspace
To maintain the operational safety of airports, Code of Federal Regulation (CFR) Title 14 Part 77
(FAA Part 77) establishes standards for determining if obstruction would cause substantial adverse
effect on air navigation. This includes the establishment of a Runway Protection Zone (RPZ)
(formerly called Clear Zones), which is an area at ground level that provides for the unobstructed
passage of landing aircraft through the above airspace. The RPZ begins at the end of the runway
and is sized base on the operational variables of each airport. The RPZ is the most critical safety
area under the approach path and should be kept free of all obstructions. No structures or the
congregation of people are typically allowed within a RPZ, however, single-family homes that
were built prior to the establishment of RPZs are within the RPZs at both ends of SMO’s runway.
FAA Part 77 also establishes standards and notification requirements for objects affecting
navigable airspace, such as new structures or lighting standards. This notification serves as the
basis for evaluating the effect of the construction or alteration on operating procedures;
determining the potential hazardous effect of the proposed construction on air navigation;
identifying mitigating measures to enhance safe air navigation; and charting of new objects.
Notification also allows the FAA to identify potential aeronautical hazards in advance to prevent
or minimize the adverse impacts to the safe and efficient use of navigable airspace.
A Notice of Proposed Construction or Alteration (Form 7460-1) would be required to be submitted
to the FAA due to the Project’s proposal to introduce new structures (e.g., recreational amenities,
concession/restroom buildings, light standards, fencing) in close proximity to Runway 3/21. As
part of FAA grant assurances, if an airport sponsor receives federal funds for an airport, it is
required that use of land adjacent to or in the immediate vicinity of the airport be restricted to
activities and purposes compatible with normal airport operations.
1984 Santa Monica Airport Settlement Agreement (1984 Settlement Agreement)
In 1984, the City and the FAA signed an agreement that allowed the City to use airport land, which
was not required for airport operation, for non-aviation purposes. The 1984 Settlement Agreement
provides the primary regulatory framework between the two government agencies for allowable
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airport land uses. The 1984 Settlement Agreement states that it resolved all legal disputes that
existed between the City and federal government in 1984, and allowed the City to make substantial
changes in the operation of SMO. For instance, the 1984 Settlement Agreement approved a new
Airport Layout Plan that shifted a substantial portion of the aviation services from the south side
of the Airport to the north side, where the businesses would be further from residences. This
reconfiguration made available a substantial amount of land on the south side designated in the
new Airport Layout Plan as “parkland and residual land”, including the entirety of the Project site.
Thus, the land was released from exclusive aviation use and identified for non-aviation uses. The
1984 Settlement Agreement expired in 2015, and thus, no longer remains applicable.
2017 Consent Decree to Cease Operations at SMO (2017 Consent Decree)
Regaining local control of land use at SMO and reducing the health and safety impacts on adjacent
residents have been long-standing goals of the City. Beginning with the 1984 Settlement
Agreement, the City started the process of reducing the amount of SMO property dedicated to
aviation uses.
On January 28, 2017, the City reached a settlement agreement/consent decree with the FAA that
determines the operating environment for SMO until December 31, 2028, when the City will be
able to legally close the airport. During this time, the City is permitted to establish an exclusive
fixed base aeronautical service provision upon completion of runway construction work, and if
City doesn’t, provide private tenants ability to establish FBO for terms of no less than three years.
The 2017 Consent Decree also requires the City to operate a runway of 3,500 feet at SMO until
the airport is closed. On February 1, 2017, the United District Court for the Central District of
California entered an Order approving the January 28, 2017 Consent Decree to resolve
longstanding disputes pertaining to the design and operation of the Airport. Consistent with the
2017 Consent Decree, the City in May 2017 approved a plan to reduce the length of the runway
from 4,973 feet to 3,500 feet. Airport runway shortening will be completed by early 2018.
State
Senate Bill 375 (SB 375)
The adoption of California’s Sustainable Communities and Climate Protection Act (SB 375)
(Steinberg, Chapter 728, Statutes of 2008) on September 30, 2008 aligns the goals of regional
transportation planning efforts, regional GHG reduction targets, and land use and housing
allocations. SB 375 requires metropolitan planning organizations (MPOs) such as SCAG to adopt
a Sustainable Communities Strategy (SCS) or Alternative Planning Strategy (APS) within their
regional transportation plan to demonstrate the achievement of greenhouse gas reduction targets.
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In compliance with SB375, SCAG has adopted a SCS, which covers the City of Santa Monica as
well as other cities and counties, as further described below.
Caltrans Division of Aeronautics
The Caltrans Division of Aeronautics is responsible for performing safety functions that are not
the FAA’s responsibility. The State Aeronautics Act, Public Utilities Code Section 21001 et seq.,
is the foundation for these policies. The Division of Aeronautics issues permits for and annually
inspects hospital heliports and public-use airports; makes recommendations regarding proposed
school sites within two miles of an airport runway; and authorizes helicopter landing sites at or
near schools. The Division of Aeronautics also administers noise regulation and land use planning
laws that foster compatible land use around airports and encourages environmental mitigation
measures to lessen aircraft noise, air pollution, and other impacts caused by aviation. The primary
mechanism for administering these regulations, including those that foster compatible land uses is
the California Airport Land Use Planning Handbook, which is used by each County’s ALUC to
prepare a Comprehensive Land Use Plan (CLUP).
In October 2011, the Caltrans Division of Aeronautics approved the current California Airport
Land Use Planning Handbook. The purpose of the Handbook is to provide guidance for conducting
airport land use compatibility planning as required by PUC, Article 3.5, Airport Land Use
Commissions. Article 3.5 outlines the statutory requirements for ALUCs including the preparation
of the CLUPs. Article 3.5 mandates that the Division of Aeronautics create a Handbook that
contains the identification of essential elements for the preparation of an CLUP. This Handbook
is intended to (1) provide information to ALUCs, their staffs, airport proprietors, cities, counties,
consultants, and the public, (2) to identify the requirements and procedures for preparing effective
compatibility planning documents, and (3) define exemptions where applicable. The 2004 Los
Angeles County CLUP (discussed below) has not yet been revised to the 2011 Handbook, and is
instead based on its 2002 predecessor.
Regional
Los Angeles County Airport Land Use Commission (ALUC)
The Project site is located within the AIA of SMO. As such, it is within the airport planning area
of the Los Angeles County ALUC. The ALUC was established by state law to coordinate land use
planning issues for Project areas within any public use airport boundaries. In Los Angeles County,
the Regional Planning Commission has the responsibility for acting as the ALUC and for
coordinating the airport planning of public agencies within the county. The purpose of the ALUC
is to protect the public health, safety, and welfare by ensuring the orderly expansion of airports
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and the adoption of land use measures that would minimize public exposure to adverse noise and
safety impacts within areas around public use airports. ALUC is also involved with airport
activities that may adversely affect adjacent areas and nearby land use that may interfere with
airport operations.
Los Angeles County ALUC Comprehensive Land Use Plan (CLUP)
The State Aeronautics Act (California Public Utilities Code Sections 21001 et seq.) mandates that
the ALUC prepare a land use compatibility plan to ensure the orderly growth of each public airport
and the area surrounding the airport within the jurisdiction of the commission, or alternatively
prepare a land use compatibility plan for all airports located within a County.
In 2004, rather than establishing a comprehensive land use plan (CLUP) for each airport within
Los Angeles County, the ALUC adopted the current CLUP for all airports in the County in
accordance with the 2002 Caltrans California Airport Land Use Planning Handbook. The CLUP
is intended to safeguard the welfare of both inhabitants in the vicinity of airports (including SMO)
and the airfield operators/ occupants themselves. The CLUP is also intended to ensure that
surrounding new or proposed land uses do not adversely impact the airfield’s ability to continue
its operation, as it hosts multiple entities with a variety of federal and non-federal missions.
Specifically, the CLUP seeks to protect the public from the adverse effects of aircraft noise, to
ensure that people and facilities are not concentrated in areas susceptible to aircraft accidents, and
to ensure that no structures or activities adversely affect navigable airspace. The implementation
of the CLUP is intended to prevent future incompatible development from encroaching on the
airfield while allowing for continued development in accordance with the current airport master
plan.
As stated by the ALUC, while the goals of the ALUC concern planning for compatible uses around
airports, there are the limitations on its powers and duties. Specifically, the ALUC does not have
jurisdiction over airport operations, the authority to zone property or apply other land use controls.4
State law emphasizes local general plans as the primary mechanism for implementing the
compatibility policies set forth in an ALUC’s plan. Thus, Los Angeles County and each city
affected by an airport land use compatibility plan is required to make its general plan consistent
with the ALUC plan (or to overrule the commission). Recommendations made by the ALUC are
advisory to local jurisdictions and may be overruled by a two-thirds vote of the City Council. The
City has sole responsibility to specify which compatible land use at SMO and surrounding SMO
property is appropriate through its planning and zoning powers.
4 http://planning.lacounty.gov/aluc. Accessed June 30, 2017.
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The current CLUP confirms that the Project site is not located within any noise restriction, safety
restriction, or height restriction areas. It is also not located within the runway approach zone, nor
the RPZ.
Southern California Association of Governments (SCAG)
SCAG is the MPO for six southern California counties, including Imperial, Orange, Riverside, San
Bernardino, Ventura, and Los Angeles. As such, it is responsible for preparing the Regional
Transportation Plan (RTP), which provides the framework for all transportation system
improvements planned for its jurisdiction. The RTP is one of several inputs used to develop the
Federal Transportation Improvement Program (FTIP) and State Transportation Improvement
Program (STIP).
Regional Transportation Plan (RTP)/Sustainable Communities Strategy (SCS)
In April of 2016, SCAG adopted the 2016-2040 RTP/SCS, which includes goals to increase
mobility and enhance sustainability for the region’s residents and visitors. The RTP/SCS
encompasses three principles to improve the region’s future: mobility, economy, and
sustainability. The RTP/SCS minimizes increases in regional traffic congestion by focusing
growth, density, and land use intensity within existing urbanized area as the general land use
growth pattern for the region while enhancing the existing transportation system and integrating
land use into transportation planning. The RTP/SCS recommends local jurisdictions accommodate
future growth within existing urbanized areas to reduce vehicle miles traveled (VMT), congestion,
and greenhouse gas (GHG) emissions. The RTP/SCS approach to sustainably manage growth and
transportation demand would reduce the distance and barriers between new housing, jobs, and
services and would reduce vehicle travel and GHG emissions. Overall, the strategies and policies
in the RTP/SCS are projected to exceed the GHG emission-reduction targets set forth by the
California Air Resources Board under SB 375.
Local
City of Santa Monica General Plan
The City of Santa Monica General Plan is the fundamental planning policy document of the City,
providing a “blueprint” for the design of the City. The purpose of the General Plan is to identify
the appropriate location of land uses, the basic design and function of circulation, open space, and
infrastructure policies, as well as public service needs. The General Plan consists of the seven state
mandated elements: Land Use and Circulation Element (2010); Housing Element (2013); Open
Space Element (2001); Scenic Corridors Element (1975); Noise Element (1992); Conservation
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Element (1975); and, Safety Element (1995). In addition, the Santa Monica General Plan also
contains a Historic Preservation Element (2002).
Land Use and Circulation Element (LUCE): The LUCE was adopted July 6, 2010 and is the land
use and transportation planning document governing existing and future land uses in the City
through 2030. The LUCE establishes the guiding goals, policies, and criteria for land uses and
circulation in the City. An important goal of the LUCE is to promote a sustainable and diverse
land use pattern that enriches the City’s neighborhoods and districts, and which is supported by
robust transportation alternatives to help reduce greenhouse gas emissions and vehicle miles
traveled. The LUCE also emphasizes the importance of increasing the amount of green space in
the City and to provide greater access to recreational facilities. The LUCE also establishes a City
goal of preparing a specific plan for Airport Park and Business Park District at the appropriate
time.
As discussed above, the LUCE Land Use Designation Map designates the Project site as
“Institutional/Public Lands”. The Institutional/Public Land designation allows any public or quasi-
public uses, including schools, colleges, municipal offices, museums or performance spaces,
corporation yards, utility stations, and other similar uses (City of Santa Monica 2015). The LUCE
does not establish specific development parameters (e.g., setbacks, stepbacks) for either the
Institutional/Public Lands or Parks and Open Space land use designations.
Housing Element: The 2013-2021 Housing Element, adopted in December 2013, outlines the
policies and programs that the City will undertake to encourage new housing to meet the needs of
existing residents and accommodate population increases over the next eight years. These policies
and programs are intended to preserve existing residential neighborhoods and promote a range of
housing opportunities at all affordability levels.
Open Space Element: The Open Space Element of the City’s General Plan was adopted in 2001.
The basic objectives and goals of the Open Space Element are to develop and maintain a diversified
and balanced system of high quality open space, to expand the open space system through the use
of public properties, to create a system of linked central parks, and to reinforce the City’s system
of pathways and green streets. The Open Space Element had conceptualized portions of the Project
site for open space uses (City of Santa Monica 2001). Objectives and policies outlined in the Open
Space Element applicable to the Project include:
• Objective 1: Develop and maintain a diversified and balanced system of high-quality open
space;
• Objective 2: Expand the open space system through use of public properties;
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• Policy 2.1: Reuse portions of public lands;
• Policy 9.2: Increase the visibility of the parks; and
• Policy 9.3: Provide appropriate signage for orientation and interpretative purposes.
Conservation Element: The Conservation Element was adopted by the City in 1975. The policies
of the Conservation Element focus on four areas of primary concern related to the management of
the City’s natural resources: (1) Beach; (2) Water; (3) Land; and (4) Air. The Conservation
Element addresses water recycling, transportation planning to reduce VMT and air pollution
impacts, State insulation standards for new residential buildings, and improved public transit.
Noise Element: The Noise Element, which was adopted by the City in 1992, provides a
comprehensive evaluation of noise issues and identifies methods to protect the community from
excessive noise. The predominant noise source in the Project area is from aircraft sources,
including regular operations of the SMO, and vehicle noise from nearby streets such as Bundy
Drive. Table 2 of the Noise Element suggests that for parks – and specifically for picnic areas –
the CNEL not exceed 65 CNEL. Please see Section 3.6, Noise, for a discussion of the Project’s
potential noise impacts.
Safety Element: The Safety Element, which was adopted by the City in 1995, provides an
assessment of natural and human-related hazards in the City and provides a framework from which
safety considerations are introduced into the land use planning process.
Historic Preservation Element: Adopted in 2002, the Historic Preservation Element includes
information about the history and historical development of Santa Monica, establishes a vision and
goals for the protection of historic resources in the City, and provides implementation strategies to
achieve those goals.
Santa Monica Zoning Ordinance
The City’s Ordinance (Chapter 9.01 through Chapter 9.52 of the SMMC) establishes regulations
for permitted uses, Project design and development, parking, loading and transportation demand
management (TDM) requirements, and other requirements regarding land use and development in
the City. The Zoning Ordinance was comprehensively updated in June 2015 to reflect the LUCE
vision, goals, and policies.
As discussed above, an official zoning designation is not applied to SMO property outside of the
existing Airport Park. The existing Airport Park is designated Parks and Open Space (OS). Per
SMMC Section 9.15.010, the Parks and Open Space (OS) zoning designation is intended to
preserve, enhance, and expand the City’s existing open space, parks, beaches, and recreational
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areas, providing residents with easy access to a relaxing, visually appealing amenity that provides
opportunities for healthy recreation. This zoning designation is applied to areas that will remain as
parks or green open space, or be developed as such. Other allowed uses in this designation include
supporting structures such as recreation centers, gymnasiums, community meeting facilities and
small-scale retail uses that support outdoor recreation, such as restaurants, refreshment stands, or
sporting equipment and rental vendors.
Santa Monica Parks and Recreation Master Plan
Adopted in 1997, the Santa Monica Parks and Recreation Master Plan guides the improvement of
the City’s parks and recreational facilities. The Master Plan is oriented to the range of public
improvements which will add to the livability of the City. The Master Plan focuses on the public
realm, and the role which the City can play in the provision of services and facilities, on its own,
as well as in cooperation with other entities. It focuses on activities that the City can best support
within the limitations of space and budget. The emphasis is placed on activities which serve the
greatest number and best represent the recreational priorities of residents.
3.5.3 Impact Assessment and Methodology
Thresholds for Determining Significance
The following thresholds of significance are based on Appendix G of the 2017 CEQA Guidelines.
For purposes of this EIR, implementation of the Project may have a significant adverse impact on
land use and planning if:
a) The Project would physically divide an established community;
b) The Project would conflict with any applicable land use plan, policy, or regulation of an
agency with jurisdiction over the Project (including, but not limited to the general plan,
specific plan, local coastal program, or zoning ordinance) adopted for the purpose of
avoiding or mitigating an environmental effect; and/or
c) The Project would conflict with any applicable habitat conservation plan or natural
community conservation plan.
Non-Applicable Threshold(s):
• Threshold (a) Division of an Established Community: The Project site is presently
developed with a portion of the existing Airport Park, paved surface areas, as well as
airport-related uses including small administration office buildings and airplane hangars.
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The Project’s proposed mix of uses would be consistent with surrounding land uses and
the existing land use patterns in the vicinity of SMO. Since the early 1920s, SMO has
formed a notable barrier to north-south circulation through the City, and physically
separated land uses on either side of the airport, most of which were developed well after
the airport itself. The existing transportation network has long been designed to
circumnavigate SMO. The Project would not exacerbate any physical barrier caused by
SMO and may improve the connectivity of established communities by implementing a
design that allows for future bicycle and pedestrian connections with Santa Monica
neighborhoods to the north and west. Although the Project would relocate the southern
terminus of Donald Douglas Loop South, this minor relocation would serve to improve
circulation to the park and to the airport-related uses in the immediate vicinity following
implementation of the Project. Therefore, the Project would not physically divide an
established community and this issue will not be analyzed further in this EIR.
• Threshold (c) Conservation Plan: The Project site is not subject to any habitat conservation
plan or natural community conservation plan, as the area is devoid of habitat area and does
not fall under any applicable plan. Accordingly, no impacts associated with potential
inconsistencies within applicable habitat conservation or natural community conservation
plans would occur with implementation of the Project. Therefore, this issue will not be
analyzed further in this EIR.
Methodology
The analysis of land use consistency impacts considers whether the Project would be consistent
with regional and local plans and regulations that are applicable to the Project and Project site.
CEQA Guidelines Section 15125(d) requires that an EIR discuss potential inconsistencies with
applicable adopted plans that the decision-makers should address. Under CEQA, a Project is
considered consistent with the provisions of the identified regional and local plans if it is
compatible with and will further the objectives and policies of the plan. Consistent with the scope
and purpose of this EIR, this discussion primarily focuses on those goals and policies that relate to
avoiding or mitigating environmental impacts, and an assessment of whether any inconsistency
with these standards creates a significant physical impact on the environment.
Consistency with adopted General Plan goals, policies, and regulations/standards is evaluated in
detail below, as well as consistency with adopted regional plans (e.g., SCAG’s RTP/SCS).
Elements of the Project that have the potential to conflict with a stated threshold, goal, policy, or
regulation/standard are summarized in this section, along with related physical environmental
consequences.
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3.5.4 Project Impacts and Mitigation Measures
Would the Project conflict with any applicable land use plan, policy, or regulation of an agency
with jurisdiction over the Project (including, but not limited to the general plan, specific plan,
local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an
environmental effect?
LU-1 The Project would be substantially consistent with the goals and policies
contained within the City’s General Plan, Zoning Ordinance, and applicable
federal, state, and regional plans, including those that govern airport land
uses. Therefore, impacts would be less than significant.
Impact Description (LU-1)
As described above, the Project site is located within SMO property. SMO operates within a
complex framework of federal, state, and local laws and regulations.
Consistency with FAA Part 77
The Project site is located outside of the runway approach zone and designated RPZs for SMO
(Figure 3.4-1). As described in Section 3.4, Hazards and Hazardous Materials, the Project would
require a FAA Part 77 Clearance Permit to be submitted to and approved by the FAA to ensure
airport land use compatibility. Through this process, the Project would be required to avoid new
development that may cause airspace obstructions and to reduce safety risks associated with airport
hazards and accidents. The Project site is located outside of the designated RPZs for SMO and
would not introduce objects into the established flight paths. The Project proposes the development
of ground-level recreational uses and small accessory structures (such as restrooms) that would
not interfere with the operation of aircraft. The Project would increase the amount of lighting
within the vicinity of the existing runway lighting. The 70-foot high light standards for the sports
fields fall within the FAA’s purview in Part 77 of the Federal Aviation Regulations obstruction
clearance regulations and require submittal of a Form 7460-1 to the FAA. In accordance with FAA
Part 77, the FAA would review both the proposed structures and lighting as part of its Form 7460-
1 review responsibilities. With FAA review and approval of a Part 77 Clearance Permit, the
Project’s proposed impacts with the respect to FAA Part 77 would be less than significant.
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Consistency with 2010 LUCE
The LUCE focuses on fostering the livability and vibrancy of the City, while promoting
sustainability and providing facilities that meet the needs of the community, including public
parks. The LUCE also focuses on fostering the economic and social health of the City, as well as
improving the streets, connections and other parts of the public realm to serve all modes (vehicles,
pedestrians, bikes, and transit). The Project site is designated as Institutional/Public Lands. Areas
designated as Institutional/Public Lands have a strong variety of government, recreational,
educational, cultural, and other facilities that meet the needs of the community. The Project would
be consistent with the LUCE vision to expand the amount, quality, diversity and interconnectivity
of parks, open spaces and recreational facilities throughout the City by more than doubling the size
of the existing Airport Park and increasing the amount of park space by approximately 12 acres.
Table 3.5-3 contains a consistency analysis of the Project with the relevant goals and policies stated
in the LUCE. As discussed in Table 3.5-3, the Project would be generally consistent with LUCE
policies. The Project incorporates pedestrian-scale open space, enhanced recreational
opportunities, and access via existing transit lines and bicycle facilities. These elements are
consistent with LUCE objectives for parks and open space, including increasing the amount of
parkland throughout the City, locating new recreational amenities near transit corridors, creating
pedestrian-oriented spaces, and providing a range of amenities and recreational uses for residents
of all ages and income levels.
As discussed above and in Table 3.5-3, the Project increases recreational opportunities within close
proximity to existing residences and transit lines, provides adequate bicycle facilities, and
improves pedestrian connections to the existing park. As a result, and consistent with the
consistency findings in Table 3.5-3, the Project would be substantially consistent with the goals
and policies of the City’s LUCE and impacts would be less than significant.
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Table 3.5-3. Consistency with 2010 LUCE Policies
Objective/Policy Relationship of Project
Citywide Goals and Policies
Policy LU1.5 Design Compatibility. Require that
new infill development be compatible with the
existing scale, mass and character of the residential
neighborhood. New buildings should transition in
size height and scale toward adjacent residential
structures.
Consistent. The Project would expand an existing park by
developing new parkland with a compatible design with
additional pedestrian lighting and expanded sidewalks on
Airport Avenue. The Project is designed at ground levels
and only includes two small restroom/concession
structures that are consistent with the scale of surrounding
development. Additionally, outdoor public seating, access
to open space and community garden plots would further
activate the adjacent streets and promote a vibrant
pedestrian environment.
Goal LU4: Complete Sustainable Neighborhoods –
Create complete neighborhoods that exemplify
sustainable living practices with open spaces, green
connections, diverse housing, local employment,
and local-serving businesses that meet the daily
needs of residents and reduce vehicle trips and GHG
emissions.
Consistent. The Project would provide the City with
additional open space, and would promote sustainable
living practices by providing 60–80 community gardening
plots. By increasing access to recreational amenities such
as new sports fields, vehicle trips to other recreational
facilities either inside or outside of the City would be
reduced.
Policy LU4.4. 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 has been designed to engage
pedestrians and emphasize bicycle and pedestrian access.
Under the Project, Donald Douglas Loop South would be
realigned to allow continuous pedestrian access for
visitors of the park.
Policy LU4.6 Open Space. Provide open space and
green connections near residences that are part of an
expanding and comprehensive system of passive
and active open space and complete street design
emphasizing inter-connectivity, recreation, and
gathering spaces.
Consistent. The Project would expand existing Airport
Park by adding approximately 12 acres of open space and
recreational amenities to the City, and is designed to
provide interconnectivity, recreation, and gathering spaces
in close proximity to established residential
neighborhoods. The Project has been designed to
alleviate the heavy demand for existing athletic fields and
would be complementary to the potential future expansion
of Airport Park following the anticipated closure of SMO.
Policy LU4.7 Pedestrian, Bicycle and Transit
Access. Emphasize pedestrian and bicycle access
throughout the City, with a special focus on
neighborhood gathering areas. Provide direct and
convenient bicycle and pedestrian connections
between destinations. Prioritize land use patterns
that generate high transit ridership at major transit
stops.
Consistent. The Project would locate additional recreation
facilities for all ages within walking distance to residential
neighborhoods, encouraging an active environment and
providing access to many residents within walking and
bicycling distance. In addition, regional bus access would
continue to be provided via Big Blue Bus Routes 14 and
44, with Route 14 maintaining bus stops at the
intersection of South Bundy Drive and Airport Avenue.
Bicycle racks to accommodate approximately 45 bicycles
would be placed adjacent to the new pathways. The
Breeze Bike Share location at the current intersection of
Airport Avenue and Donald Douglas Loop South would
be temporarily relocated during Project construction, and
placed at the new intersection upon Project completion.
The Project would provide new pedestrian access points
to the Project site from South Bundy Drive.
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Table 3.5-3. Consistency with 2010 LUCE Policies (Continued)
Objective/Policy Relationship of Project
Goal LU8: Reduction of Vehicle Trips/Management
of Congestion. Establish a complete transportation
network that supports integrated land use. Ensure
that transportation supports human activity and
access to land uses through a diverse multi-modal
transportation system that incentivizes walking,
biking and transit and reduces the need for vehicle
trips.
Consistent. See Policy LU4.7 above.
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. See Policy LU4.7 above. Additionally,
increasing recreational amenities within the City would
reduce travel demands for City residents seeking
recreational opportunities within the City.
Policy LU8.3 Pedestrian, Bicycle and Transit
Connections. Ensure pedestrian, bicycle and transit
mobility by creating facilities for comfortable
walking throughout the City, a complete and safe
bicycle network, and convenient and frequent transit
service that will make transit an attractive option for
all types of trips.
Consistent. See Policy LU4.7 above.
Policy LU8.4 Roadway Management. Prioritize
investment in amenities for pedestrian, bicycle, and
transit movement to facilitate green connections and
mobility.
Consistent. See Policy LU4.7 above.
Policy LU13.1 Maintain Character: Reinforce the
City’s distinctive natural, social, and environmental
characteristics including its beachfront and
connections to the water, civic and cultural
institutions, terrain and climate, and the geographic
fabric of neighborhoods and boulevards.
Consistent. The Project’s open space, uniform
architectural design, and extensive landscaping would
generally represent an improvement to the visual character
of the Project site and surrounding vicinity, which is now
sparsely vegetated and developed with paved surface
areas, buildings of varying age, quality of architectural
design, and states of repair. However, consistent with
other airport-themed architectural elements in the
immediate vicinity, the Project would incorporate unique
design features to acknowledge the site’s proximity to
SMO and the airport’s contribution to the historic
development of the City.
Policy LU13.2 Neighborhoods: Recognize, maintain
and enhance existing neighborhoods as defined by
their distinctive character, design and pattern of
development and the high-quality environment they
provide for a diversity of households.
Consistent. The Project would provide recreational
opportunities and outdoor space for neighborhoods in the
Project vicinity, as well as for the City as a whole.
Policy 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. See Policy LU4.7 above.
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Table 3.5-3. Consistency with 2010 LUCE Policies (Continued)
Objective/Policy Relationship of Project
Policy LU15.5 Pedestrian and Bicycle Connectivity:
Encourage the design of site and buildings to
facilitate easy pedestrian- and bicycle-oriented
connections and to minimize the separation created
by parking lots and driveways.
Consistent. See discussion for Policy LU4.7.
Policy 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 Policy LU4.4.
Goal LU17: Increase Open Space – Increase the
amount of open space in the City and improve the
quality and character of existing open space areas
ensuring access of all residents.
Consistent. The Project would more than double the size
of the existing Airport Park by providing an additional 12
acres of open space, and would improve the quality and
character of the park while providing the recreational
amenities that were desired by the community (i.e., sports
fields) and ensuring access for all residents.
Policy LU17.1 New Facilities. Encourage new
ground level open space including, but not limited
to landscaped areas, gathering spaces and play areas
in new development.
Consistent. The Project would provide new ground level
open space, including landscaped areas, community
gardens, sports fields and play areas.
Policy LU17.2 Active Streets for Living. Utilize
streets as the largest and most universally accessible
public spaces in the community by improving them
with landscaping (particularly shade trees)
pedestrian facilities and other enhancements that
promote active recreation and creates a system of
green connections.
Consistent. The Project site is located adjacent to Donald
Douglas Loop South and Airport Avenue. The Project
would realign Donald Douglas Loop South so that it no
longer bifurcates the park. The shoulders of the realigned
roadway would provide sidewalks, landscaping, and
streetscaping consistent with the Park’s architectural
design. The continuous pedestrian pathway through the
park and the park entrances would be designed on a
pedestrian scale. These features would enhance the
pedestrian connections of the Project site.
Policy H7.3: Encourage pedestrian and bicycle
connections that support active and healthy living,
and increase accessibility to daily needs and services.
Consistent. See discussion for Policy LU4.7.
Policy H7.4: Encourage context-sensitive design that
opens to the neighborhood with pedestrian friendly
features such as entrances, large windows, balconies,
stoops and porches facing the street.
Consistent. See discussion for Policy LU4.7, LU13.1, and
Policy 15.3.
Goal S2. Reduce GHG emissions from land use and
transportation decisions.
Consistent. The Project would expand an existing park
with additional open space and recreational amenities. The
project would be accessible to nearby neighborhoods and
would provide adequate bicycle parking. The Project
includes the realignment of Donald Douglas Loop South
so that it would provide new multi-use path, landscaping,
and streetscaping consistent with the City’s pedestrian-
friendly objectives. The Project would also open up
Donald Douglas Loop South to bicyclists, and improve
pedestrian connection from South Bundy Drive, allowing
for improved connections to alternative transportation.
3.5-24 Airport Park Expansion Project
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Table 3.5-3. Consistency with 2010 LUCE Policies (Continued)
Objective/Policy Relationship of Project
Goal S2.3. Advance the No Net New Trips goal in
the Land Use and Circulation Element with TDM
projects such as expanded rideshare programs,
parking management strategies, as well as
development impact fees for public transit
infrastructure
Consistent. The Project has been designed to engage
pedestrians and provide for bicycle and pedestrian access.
Under the Project, Donald Douglas Loop South would be
realigned to allow continuous pedestrian access for
visitors of the park. In addition, regional bus access would
continue to be provided via Big Blue Bus Routes 14 and
44, with Route 14 maintaining bus stops at the
intersection of South Bundy Drive and Airport Avenue.
Bicycle racks to accommodate approximately 45 bicycles
would be placed adjacent to the new pathways. The
Breeze Bike Share location at the current intersection of
Airport Avenue and Donald Douglas Loop South would
be temporarily relocated during Project construction, and
placed at the new intersection upon Project completion.
The Project would provide new pedestrian access points
to the Project site from South Bundy Drive.
Goal S6: Promote water conservation and increase
the use of reclaimed and recycled water.
Consistent. The Project would develop seven hydrozones
to selectively landscape different areas within the Project
site to minimize water usage. Drought-tolerant species
would be utilized in less active areas of the park.
Goal S9: Continue the City’s role as a leader in
sustainable development.
Consistent. The Project would be designed incorporate
sustainable design features, including the use of energy
efficient lighting features, use of synthetic turf, drought
tolerant plant species, and water efficient plumbing.
Airport and Business Park District Goals and Policies
Goal D36: Create and adopt a specific plan to
transition the Santa Monica Business Park and the
Santa Monica Airport from stand-along elements to
neighborhoods integrated into the City.
Consistent. The Project would add recreational uses to
existing Airport Park at the southeast corner of SMO. The
Project is designed to be compatible with the future
expansion of Airport Park following the anticipated
closure of SMO and does not impede the development or
implementation of a future specific plan to guide
development within the Airport and Business Park District.
Policy D36.3: The Santa Monica Airport/ Business
Park Specific Plan should set forth an appropriate
mix of land uses as well as establish a framework of
vehicular roadways and pedestrian routes, open
space and shared parking facilities to create a
complete neighborhood.
Consistent. The Project represents an appropriate
expansion of the recreational uses at existing Airport Park.
Furthermore, the Project’s design was based largely on
community input which informed the Project’s layout of
pedestrian routes, recreational, and parking facilities. The
Project has been designed to ensure compatibility with the
goal of a much larger and more varied mix of active and
natural park uses anticipated following the closure of the
airport and does not impede the development or
implementation of a future specific plan to guide
development within the Airport and Business Park District.
Policy D36.4: The Santa Monica Airport/Business
Park Specific Plan should interface carefully with
adjoining commercial uses and establish standards
and guidelines to transition to the adjacent
residential neighborhoods
Consistent. As an expansion of an existing park, the
Project will interface compatibly with adjoining
commercial uses, and provides a low-density use that
respects the scale of adjacent residential neighborhoods.
Airport Park Expansion Project 3.5-25
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Table 3.5-3. Consistency with 2010 LUCE Policies (Continued)
Objective/Policy Relationship of Project
Sunset Park Neighborhood Goals and Policies
Policy N1.3: Create active places in existing
neighborhoods to promote sociability and human
interaction.
Consistent. The Project site is located in the Sunset Park
neighborhood, and will provide residents of this
neighborhood and the City as a whole with recreation
opportunities and will promote sociability and human
interaction.
Policy N3.3: Create direct and safe pedestrian and
bicycle connections between residential areas and
nearby boulevards through the provision of
improved walkways, greenways, plazas, bicycle
trails and open space.
Consistent. See discussion for Policy LU4.7.
Policy N4.5: Ensure that new development or
redevelopment of existing properties respects the
neighborhood history and culture.
Consistent. See discussion for Policy LU13.1.
Open Space, Parks and Recreation Goals and Policies
Goal CE1: Expand the amount, quality, diversity and
interconnectivity of parks, open spaces and
recreational facilities throughout the city.
Consistent. The Project would expand the City’s open
space by 12 acres and would provide additional
recreational facilities to residents and visitors.
Policy CE1.2: Consider the use of City-owned lands
and acquired additional properties to create new
parkland throughout the City, exploring possible
code modifications if necessary.
Consistent. The Project would create new parkland on
City-owned land, consistent with the City’s long-standing
objectives. A Zoning Amendments would be implemented
to accommodate expansion of the existing park.
Policy CE1.8. Seek to improve and expand sports
and recreational facilities throughout the City.
Consistent. The Project would expand Airport Park with
two International Federation of Association Football
(FIFA)-regulation-sized synthetic turf sports fields; 60–
80 community garden plots; a large, natural turf multi-
purpose area; three pickleball courts; a continuous loop
path throughout the park; fitness equipment; children’s
play areas; and two restroom/concession buildings.
Policy CE1.9: Continue to maintain a diverse range
of recreational facilities, offering residents of all
ages affordable and safe access to high-quality
recreational opportunities.
Consistent. See response to Policy CE1.8 above.
Goal CE2: Develop a comprehensive system of
pedestrian-friendly, green streets and recreational
pathways.
Consistent. One of the Project’s major objectives is to
provide sidewalk, street and streetscape improvements
along the relocated portion of Donald Douglas Loop South
and portions of South Bundy drive to enhance the
aesthetics of the Airport, including Airport Park and its
surrounding land uses.
Goal CE7: Create convenient and safe opportunities
for physical activity for residents of all ages and
income levels.
Consistent. See response to Policy CE1.8 above.
3.5-26 Airport Park Expansion Project
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Consistency with Other General Plan Elements
State law mandates that every California city and county adopt a “comprehensive, long-term
general plan.” The elements of the general plan make up the framework for decision-making
regarding growth and development in the City. As shown in Table 3.5-4, the Project would be
consistent with the applicable goals and policies of the other General Plan Elements, and therefore
impacts would be less than significant.
Table 3.5-4. Other General Plan Policies
Policy Relationship to Project
Circulation Element
Goal T8: Provide a beautiful and attractive
pedestrian environment throughout the City.
Consistent. The Project includes pedestrian-oriented
streetscape improvements such as completion of the
sidewalk along the western park border to the new parking
lot, adding landscaping street trees, and pedestrian-level
lighting immediately adjacent to the sidewalk.
Policy T15.7: Monitor and coordinate construction
activity to minimize disruption on the transportation
system.
Consistent. A Traffic Control Plan and a Construction
Mitigation Plan would be prepared to include demolition,
site preparation, and on-going construction activities.
Components of the Traffic Control 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 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 T26.4: Adjust parking requirements for
Projects when it can be demonstrated that a lower
parking demand is appropriate.
Consistent. The Project would provide parking to meet
Projected demands, expanding parking at Airport Park
from the existing 118 spaces to 180 spaces.
Noise Element
Action 2.2: Through the Noise Ordinance, incorporate
noise reduction features during site planning to
mitigate anticipated noise impacts on affected noise
sensitive land uses. The noise referral zones identified
in Exhibits 6 and 7 (areas exposed to noise levels
greater than 60 dB CNEL) can be used to identify
locations of potential conflict. New development
would be permitted only if appropriate mitigation
measures are included such that the standards
contained in this Element are met.
Consistent. As discussed in Section 3.10, Noise, the
Project would not exceed City noise standards or
thresholds and would comply with the Noise Ordinance.
Impacts related to construction noise and operational
noise would be less than significant with proposed
mitigation. Further, an acoustical berm would also be
constructed at the northeast corner of the Project site,
adjacent to existing runways and South Bundy Drive, to
buffer the park from noise from airport operations and
from park usage on nearby residences.
Airport Park Expansion Project 3.5-27
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Table 3.5-4. Other General Plan Policies (Continued)
Policy Relationship to Project
Historic Preservation Element
Goal 4: Protect historic and cultural resources from
demolition and inappropriate alterations.
Consistent. The Project would comply with all federal,
state, and local regulations that protect historic and
cultural resources. As described in Section 4.0, Other
CEQA Considerations, previous surveys and record
searches of the Project vicinity indicate that there are no
historically significant structures or landmarks within the
Project site. In the event of inadvertent discovery of
significant archaeological and/or paleontological resources
are encountered during Project construction activities,
Mitigation Measure CR-1 would be implemented (see
Section 4.0, Other CEQA Considerations).
Conservation Element
Goal: Preservation of the ecological balance and
natural resources of the City and conservation of the
energies and materials without serious interference
with community needs.
Consistent. The Project would preserve ecological balance
and natural resources to the maximum extent feasible.
Drought-tolerant landscaping would be installed at the
Project site as appropriate for Zone 10B. As described in
Section 4.0, Other CEQA Considerations, the Project
would not have the potential for significant impacts
associated with biological resources and/or hydrology and
water quality, as the Project site would develop additional
landscaping, trees, and habitat on a Project site that is fully
developed and located within a highly urbanized area in
the City.
Objective 4: Consider environmental impacts as a
decision-making factor in planning.
Consistent. The CEQA analysis considered herein fully
considers all environmental impacts of the Project and
provides the City and the public with disclosure of all
impacts to facilitate decision-making.
Objective 5: Encourage activities and efficient
operations which favor energy conservation.
Consistent. As described in Section 2.0, Project
Description, the Project would be designed to incorporate
sustainable design features, including energy efficient
light features that meet or exceed the City’s Green
Building standards. The Project would also be designed in
accordance with the City’s Low Impact Development
(LID) Ordinance.
Open Space Element
Objective 1: Develop and maintain a diversified and
balanced system of high-quality open space.
Consistent. The Project would increase the City’s open
space area by approximately 12 acres.
Objective 2: Expand the open space system through
the use of public properties.
Consistent. See discussion for Objective 1.
Policy 2.1: Reuse portions of public lands. Consistent. The Project would convert non-aviation public
lands at SMO to Open Space/Recreation land for
expansion of Airport Park.
Policy 9.2: Increase the visibility of the parks. Consistent. See discussion for Policy 2.1.
Policy 9.3: Provide appropriate signage for
orientation and interpretive purposes.
Consistent. As described above, the Project will include
signage oriented towards pedestrians and bicyclists.
3.5-28 Airport Park Expansion Project
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Consistency with SMMC Zoning and Development Standards
Only the portion of the Project site occupied by the existing Airport Park has an official City of
Santa Monica zoning designation of OS. No SMMC zoning regulations apply to the remaining
acres of the Project that would be developed for additional park and recreational uses (i.e., west
and east parcels). There is a small portion of the Project site’s east paved surface area (Parcel APN
4272-027-270) that is located within the jurisdictional boundaries of the City of Los Angeles and
zoned R1-1 (One-Family Zone, Height District 1) by the Los Angeles Municipal Code. This land
has been owned in fee by the City (i.e., deeded to the City) since it assumed operation of SMO in
1926. Los Angeles’ One-Family Zone permits the development of parks, playgrounds, owned and
operated by a governmental agency, even though under Government Code sections 53090-91, the
City is not strictly required to comply with the City of Los Angeles Zoning Code. Lawler v. City
of Redding (1992) 7 Cal.App.4th 778, 783. Therefore, no conflict in zoning would occur.
Furthermore, no Zoning Amendment would be necessary.
Consistency with SCAG RTP/SCS Policies
Table 3.5-5 provides a discussion of the Project’s consistency with the goals and policies of the
SCAG regional planning documents that are most applicable to the Project. Consistent with the
scope and purpose of this EIR, this discussion primarily focuses on those goals and policies that
relate to avoiding or mitigating environmental impacts, and an assessment of whether any
inconsistency with these standards creates a significant physical impact on the environment. As
indicated in Table 3.5-5, the Project is consistent with SCAG policies and impacts are less than
significant.
Airport Park Expansion Project 3.5-29
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Table 3.5-5 SCAG RTP/SCS Policy Consistency Table
Policy Relationship to Project
SCAG Regional Transportation Plan/ Sustainable Communities Strategy
RTP Goal: Maximize the productivity of our
transportation system.
Consistent. The Project site is accessed by two existing Big Blue Bus
routes providing regional transit services and has pedestrian and
bicycle access for local neighborhoods. See also Policy LU4.7 above.
RTP Goal: Encourage land use and growth
patterns that facilitate transit and non-
motorized transportation.
Consistent. The Project site is located near existing transit lines
provided by the Big Blue Bus, with access to both pedestrian and
bicycle facilities. Therefore, Project residents and visitors would
have easy access to alternative transportation options. Bicycle
racks to accommodate approximately 45 bicycles would be placed
adjacent to the new pathways. The Breeze Bike Share station at the
current intersection of Airport Avenue and Donald Douglas Loop
South would be temporarily relocated during Project construction,
and placed at the new intersection of these two ways upon Project
completion.
The Project includes a mix of recreational, active, and community
serving uses. The Project would improve the pedestrian-orientation
of the area by providing expanded pathways to and through
expanded Airport Park and would provide opportunities for
bicycling and walking.
Pedestrian access would be provided at two locations along Bundy
Avenue, including at the Main Bundy Entry and the Secondary
Bundy Entry, and at six locations along Airport Avenue, including
a pedestrian path at the vacated alignment of Donald Douglas
Loop South. The pedestrian access points are designed to provide
linkages to surrounding uses and facilitate an uninterrupted flow
through the park and to other pedestrian entrances. The Project
would create a more pedestrian-oriented environment by that
would encourage walking and attract neighborhood use.
SCS Goal 1. Better Placemaking: The
strategies outlined in the 2012– 2035
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 would contribute to bicycle and pedestrian
improvements through the provision of extended sidewalks, onsite
bicycle parking and access to recreational amenities. Overall, the
Project would contribute to better placemaking in the Sunset Park,
Ocean Park and Mar Vista neighborhoods.
Consistency with the ALUC CLUP
Table 3.5-6 provides a discussion of the Project’s consistency with the goals and policies of the
ALUC CLUP that are applicable to the Project site. As shown in Table 3.5-6, parks and
recreational uses are a compatible land use within proximity to SMO per the CLUP Land Use
Compatibility Chart. Further, the Project site is located outside of established RPZs for SMO and
would no introduce objects into navigable air space. The Project site is also outside of the 65 dB
CNEL contour, which indicates the use of the Project site for parks and recreational uses if
acceptable based on ambient noise levels. Thus, impacts associated with the Project’s consistency
with the ALUC CLUP are less than significant.
3.5-30 Airport Park Expansion Project
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Table 3.5-6. CLUP Policy Consistency Table
Objective/Policy Relationship of Project
General Policies:
Policy G-1: Require new uses to adhere to the Land
Use Compatibility Chart.
Consistent. The Project would consist of development of
recreational facilities outside of designated RPZs, which
is consistent with the CLUP Land Use Compatibility
Chart.
Policy G-2: Encourage the recycling of
incompatible land uses to uses which are
compatible with the airport, pursuant to the Land
Use Compatibility Table.
Consistent. Based upon the CLUP Land Use
Compatibility Table, recreational use is considered
satisfactory up to a CNEL of 65 dB, and cautionary up to
a CNEL of 75 dB. According to the Calendar Year 2016
CNEL Contours for SMO, the Project site is outside of the
65 dB CNEL contour for SMO (City of Santa Monica
2017). Please refer to Section 3.6, Noise, for additional
discussion. As a result, park and recreational uses are
compatible from a noise perspective. As discussed above,
the Project would replace aviation uses with park and
recreation facilities in accordance with the City’s long-
standing objectives.
Policy G-3: Consider requiring dedication of an
aviation easement to the jurisdiction owning the
airport as a condition of approval on any project
within the designated planning boundaries.
Consistent. The City maintains jurisdiction over the
airport and will continue to have jurisdiction following
implementation of the Project. As discussed above, the
Project would replace aviation uses with park and
recreation facilities in accordance with the City’s long-
standing objectives.
Policy G-4: Prohibit any uses which will negatively
affect safe air navigation.
Consistent. As described above, the maximum height of
light standards associated with the Project would not
exceed 70 feet, and would not involve any development
that would negatively affect safe air navigation. FAA
review and approval of an FAA Part 77 Clearance Permit
would ensure that the Project does not introduce
obstructions into navigable air space or negatively impact
the directional and safety lighting at the airport.
Policy G-5: Airport proprietors should achieve
airport/community land use compatibility by
adhering to the guidelines of the California Noise
Standards.
Consistent. Refer to Policy G-2 above.
Policy N-1: Use the CNEL method for measuring
noise impacts near airports in determining
suitability for various types of land uses.
Consistent. Refer to Policy G-2 above.
Policy N-3: Utilize the table listing Land Use
Compatibility for Airport Noise Environments in
evaluating projects within the planning boundaries.
Partially consistent. Refer to Policy G-2 above.
Airport Park Expansion Project 3.5-31
Final EIR – January 2018
3.5 LAND USE AND PLANNING
Table 3.5-6. CLUP Policy Consistency Table (Continued)
Objective/Policy Relationship of Project
Policy N-4: Encourage local agencies to adopt
procedures to ensure that prospective property
owners in aircraft noise exposure areas above a
current or anticipated 60 dB CNEL are informed of
these noise levels and of any land use restrictions
associated with high noise exposure.
Consistent. Refer to Policy G-2 above. In addition, the
City is the owner and operator of SMO and the Project
site. The City implements a rigorous noise monitoring
and reporting program that includes the preparation of
annual noise reports, routine community updates, and a
24-hour hotline for noise complaints.
Policy S-1: Establish “runway protection zones”
contiguous to the ends of each runway. These RPZs
shall be identical to the FAA’s Runway Protection
Zone (formally called Clear Zones).
Consistent. RPZs have already been established at SMO.
As discussed above, the Project site is located outside of
the RPZs for SMO and the Project does not propose any
development within the established RPZs.
Policy S-2: Prohibit above ground storage of more
than 100 gallons of flammable liquids or toxic
materials on any one net acre in a designated RPZ.
It is recommended that these materials be stored
underground.
Consistent. Refer to Policy N-4 above.
Policy S-5: Prohibit uses which would attract large
concentrations of birds, emit smoke, or which may
otherwise affect safe air navigation.
Consistent. The Project includes recreational uses, and is
not expected to attract large concentrations of birds, emit
smoke, nor otherwise affect safe air navigation.
S-6: Prohibit uses which would generate electrical
interference that may be detrimental to the
operation of aircraft and/or aircraft
instrumentation.
Consistent. No uses which would generate electrical
interference are proposed as part of the Project. Therefore,
the Project would not affect the operation of aircraft nor
aircraft instrumentation.
S-7: Comply with the height restriction standards
and procedures set forth in FAR Part 77.
Consistent. As described above, the tallest structure
proposed as part of the Project would not exceed a height
of 28 feet, which is well below the height restriction
standards set forth in FAR Part 77.
Cumulative Impacts
Implementation of the Project would be substantially consistent with the goals and policies
contained within SCAG’s RTP/SCS, the City’s Zoning Ordinance, LUCE, and other Elements of
the City’s General Plan. The Project would also be compatible with the Airport Avenue
Improvement Project, would include roadway, bicycle lane, sidewalk, streetscape and landscaping
improvements along Airport Avenue. The construction schedule of this pending project would be
programmed to overlap with the Project. In conjunction, the two Projects would help to further
many of the City’s goals to increase pedestrian and bicycle connections throughout the City,
incentivize the use of non-motorized transportation, utilize City streets as park space, develop
projects with an attractive appearance, and maintain a positive interface with adjacent
neighborhoods. Furthermore, with completion of the Airport Runway Shortening Project, potential
land use and airport hazard effects on Project visitors would be reduced. As a result, cumulative
impacts resulting from the Project and cumulative projects would be less than significant.
3.5-32 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
This section analyzes the potential impacts of the proposed Airport Park Expansion Project
(Project) related to noise. The existing noise environment for the Project site is described and the
analysis evaluates the potential noise and vibration impacts that could result from the Project. This
analysis addresses both short-term construction impacts and long-term operational noise impacts.
Potential direct and indirect impacts resulting from construction and operational activities of the
Project are identified, and feasible mitigation measures that could avoid or reduce impacts are
recommended, where necessary. The discussion and analysis provided in this section is informed
by the City of Santa Monica (City) General Plan Land Use and Circulation Element (LUCE),
General Plan Noise Element, the Los Angeles County Airport Land Use Plan (ALUP), the Santa
Monica Airport Calendar Year 2016 Annual Operations Report, the Santa Monica 2016 CNEL
(Community Noise Equivalent Level) Contour Study, the March 2016 Site Noise Survey prepared
by ARUP (Appendix E), and the Transportation Impact Analysis prepared by Fehr & Peers
(Appendix F).
3.6.1 Fundamentals of Sound and Environmental Noise
Noise
Sound is technically described in terms of the loudness (amplitude) and frequency (pitch) of the
sound. Noise is typically defined as unwanted sound that interferes with normal activities or
otherwise diminishes the quality of the environment. Prolonged exposure to high levels of noise is
known to have several adverse effects on people, including hearing loss, communication
interference, sleep interference, physiological responses, and annoyance (City of Santa Monica
1992). The noise environment typically includes background noise generated from both near and
distant noise sources, as well as the sound from individual local sources. These can vary from an
occasional aircraft departures and arrivals occurring at the adjacent Santa Monica Municipal
Airport (SMO) to continuous noise from sources, such as traffic on a major road.
The standard unit of measurement of the loudness of sound is the decibel (dB). Since the human
ear is not equally sensitive to sound at all frequencies, a special frequency-dependent rating scale
has been devised to relate noise to human sensitivity. The A-weighted decibel scale (dBA)
performs this compensation by discriminating against frequencies in a manner approximating the
sensitivity of the human ear. Decibels are based on the logarithmic scale. The logarithmic scale
compresses the wide range in sound pressure levels to a more useable range of numbers in a
manner similar to the way that the Richter scale is used to measure earthquakes. In terms of human
response to noise, studies have indicated that a noise level increase of 3 dBA is barely perceptible
Airport Park Expansion Project 3.6-1
Final EIR – January 2018
3.6 NOISE
to most people, a 5-dBA increase is readily noticeable, and a difference of 10 dBA would be
perceived as a doubling of loudness. Everyday sounds normally range from 30 dBA to 100 dBA
(City of Santa Monica 1992). Examples of various sound levels in different environments are
shown in Table 3.6-1.
Table 3.6-1. Representative Noise Levels
Common Outdoor Activities Noise Level
(dBA) Common Indoor Activities
Power Saw —110— Rock Band
Jet Fly-over at 100 feet Crying Baby
Subway —100—
Gas Lawnmower at 3 feet
Rail Transit Horn/ Tractor —90—
Jack Hammer Food Blender at 3 feet
Rail Transit At-grade (50 mph) —80— Garbage Disposal at 3 feet
Noisy Urban Area during Daytime
Gas Lawnmower at 100 feet —70— Vacuum Cleaner at 10 feet
Rail Transit in Station/ Commercial Area Normal Speech at 3 feet
Heavy Traffic at 300 feet —60— Sewing Machine
Air Conditioner Large Business Office
Quiet Urban Area during Daytime —50— Dishwasher in Next Room
Refrigerator
Quiet Urban Area during Nighttime —40— Theater, Large Conference Room
(background)
Quiet Suburban Area during Nighttime
—30— Library
Quiet Rural Area during Nighttime Bedroom at Night, Concert Hall (background)
—20—
Broadcast/Recording Studio
—10—
Lowest Threshold of Human Hearing —0— Lowest Threshold of Human Hearing
Source: Caltrans 2013a..
3.6-2 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
Several rating scales have been developed to analyze the adverse effect of community noise on
people. Since environmental noise fluctuates over time, these scales consider the effect of noise
upon people largely dependent upon the total acoustical energy content of the noise, as well as the
time of day when the noise occurs. Each noise rating scale applicable to this analysis is defined as
follows:
• Leq (equivalent energy noise level) is the average acoustic energy content of noise for a
stated period of time. Thus, the Leq of a time-varying noise and that of a steady noise are
the same if they deliver the same acoustic energy to the ear during exposure. For evaluating
community impacts, this rating scale does not vary, regardless of whether the noise occurs
during the day or the night.
• CNEL (Community Noise Equivalent Level) is a 24-hour average A-weighted Leq with a
5-dBA penalty added to noise events during the hours of 7:00 P.M. to 10:00 P.M. and a 10-
dBA penalty added to noise events during the hours of 10:00 P.M. to 7:00 A.M. to account
for noise sensitivity in the evening and nighttime, respectively. The logarithmic effect of
these additions is that a 60 dBA 24-hour Leq would result in a measurement of 66.7 dBA
CNEL.
• Ldn (day-night average noise level) is a 24-hour average A-weighted Leq with a 10-dBA
penalty added to noise events during the hours of 10:00 P.M. to 7:00 A.M. to account for
noise sensitivity in the nighttime. The logarithmic effect of these additions is that a 60 dBA
24-hour Leq would result in a measurement of 66.4 dBA Ldn.
Local average ambient noise levels are defined by an average of the ambient background noise levels and peak
noise events. Peak noise events may include sporadic increases in noise levels from street noise, aircraft
overflights, and other temporary increase in noise.
Source: Santa Monica Municipal Airport.
Airport Park Expansion Project 3.6-3
Final EIR – January 2018
3.6 NOISE
• Lmin (minimum instantaneous noise level) is the minimum instantaneous noise level
experienced during a given period of time.
• Lmax (maximum instantaneous noise level) is the maximum instantaneous noise level
experienced during a given period of time.
Noise levels from a particular source decline (attenuate) as distance to the receptor increases. Other
factors, such as the weather and reflecting or shielding by buildings or other structures, intensify
or reduce the noise level at a location. A common method for estimating mobile source (e.g.,
vehicles along roadways) noise is that for every doubling of distance from the source, the noise
level is reduced by about 3 dBA at acoustically “hard” locations (i.e., mostly asphalt, concrete,
hard-packed soil, or other solid materials) and 4.5 dBA at acoustically “soft” locations (i.e.,
contains normal earth or vegetation, such as grass).
Noise from stationary or point sources (including construction noise) is reduced by about 6 to
7.5 dBA for every doubling of distance at acoustically hard and soft locations, respectively.1 Noise
levels may also be reduced by intervening structures. Generally, a single row of buildings between
the potential noise receptor and the noise source reduces the noise level by about 5 dBA, while a
solid wall or berm can reduce noise levels by up to 5 to 10 dBA. In addition, the manner in which
older homes in California were constructed generally provides a reduction of exterior-to-interior
noise levels of about 20 to 25 dBA with closed windows. The exterior-to-interior noise reduction
of newer residential units is generally 30 dBA or more due to improved insulation, double glazed
windows and other modern design requirements.
Vibration
Vibration is sound radiated through the ground. Most perceptible indoor vibration is caused by
sources within buildings, such as operation of mechanical equipment, movement of people, or
slamming of doors. Typical outdoor sources of perceptible ground-borne vibration are construction
equipment, steel-wheeled trains, and traffic on rough roads. If a roadway is smooth, the ground-
borne vibration from traffic is rarely perceptible. The vibration of floors and walls may cause
perceptible vibration, rattling of items such as windows or dishes on shelves, or a rumble noise.
The rumble is the noise radiated from the motion of the room surfaces. In essence, the room
surfaces act like a large loudspeaker causing what is called ground-borne noise. Ground-borne
vibration rarely disturbs people in outdoor settings. Although the motion of the ground may be
1 Acoustically hard locations typically include urban environments developed with hard surfaces and materials that reflect
a greater amount of noise, while soft locations typically include less developed areas where noise can be absorbed by trees,
vegetation and other soft materials.
3.6-4 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
perceived, without the effects associated with the shaking of a building, the motion does not
provoke the same adverse human reaction. In addition, the rumble noise that usually accompanies
the building vibration is perceptible only inside buildings. Typically, ground-borne vibration
generated by manmade activities attenuates rapidly with distance from the source of the vibration.
Man-made vibration issues are therefore usually confined to short distances from the source.
The ground motion caused by vibration can be measured as particle velocity in inches per second
(in/sec). The range of human response for continuous ground-borne vibration is from 0.012 in/sec
which is barely perceptible, to 0.4 in/sec, which is considered severe. The vibration level at which
continuous vibration is strongly perceptible is 0.1 in/sec. For incidental ground-borne vibration,
0.035 in/sec is barely perceptible while 2.0 in/sec is felt severely (Caltrans 2013b). General human
response to different levels of ground-borne vibration velocity levels are described in Table 3.6-2
and guidelines for the effect of vibration levels in structures described in Table 3.6-3.
Table 3.6-2. Human Response to Different Levels of Ground-borne Vibration
Human Response Transient
(in/sec)
Continuous
(in/sec)
Barely perceptible 0.035 0.012
Distinctly perceptible 0.24 0.035
Strongly perceptible 0.9 0.1
Severe/Disturbing 2 0.4
Source: Caltrans 2013.
Note: Transient sources create a single isolated vibration event, such as blasting or drop balls. Continuous/frequent intermittent
sources include impact pile drivers, pogo-stick compactors, crack-and-seat equipment, vibratory pile drivers, and vibratory
compaction equipment.
Table 3.6-3. Vibration Thresholds for Potential Structural Damage
Structure and Condition Transient
(in/sec)
Continuous
(in/sec)
Extremely fragile historic buildings, ruins, ancient
monuments 0.12 0.08
Fragile buildings 0.2 0.1
Historic and some old buildings 0.5 0.25
Older residential structures 0.5 0.3
New residential structures 1 0.5
Modern industrial/commercial buildings 2 0.5
Source: Caltrans 2013.
Airport Park Expansion Project 3.6-5
Final EIR – January 2018
3.6 NOISE
3.6.2 Existing Setting
The Project site lies within a developed urban area at the southeastern edge of the City. Noise
levels in the vicinity are typical for land uses within the City include a range of residential,
commercial, light industrial, institutional, and recreational open space areas. At the Project site,
the primary source of noise is aircraft operations from the SMO, sporting events as well as other
activities at the existing Santa Monica Airport Park (Airport Park), and vehicular noise from the
local road network such as South Bundy Drive. Specifically, noise generated by Airport Park
currently includes noise from canines and users of the Airport Park Dog Park, active and passive
park users, picnickers, and noise from games held at the existing synthetic turf sports field. Use of
the synthetic sports field requires a permit from the City, in which typical game time hours are
Monday through Friday from 5 P.M. to 9 P.M. (beginning at 3 P.M. during the school year), and
Saturdays and Sundays from 9 A.M. to 5 P.M. Due to the high demand for sports play at Airport
Park, permit hours have been limited by the City. Noise in the vicinity may also occur from various
stationary sources, such as mechanical equipment associated with buildings,
loading/delivery/garbage truck operations, and the operation of various types of businesses.
The Project site is located along Airport Boulevard and is bound by aviation-related commercial
uses to the west, the SMO Administration Building and Donald Douglas Loop to the North, South
Bundy Drive to the east, and Aviation Boulevard to the south. Donald Douglas Loop South serves
as the primary southern entrance to SMO and aviation facilities, as well as access to aircraft
hangars and airport aprons. Adjacent to the Project site, South Bundy Drive carries approximately
The primary source of noise in the Project vicinity include runway and aircraft noise generated by aircraft operations
at SMO (left), sports events and recreational activities at Airport Park (right), vehicular noise from the local road
network, and delivery trucks and other typical noise sources from commercial businesses in the vicinity (Santa
Monica Municipal Airport & Airport Land Use Commission 2015).
3.6-6 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
48,457 average daily vehicle trips at the intersection of South Bundy Drive with National
Boulevard (LADOT 2016).
In order to identify representative noise levels at the Project site and vicinity, short-term attended
noise measurements were on taken on March 10, 2016 between the hours of 10:00 A.M. and
10:00 P.M. at 10 locations by ARUP as part of the Site Noise Survey for the Project (Appendix E).
Noise measurements were taken at 8 locations at the east paved surface area, with two locations
within both the west paved surface area and at the existing Airport Park (see Figure 3.6-1). Noise
measurements were taken in 5-minute intervals (Leq), with maximum instantaneous noise levels
recorded during this period (Lmax). These noise measurements were conducted at different times
during the day to capture ambient noise levels representative of busy airport operations (late
morning) and P.M. peak traffic period on nearby roadways.2
The highest measured noise levels were at the locations closest to the SMO runway (Sites 8 and
10), had an Lmax of 77 dB in the mid-day and 75 dB in the evening, respectively. Based on
proximity to multiple noise sources (SMO runway and South Bundy Drive), the existing east paved
surface area generally experiences greater noise levels, with average Leqs over the three periods of
67.0 dBA and 59.7 dBA (Sites 8 and 10). The lowest Leqs were experienced within the area of the
existing Airport Park (Site 3, 55.3 dBA), the portion of the east paved surface area obstructed from
the runway by the Airport Administration Building (Site 5, 56.7 dBA), and the portion of the west
paved surface areas furthest from the runway and South Bundy Drive (Site 6, 57.0 dBA)
(Table 3.6-4).
Table 3.6-4. Existing Noise Levels Measured in the Project Vicinity (in dBA)
Site 1 Site 2 Site 3 Site 4 Site 5 Site 6 Site 7 Site 8 Site 9 Site 10
La
t
e
Mo
r
n
i
n
g
Leq 58 60 58 58 57 58 60 71 59 57
Lmax 73 75 63 72 67 73 74 77 66 71
PM
P
e
a
k
Leq 59 57 54 57 60 58 59 65 59 61
Lmax 66 70 60 66 72 70 71 71 68 73
Ev
e
n
i
n
g
Leq 55 56 54 59 53 55 54 65 60 61
Lmax 65 67 60 67 59 62 60 74 66 75
Average Leq1 57.3 57.7 55.3 58.0 56.7 57.0 57.7 67.0 59.3 59.7
1 Average of Leq during Mid-Day, PM Peak, and Evening hours for each site.
2 Late morning noise data was collected during one period at each site, between 10:18 A.M. and 12:33 P.M. P.M. peak
hour traffic noise data was collected during two periods at each site, between 4:33 P.M. and 7:25 P.M.
Airport Park Expansion Project 3.6-7
Final EIR – January 2018
6
5
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3.6-8
3.6 NOISE
Noise from Airport Operations
The Project site is located on the southeastern boundary of SMO property, adjacent to commercial
aviation-related uses and approximately 500 feet south of the runway. SMO operates 24 hours a
day, seven days a week; however, the Santa Monica Municipal Code (SMMC) establishes curfews
for late night aircraft arrivals and restrictions on prohibitions on nighttime aircraft departures. In
2016, the most recent year in which data is tabulated, SMO managed a total of 87,904 aircraft
operations.3 Of these operations, 76.5 percent were from propeller aircraft, 20.0 percent were from
jet aircraft, and 3.5 percent were from helicopter operations, with jet aircraft operations typically
representing the loudest noise occurrences. According to the Calendar Year 2016 CNEL Contours
for SMO, the majority of the Project site is located within the 60 CNEL contour and areas of the
western portion of the Project site (where vehicle parking areas are proposed) overlap the 65 CNEL
contour (City of Santa Monica 2017).
In response to concerns from the
community regarding airport noise and a
long-standing goal of minimizing aircraft
noise exposure, SMO established the
Santa Monica Airport Noise
Management Program. This program
summarizes aircraft operations in an
annual report, monitors airport noise
exposure and noise violations, and
provides recommendations to the public
and Los Angeles County Airport Land
Use Commission (ALUC) for reducing
airport noise operations and improving
the management of noise at SMO. Based
on the most recent 2016 Annual
Operations Report, operations at SMO
resulted in three violations of the SMMC airport curfew regulations, and a total of 137 noise
violations (Appendix E).
Following a several-year-long lawsuit, the City and the Federal Aviation Administration (FAA)
entered into a 2017 consent decree which establishes that the FAA shall release its holdings at
3 Aircraft operations are defined as one departure, one arrival, one arrival associated with a closed pattern, or one
departure associated with a closed pattern.
Violations of SMO noise standards and the requirements of the
City Municipal Code most often result from the departure of
aircrafts during night departure curfews. Of the violations
reported for the airport, the majority related to exceedance of
noise standards are comprised by jet aircraft, resulting in a focus
on reducing the number of jet aircraft operations at SMO.
Airport Park Expansion Project 3.6-9
Final EIR – January 2018
3.6 NOISE
SMO to the City for the ultimate cessation of airport operations by December 31, 2028. In addition,
this consent decree establishes that the City, for the purpose of reducing annual airport operations
and eliminating louder single-event noise generators (i.e., jets, older aircrafts), may shorten the
runway by 1,473 feet to an operational length of 3,500 feet by December 7, 2017. Subsequently,
in June 2017, the City approved shortening the runway. Airport shortening is expected to be
complete by early 2018.
Noise Sensitive Land Uses
Some land uses are considered more sensitive to noise than others due to the amount of noise
exposure and the types of activities typically involved at the receptor location. Land uses identified
by the City of Santa Monica Municipal Code Chapter 4.12 as noise sensitive uses include hospitals,
and institutional uses such as schools, churches, museums, and libraries within 500 feet. The City
also considers residential uses to be noise sensitive receptors. The sensitive receptors nearest to
the Project site are listed below:
• Grand View Boulevard residential neighborhood, located east of the Project site across
South Bundy Drive — apartment buildings located at 3051 Grand View Boulevard and
single-family residences located along Grand View Avenue and side streets.
• Santa Monica College South Bundy Campus, 3171 South Bundy Drive, located southeast
of the Project site across Airport Avenue — a community college which provides
additional special classes for children and teens. The Santa Monica College South Bundy
Campus is located within the City of Los Angeles.
• Dewey Street residential neighborhood, located south of the Project site across Airport
Avenue — a residential street with single-family residences.
3.6.3 Regulatory Framework
Various standards have been developed to address the compatibility of land uses and noise levels.
The applicable standards are presented in the following discussion. Special emphasis is placed on
land uses that are considered to be sensitive to high noise levels. Typical sensitive receptors in the
City include residences, schools, childcare centers, hospitals, long-term health care facilities,
convalescent centers, and retirement homes.
3.6-10 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
Federal Regulations
Code of Federal Regulations
Title 14 of the Code of Federal Regulations (CFR) provides for the regulation of airport operations
and noise, as well as Airport Noise Compatibility Planning (CFR Title 14, Part 150). This section
provides for procedures, standards, and methodology governing the development of surrounding
uses of an airport, as well as the measurement and documentation of noise levels at an airport. As
provided in CFR Title 14 Section A150.101, parks are considered compatible within a CNEL of
up to 75 dBA.
State Policies and Regulations
California Public Utilities Code Sections 21670–21679 designate the power to regulate the orderly
development of California’s airports and surrounding areas to the counties. Regulatory authority
is the responsibility of an established ALUC. Public Utilities Code Section 21675 requires that
each County’s ALUC prepare a comprehensive land use plan for the orderly growth of each public
airport and the area surrounding the airport within the jurisdiction of the commission. The Los
Angeles ALUC and ALUP are discussed under regional policies below.
The Caltrans Division of Aeronautics is responsible for performing safety functions that are not
the FAA’s responsibility. The State Aeronautics Act, Public Utilities Code Section 21001 et seq.,
is the foundation for these policies. The Division of Aeronautics issues permits for and annually
inspects hospital heliports and public-use airports; makes recommendations regarding proposed
school sites within two miles of an airport runway; and authorizes helicopter landing sites at or
Noise sensitive land uses in the project vicinity include the residential neighborhood adjacent to the project site
across South Bundy Drive, including many units with balconies or patios facing directly toward the project site (left).
The Santa Monica College Bundy Campus provides community college courses and other educational amenities,
in addition to providing special classes for children and teens.
Source: Google Earth 2017.
Airport Park Expansion Project 3.6-11
Final EIR – January 2018
3.6 NOISE
near schools. The Division of Aeronautics also administers noise regulation and land use planning
laws that foster compatible land use around airports and encourages environmental mitigation
measures to lessen aircraft noise, air pollution, and other impacts caused by aviation. Further, the
Division of Aeronautics provides grants and loans at airports for safety, maintenance and capital
improvement projects.
In October 2011, the Caltrans Division of Aeronautics approved the current California Airport
Land Use Planning Handbook. The purpose of the Handbook is to provide guidance for conducting
airport land use compatibility planning as required by PUC, Article 3.5, Airport Land Use
Commissions. Article 3.5 outlines the statutory requirements for ALUCs including the preparation
of an ALUP. Article 3.5 mandates that the Division of Aeronautics create a Handbook that contains
the identification of essential elements for the preparation of an ALUP. This Handbook is intended
to (1) provide information to ALUCs, their staffs, airport proprietors, cities, counties, consultants,
and the public, (2) to identify the requirements and procedures for preparing effective
compatibility planning documents, and (3) define exemptions where applicable. The 2004 Los
Angeles County ALUP has not yet been revised to the 2011 Handbook, and is instead based on its
2002 predecessor.
Regional Policies and Regulations
Los Angeles County ALUP
In conformance with PUC, Article 3.5, the County of Los Angeles ALUC prepared and adopted
the Los Angeles County ALUP to coordinate land use planning for projects within any public use
airport boundary. The ALUP serves to protect the public health, safety, and welfare through
ensuring the appropriate development or expansion of airports and the establishment of regulations
for development of land uses when are compatible with airports. The ALUP has adopted planning
boundaries for each of the 14 general aviation and air carrier airports within its jurisdiction. The
ALUP establishes policies and programs applicable to all of these airports which related to land
use planning, noise, and safety. Consistent with Title 14 of the CFR, Section A150.101, the ALUP
considers recreational uses under 75 dBA CNEL as generally compatible with airport uses.
However, it should be noted that this standard conflicts with the City of Santa Monica and City of
Los Angeles noise compatible land uses, which indicate that recreational uses are normally
compatible or acceptable in areas with ambient noise levels less than 65 dB CNEL (see
Tables 3.6-5 and 3.6-6).
3.6-12 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
Local Policies and Regulations
City of Santa Monica Land Use and Circulation Element (LUCE)
Policies relating to noise were identified in the following goals of the LUCE:
Goal N1: Protect, preserve, and enhance the residential neighborhoods.
Policy N1.4. Preserve and protect existing neighborhoods against potential impacts related
to development, traffic, noise, air quality and encroachment of commercial activities.
City of Santa Monica General Plan – Noise Element
The Noise Element of the City of Santa Monica General Plan provides guidance about acceptable
noise levels based on the proposed land use. Based on these standards, which follow the State
guidelines outlined in Table 3.6-5, exterior noise levels of 60 dBA CNEL and lower are “clearly
compatible” for residential uses that include single family, duplex, and multiple family residences;
while exterior noise levels of up to 70 dBA CNEL are “compatible with mitigation.” Exterior noise
levels of 70 dBA CNEL and lower are “clearly compatible” for commercial retail; while exterior
noise levels up to 80 dBA CNEL are “compatible with mitigation”. For open space areas such as
City parks, exterior noise levels below 65 dBA CNEL are considered “clearly compatible”; while
exterior noise levels between 65-70 dBA CNEL are considered “compatible with mitigation” and
noise levels above 70 dBA CNEL are “normally incompatible”. “Clearly compatible” is defined
as the highest noise level that should be considered for the construction of new buildings that
incorporate conventional construction techniques, but without any special noise insulation
requirements. “Compatible with mitigation” includes the highest noise levels that should be
considered only after detailed analysis of the noise reduction requirements are made and needed
noise insulation features are determined. Within the Noise Element, typical mitigation strategies
for reducing noise levels to acceptable exterior and interior noise levels are through design and
construction of a noise barrier (e.g., wall, berm, or combination of the two) and establishment of
specific noise standards and criteria through the land use planning process for acceptable limits on
noise levels.
Airport Park Expansion Project 3.6-13
Final EIR – January 2018
3.6 NOISE
Table 3.6-5. City of Santa Monica Land Use/Noise Compatibility Matrix
Proposed Land Use Categories Compatible Land Use Zones (in CNEL)
Category Uses <60 60-
65
65-
70
70-
75
75-
80 >80
OPEN SPACE Parks A A B C D D
COMMERCIAL
Office Building, Research and
Development, Professional Offices,
City Office Building
A A B B C D
RESIDENTIAL Single Family, Duplex, Multiple
Family A B B C D D
ZONE A – Clearly Compatible: Specified land use is satisfactory, based upon the assumption that any buildings
involved are of normal conventional construction without any special noise insulation requirements.
ZONE B – Compatible with Mitigation: New construction or development (i.e., substantial remodels and
additions representing 50 percent or more of existing square footage, including garage square footage), should be
undertaken only after detailed analysis of the noise reduction requirements are made and needed noise insulation
features in the design are determined. Conventional construction, with closed windows and fresh air supply
systems on air conditioning, will normally suffice.
ZONE C – Normally Incompatible: New construction or development should generally be discouraged. If new
construction or development does proceed, a detailed analysis of noise reduction requirements must be made and
needed noise insulation features included in the design.
ZONE D – Clearly Incompatible: New construction or development should generally not be undertaken.
Source: City of Santa Monica 1992.
The Noise Element addresses the issue of noise by identifying sources of noise in the City and
providing objectives and policies that ensure that noise from various sources would not create an
unacceptable noise environment. The Noise Ordinance places limitations on noise produced by
equipment operation, human activities, and construction. The Noise Element policies and actions
that are relevant to the proposed projects are identified below.
Policy 1 Provide for measures to reduce noise impacts from transportation noise sources.
Action 1.2 Provide for continued evaluation of truck movements and routes in the City to
provide effective separation from residential or other noise sensitive land uses.
Policy 2 Incorporate noise considerations into land use planning decisions (as they apply to
finished projects, not construction actions).
Action 2.2 Through the Noise Ordinance, incorporate noise reduction features during site
planning to mitigate anticipated noise impacts on affected noise sensitive land uses. The
noise referral zones identified in Exhibits 6 and 7 (areas exposed to noise levels greater
than 60 dB CNEL) can be used to identify locations of potential conflict. New
developments would be permitted only if appropriate mitigation measures are included
such that the standards contained in this Element are met.
3.6-14 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
Policy 4 The City shall develop measures to control construction noise impacts.
Action 4.1 Consider incorporating provisions into the Noise Ordinance to address the
problems of construction noise:
• Clearly state the permitted hours of construction and expressly prohibit construction on
Sunday.
• During the environmental review of all projects requiring extensive construction,
determine the proximity of the site to the established residential areas. If the project
will involve pile-driving, nighttime truck hauling, blasting, 24-hour pumping
(important in coastal excavations), or any other very high noise equipment, the
environmental review shall include a construction noise alternative analysis. From this
analysis, specific mitigation measures shall be developed to mitigate potential noise
impacts. This may include but not be limited to:
o Requirements to use quieter albeit costlier construction techniques.
o Notification of residents (homeowners and renters) of time, duration, and location
of construction.
o Relocation of residents to hotels during noise construction periods.
o Developer reimbursement to City for 24-hour onsite inspection to verify
compliance with required mitigation.
o Limit hours of operation of equipment 15 dB above noise ordinance limits to the
hours of 10:00 A.M. to 4:00 P.M.
City of Santa Monica Municipal Code
SMMC Chapter 4.12 (Noise) includes limitations on unnecessary, excessive, and annoying noises
within the City. These limitations apply to uses within designated noise zones as identified by
zoning designation. Under Section 4.12.030, all activities conducted on public property that is
generally open to the public, including parks are exempt from the requirements and regulation of
Chapter 4.12 of the SMMC. In addition, this same section of the SMMC provides that all aircraft
activities and associated noises are exempted from the requirements and regulations of Chapter
4.12 and are instead regulated under Chapter 10.04 (Municipal Airport), Subchapter 10.04.04
(Aircraft Noise Abatement Code).
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Final EIR – January 2018
3.6 NOISE
Section 4.12.110 of the SMMC restricts the hours for construction activity to between 8:00 A.M.
to 6:00 P.M. on Mondays through Fridays and 9:00 A.M. to 5:00 P.M. on Saturdays, with some
exceptions for construction that the City deems to be in the public interest. Construction activity
is prohibited on Sundays and Holidays. This Section also sets limits for noise from construction
activities relative to the noise standards set in Section 4.12.060, with the equivalent noise level not
to exceed 20 dBA above standards and the maximum instantaneous noise level not to exceed
40 dBA above standards. Any construction exceeding this limit is required to occur between
10:00 A.M. and 3:00 P.M. Monday through Friday.
With regard to vibration, Section 4.12.070 of the SMMC prohibits any person to create, maintain
or cause any ground vibration that is perceptible without instruments at any point on any property.
The perception threshold shall be presumed to be more than 0.05 inches per second root-mean-
square velocity. The vibration caused by construction activity, moving vehicles, trains, and aircraft
is exempt from this section.
Santa Monica Aircraft Noise Abatement Code
The Santa Monica Aircraft Noise Abatement Code (SMMC Chapter 10.04.04) includes the
following subchapters which establish procedures and limitations on aircraft operations at SMO:
Subchapter 10.04.04.060 Maximum Noise Level: No aircraft shall exceed a Single Event
Noise Exposure Level (SENEL) or ninety-five (95) decibels as measured at the Airport
Noise Measuring Stations.
Subchapter 10.04.04.080 Hours of Operation: No aircraft shall be started, run-up, or depart
the Airport between the hours of 11:00 P.M. and 7:00 A.M. Mondays through Fridays nor
between 11:00 P.M. and 8:00 A.M. Saturdays and Sundays, except in case of bona fide
medical or public safety emergency, with the consent of the Airport Director or, in his or
her absence, the Watch Commander of the Police Department.
Subchapter 10.04.04.090 Restriction on Aircraft Operations: Touch-and-go, stop-and-go,
and low approaches are prohibited on weekends, holidays, and weekdays from one-half
hour after sunset until 7:00 A.M. the following day. This restriction shall not apply in
emergencies.
Subchapter 10.04.04.100 Helicopter Operations: Helicopter flight training operations at the
Airport are prohibited at all times.
3.6-16 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
City of Los Angeles General Plan – Noise Element
The City of Los Angeles General Plan Noise Element contains the below listed policies which may
apply to the Project and are intended to limit exposure of citizens to excessive, disruptive, or
nuisance noise levels.
Objective 2 (Nonairport) Reduce or eliminate nonairport related intrusive noise, especially
relative to noise sensitive uses.
Policy 2.2 Enforce and/or implement applicable city, state and federal regulations intended
to mitigate proposed noise producing activities, reduce intrusive noise and alleviate noise
that is deemed a public nuisance.
Objective 3 (Land Use Development) Reduce or eliminate noise impacts associated with proposed
development of land and changes in land use.
Policy 3.1 Develop land use policies and programs that will reduce or eliminate potential
and existing noise impacts.
City of Los Angeles Municipal Code (LAMC)
The City of Los Angeles Municipal Code (LAMC) Chapter XI (Noise Regulation) establishes the
noise standards and restrictions pertinent to ensuring the health and welfare of the citizens of the
As an aircraft approaches a noise receptor, the sound of the aircraft begins to rise above the threshold level. The
closer the aircraft gets, the louder it is until the aircraft is at its closest point directly overhead. As the aircraft passes,
the noise level decreases until the sound settles below the threshold level. Such a history of a flyover is plotted in
the graph below. The highest noise level reached during the flyover is called the “Maximum Noise level”, or LMax.
Referring to the same graph, the area within 10 dB of the LMax is the area from which the SENEL is computed. This
metric takes into account the maximum noise level and the duration of the event. The SENEL value is always higher
than the LMax value for aircraft events.
Source: Santa Monica Airport Calendar Year 2016 Annual Operations Report; Appendix E.
Airport Park Expansion Project 3.6-17
Final EIR – January 2018
3.6 NOISE
City of Los Angeles. Chapter XI of the LAMC establishes acceptable baseline ambient noise levels
for land uses within its jurisdiction. The noise regulations provided within this chapter of the
LAMC for noise compatible land uses establish that an increase in noise by 5 dBA over the existing
ambient noise level at the property boundary of an adjacent land use shall constitute a significant
noise effect in violation of the provisions of the City of Los Angeles Noise Regulations.
Section 112.05 of Chapter XI of the LAMC restricts the hours of operation of any powered
equipment or powered hand tools within any residential zone or within 500 feet of a residential
zone between the hours of 7:00 A.M. and 10:00 P.M. on or within the vicinity of such residential
zones, the maximum noise level of powered equipment or powered hand tools is not to exceed the
following noise levels at a distance of 50 feet from the source or such noise sources:
a) 75 dB(A) for construction, industrial, and agricultural machinery including crawler-
tractors, dozers, rotary drills and augers, loaders, power shovels, cranes, derricks, motor
graders, paving machines, off-highway trucks, ditchers, trenchers, compactors, scrapers,
wagons, pavement breakers, compressors and pneumatic or other powered equipment;
b) 75 dB(A) for powered equipment of 20 HP or less intended for infrequent use in residential
areas, including chain saws, log chippers and powered hand tools;
c) 65 dB(A) for powered equipment intended for repetitive use in residential areas, including
lawn mowers, backpack blowers, small lawn and garden tools and riding tractors.
Section 41.40 of Chapter IV (Public Welfare) of the LAMC restricts the hours for construction
activity to between 7:00 A.M. to 9:00 P.M. on any day (Section 41.40(a)), unless express written
permission has been provided for construction that the Executive Director of the Board of Police
Commissioners deems to be in the public interest (Section 41.40(b)). For construction activity
proposed on land that is developed with residential or hotel buildings or within 500 feet of land
developed with residential or hotel buildings, construction activities are restricted to the hours of
8:00 A.M. and 6:00 P.M. on any Saturday or national holiday (Section 41.40(c)). The provisions of
Section 41.40(c) prohibit construction activities on any Sunday.
The LAMC has established acceptable ambient noise levels for land uses within close proximity
to the Project site (see Table 3.6-6).
3.6-18 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
Table 3.6-6. City of Los Angeles Land Use/Noise Compatibility Matrix
Land Use Compatible Land Use Zones (in CNEL dB)
50 55 60 65 70 75 80
Residential Single-Family, Duplex,
Mobile Home A C C C N U U
Residential Multi-Family A A C C N U U
Sports Arena, Outdoor Spectator Sports C C C C C/U U U
Playground, Neighborhood Park A A A A/N N N/U U
Office Buildings, Business, Commercial,
Professional A A A A/N N N/U U
A – Normally Acceptable: Specified land use is satisfactory, based upon assumption buildings involved are
conventional construction, without any special noise insulation.
C – Conditionally Acceptable: New construction or development only after a detailed analysis of the noise
mitigation is made and needed noise insulation features included in project design. Conventional construction, but
with closed windows and fresh air supply systems or air conditioning will normally suffice.
N – Normally Unacceptable: New construction or development generally should be discouraged. A detailed
analysis of the noise reduction requirements must be made and noise insulation features included in the design of
a project.
U – Clearly Unacceptable: New construction or development generally should not be undertaken.
Source: City of Los Angeles 1999.
3.6.4 Impact Assessment and Methodology
Thresholds of Significance
Appendix G of the 2017 CEQA Guidelines provides a set of screening questions that address
impacts related to noise. Specifically, the Guidelines state that a proposed project may have a
significant adverse impact related to noise if:
a) The project would result in exposure of persons to or generation of noise levels in excess
of standards established in the local general plan or noise ordinance, or applicable standards
of other agencies;
b) The project would result in exposure of persons to or generation of excessive ground-borne
vibration or ground-borne noise levels;
c) The project would result in a substantial permanent increase in ambient noise levels in the
project vicinity above levels existing without the project;
d) The project would result in a substantial temporary or periodic increase in ambient noise
levels in the project vicinity above levels existing without the project;
Airport Park Expansion Project 3.6-19
Final EIR – January 2018
3.6 NOISE
e) For a project located within an airport land use plan or, where such a plan has not been
adopted within two miles of a public airport or public use airport, the project would expose
people residing or working in the project area to excessive noise levels; and/or
f) For a project within the vicinity of a private airstrip, the project would expose people
residing or working in the project area to excessive noise levels.
Non-Applicable Threshold(s) - Threshold (f) Project Within Vicinity of a Private Airstrip: The
Project site is immediately adjacent to and within the Airport Influence Area (AIA) for SMO,
which is a public airport owned and operated by the City. The Project site is not within the vicinity
of a private airstrip.
City of Santa Monica Construction Noise Levels
The City’s Noise Ordinance establishes noise standards which vary depending on the zone of the
Project site and the time period. The timing of construction noise impacts is an important factor in
determining significance. In any urban area, residents expect to periodically be exposed to
construction noise during normal working hours on weekdays and for more abbreviate periods on
Saturdays (and sometimes Sundays). As set forth in the previous discussion of the City’s Noise
Ordinance, construction activities are generally permissible only between 8:00 A.M. and 6:00 P.M.
on weekdays, and between 9:00 A.M. and 5:00 P.M. on Saturdays. During these hours, the City
permits construction noise up to 20 dBA in excess of normally acceptable levels, or up to 40 dBA
above normally acceptable levels for any “maximum instantaneous” noise event. Construction
noise beyond these heightened levels is only permitted between 10:00 A.M. and 3:00 P.M. on
weekdays. The City does not consider construction activities consistent with these timing limits to
constitute significant environmental effects.
City of Los Angeles Construction Noise Levels
The Project is located adjacent to and overlaps the jurisdiction of the City of Los Angeles. Given
the Project’s potential to generate noise levels from construction which may affect sensitive uses
within the City of Los Angeles, significant thresholds for construction noise from the City of Los
Angeles are considered in this analysis. The L.A. City CEQA Thresholds Guidelines include the
following thresholds for determining noise impacts associated with construction of a project.
Under the City of Los Angeles thresholds, a project would have a significant impact with regard
to construction noise if:
• Construction activities lasting more than one day would exceed existing ambient exterior
sound levels by 10 dBA or more at a noise-sensitive use;
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Final EIR – January 2018
3.6 NOISE
• Construction activities lasting more than 10 days in a three-month period would exceed
existing ambient noise levels by 5 dBA or more at a noise-sensitive use; or
• Construction activities of any duration would exceed the ambient noise levels by 5 dBA at
a noise-sensitive use between the hours of 9:00 P.M. and 7:00 A.M. Monday through Friday,
before 8:00 A.M. or after 6:00 P.M. on Saturday, or at any time on Sunday.
City of Santa Monica Operational Noise Levels
The CEQA Guidelines do not define the levels at which temporary and permanent increases in
ambient noise are considered “substantial”, as discussed in CEQA Appendix G. A noise level
increase of 3 dBA is barely perceptible to most people, a 5 dBA increase is readily noticeable, and
a difference of 10 dBA would be perceived as a doubling of loudness. However, as the existing
level of ambient noise increases, the allowable level of project-generated noise increases, but the
total amount that community noise exposure is allowed to increase is reduced. This accounts for
the unexpected circumstance wherein project noise exposure which is less than the existing noise
exposure can still cause an impact. As a result, and consistent with the thresholds used for the
LUCE Final Environmental Impact Report, the following noise thresholds are used with respect
to assessing operational roadway noise (Table 3.6-7).
Table 3.6-7. Interior and Exterior Noise Thresholds in the City of Santa Monica
Ambient Noise Levels Without Projects (Ldn or CNEL) Threshold (Ldn or CNEL)
< 60 dB + 5.0 dB or more
60–65 dB + 3.0 dB or more
> 65 dB + 1.5 dB or more
The justification for the above thresholds is that people already exposed to high noise levels would
notice and be annoyed by a small increase in the amount of noise in their community. In contrast,
if the existing noise levels are already low, a greater change in community noise would be required
for the equivalent level of annoyance.
City of Los Angeles Operational Noise Levels
As the Project is located partially within and adjacent to the City of Los Angeles, significant
thresholds for operational noise from the City of Los Angeles are considered in this analysis. Under
the L.A. City CEQA Thresholds Guide, a project would have a significant on noise levels from
project operation if:
Airport Park Expansion Project 3.6-21
Final EIR – January 2018
3.6 NOISE
• A project causes the ambient noise level measured at the property line of an affected use
to increase by 3 dBA or more in CNEL to or within the “normally unacceptable” or “clearly
unacceptable” category (see Table 3.6-8);
• A project causes the ambient noise levels measures at the property line of an affected noise-
sensitive use to increase by 5 dBA in CNEL or greater; or
• Project-related operation (i.e., non-roadway) noise sources such as outdoor building
mechanical/electrical equipment, outdoor activities, or parking facilities increase the
ambient noise level (Leq) at noise sensitive uses by 5 dBA.
Table 3.6-8. Noise Ranges of Typical Construction Equipment
Construction Equipment Noise Levels in dBA Leq at 50 Feet
Auger Drill Rig 80-85
Front Loader 73–86
Trucks 82–95
Cranes (moveable) 75–88
Cranes (derrick) 86–89
Vibrator 68–82
Saws 72–82
Pneumatic Impact Equipment 83–88
Jackhammers 81–98
Pumps 68–72
Generators 71–83
Compressors 75–87
Concrete Mixers 75–88
Concrete Pumps 81–85
Back Hoe 73–95
Tractor 77–98
Scraper/Grader 80–93
Paver 85–88
Note: Machinery equipped with noise control devices or other noise-reducing design features does not generate the same level of
noise emissions as that shown in this table.
Source: U.S. Department of Transportation 2006.
Vibration
The CEQA Guidelines do not define the levels at which ground-borne vibration or ground-borne
noise is considered “excessive.” For the purpose of this analysis, ground-borne vibration impacts
3.6-22 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
associated with human annoyance would be significant if the Project exceeds the threshold of 0.1
in/sec within 25 feet of any building. Per Caltrans, this threshold corresponds to the level at which
vibration can cause a “strongly perceptible” degree of human annoyance and has the potential to
cause structural damage in fragile buildings.
Methodology
The analysis of the existing and future noise environments is based on noise level monitoring,
noise prediction modeling, and empirical observations. Data for this section was based on a field
investigation to measure existing noise levels and a review of current noise standards and noise
assessment methodologies, including the City of Santa Monica Noise Element and the Federal
Transit Administration’s Transit Noise and Impact Assessment document. As defined by the
SMMC, noise sensitive land uses include schools, hospitals, and institutional uses such as
churches, museums, and libraries. The City also considers residential uses to be noise sensitive
receptors. The nearest sensitive receptors to the Project site include: apartments and single-family
residences along Grand View Boulevard located across South Bundy Drive and as close as 90 feet
north of the east end of the Project site and approximately 175 feet from the nearest proposed
sports field; single-family residences along Dewey Street, located approximately 250 feet to the
southeast end of the Project site and approximately 280 feet from the nearest proposed sports field;
and the Santa Monica College Bundy Campus, which is located approximately 390 feet south of
the Project site’s southern-most boundary and 490 feet from the nearest proposed sports field (see
Figure 3.6-1). These receptors are all in the immediate vicinity of the Project site; however, none
of them share the property line with the Project site.
Construction Noise Levels
Construction noise levels are estimated based on the Project’s anticipated construction equipment
inventory, estimated duration of construction, anticipated construction phasing distance, and
between the Project construction site and sensitive receptors.
Construction noise levels at on and offsite locations were estimated using data published by the
FHWA. The U.S. Department of Transportation has compiled data regarding the noise-generating
characteristics of typical construction activities.
These noise levels would diminish rapidly with distance from the construction site, at a rate of
approximately 6 dBA per doubling of distance as equipment is generally stationary or confined to
specific areas during construction. For example, a noise level of 86 dBA measured at 50 feet from
the noise source to the receptor would reduce to 80 dBA at 100 feet from the source to the receptor,
and reduce by another 6 dBA to 74 dBA at 200 feet from the source to the receptor. The noise
Airport Park Expansion Project 3.6-23
Final EIR – January 2018
3.6 NOISE
levels from construction at the offsite sensitive uses can be determined with the following equation
from the U.S. Department of Transportation (DOT) Transit Noise and Vibration Impact
Assessment, Final Report: Leq = Leq at 50 feet – 20 Log(D/50), where Leq = noise level of noise
source, D = distance from the noise source to the receiver, Leq at 50 feet = noise level of source at
50 feet.
Vibration Levels Associated with Construction Equipment
Ground-borne vibration levels resulting from construction activities occurring within the Project
vicinity were estimated using the 2013 Caltrans Transportation and Construction Vibration
Guidance Manual. Potential vibration levels are identified for on- and off-site locations that are
sensitive to vibration, including nearby residences. Caltrans provides thresholds of significance
for vibration and methodology for calculating vibration levels at distances from generation.
Vibration levels at the off-site sensitive uses were determined with the following equation:4
PPVProjected = PPVRef (25/D)n
Where: PPVRef = reference PPV at 25 feet; D = distance from equipment to the receiver in feet; n = 1.1 (a
recommended conservative value pertaining to attenuation rate of vibration through ground)
Operational Noise Levels
Ambient noise levels are based on the Santa Monica Airport 2016 CNEL Contour Study and
measured locations at the Project site and existing Airport Park (see Table 3.6-4). Because aircraft
noise and traffic is the primary component of the noise environment in in the Project vicinity, noise
contours established in this study and noise measured along Bundy Drive (Sites 8 and 9) are
indicative of existing airport operational noise and local roadway noise. Project-related roadway
noise was considered in terms of the increase in traffic noise related to the Project. Noise
measurements within sensitive neighborhood areas located adjacent to or within the Project
vicinity were not determined necessary as ambient noise levels within these areas are considered
to be highly characterized by existing airport operations and roadway traffic noise, similar to the
existing noise environment present at the Project site. To quantify the Project’s estimated effect
on traffic noise, the below analysis utilizes two separate approaches to estimate any increase in
traffic related-noise using the best-available data from the Transportation Impact Analysis,
including P.M. peak period traffic volumes at the 15 study intersections (as a representative data
point for roadway noise in the Project vicinity) and 24-hour traffic counts on six neighborhood
street segments.
4 Caltrans 2013, Transportation and Construction Vibration Guidance Manual, Equation 12.
3.6-24 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
To estimate the Project’s associated increase in traffic noise for roadway segments within the
Project vicinity, the analysis utilizes the P.M. peak intersection movements for the 15 studied
intersections in the Traffic Impact Analysis as representative data points for traffic noise on the
adjacent roadway segments, under Approval Year (2017) and Future Year (2025) traffic
conditions.5
To support and confirm any increase in noise estimated at the 15 study intersections during the
P.M. peak hour, the increase in noise levels along the six neighborhood street segments where 24-
hour traffic counts were collected for the Transportation Impact Analysis (Appendix F) was also
calculated using the U.S. Department of Housing and Urban Development Day/Night Noise Level
(DNL) Calculator.
The noise levels of park operations (e.g., games on the sports fields, crowd noise) was qualitatively
considered to determine its impact on nearby sensitive uses, and this EIR considers the increase in
noise from the development and operation of additional fields, which would add to the existing
noise environment and levels currently generated by existing Airport Park sports fields and
recreational amenities. Future park noise levels are typical of noise levels from sports field with
spectators; noise from sports field activities and events are estimated based on the existing 2002
Santa Monica Airport Park EIR.
3.6.5 Project Impacts and Mitigation Measures
Would the proposed project result in exposure of persons to or generation of noise levels in excess
of standards established in the local general plan or noise ordinance, or applicable standards of
other agencies?
Would the project result in a substantial temporary or periodic increase in ambient noise levels in
the project vicinity above levels existing without the project?
NOI-1 Construction of the Project would result in a temporary increase in ambient
noise levels in the Project vicinity. The Project would be required to comply
with SMMC regulations related to noise reduction. With mitigation,
construction noise impacts would be reduced to less than significant when
compared to City of Santa Monica thresholds, but would remain significant
and unavoidable when compared to City of Los Angeles thresholds.
5 Measured traffic volumes during the P.M. peak hour represents the highest volume of traffic that would occur throughout
the day, and the increase in traffic volumes and associated noise levels during this hour are used to represent the
maximum traffic-related noise levels experienced throughout the day.
Airport Park Expansion Project 3.6-25
Final EIR – January 2018
3.6 NOISE
Impact Description (NOI-1)
Construction of the Project would require demolition and removal of paved areas, aviation-related
structures, removal of vegetation and trees, realignment of the Donald Douglas Loop South, and
grading/excavation of an estimated 32,400 cubic yards of materials, followed by construction of
the new park facilities (i.e., sports fields), recreational amenities, and an acoustical sound berm.
The precise construction timeline for the Project depends on the timing of entitlements and permit
processing. For the purposes of this EIR, construction activity for the Project is assumed to begin
in 2019 with an estimated completion and opening of the expanded park to the public in 2020. The
existing Airport Park would remain open during Project construction, - although limited portions
of the park could close intermittently to accommodate the construction. The Project’s construction
activities and estimated durations are as follows:
• Demolition – 1 month
• Excavation and grading – 1–2 months
• Construction phase – 11–12 months
Consistent 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 A.M. to 6:00 P.M. on weekdays, 9:00 A.M. to 5:00 P.M. on
Saturdays, and no construction activities would be allowed on Sundays or public holidays. Work
outside of normal hours would require City approval of an after-hours construction permit.
Portions of the work may be performed outside of normal working hours when found to be in the
public interest (e.g., for safety reasons or to avoid road closures).
All phases of construction would involve the use of heavy equipment that would produce noise
(e.g., backhoes, loaders, heavy-duty trucks, cranes forklifts, concrete trucks). Construction
activities would also involve the use of smaller power tools, generators, and other equipment that
are sources of noise. Haul trucks using the local roadways would generate noise as they move
along the road. Each stage of 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. No pile driving would be necessary for construction. The estimated noise
levels to occur at nearby sensitive receptors during each phase of project construction are shown
in Table 3.6-9.
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Final EIR – January 2018
3.6 NOISE
Table 3.6-9. Estimated Peak Construction Outdoor Noise Levels at Sensitive Receptors
Construction
Activity
Existing Santa
Monica Airport
Park (50 feet;
dBA Leq)
Noise Level at
Residences East
of South Bundy
Drive (90 feet;
dBA Leq)
Noise Level at
Residences
south of Dewey
Street
(250 Feet; dBA
Leq)
Noise Level at
Santa Monica
College Bundy
Campus (390
Feet; dBA Leq)
Noise Level at
100 Feet; dBA
Leq
Demolition 98 93 84 80 92
Excavation/
Grading
98 93 84 80 92
Construction 88 83 74 70 82
Note: Noise levels at offsite sensitive uses were determined with the following equation from the DOT Transit Noise and
Vibration Impact Assessment, Final Report: Leq = Leq at 50 feet. – 20 Log(D/50), where Leq = noise level of noise source, D =
distance from the noise source to the receiver, Leq at 50 feet = noise level of source at 50 feet. Noise levels have been rounded up
to the nearest whole number.
Source: U.S. Environmental Protection Agency, Noise from Construction Equipment and Operations, Building Equipment and
Home Appliances (1971).
Per 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 open space areas and parks (which the Project
would develop) is set at 65 dBA and for residential uses is set at
60 dBA, thereby allowing for a maximum noise level of 85 dBA
within the City. During Project construction, maximum noise
levels could reach as high as 98 dBA at the existing Airport Park
and 93 dBA at the exterior of nearby residential uses during the
demolition and grading phases of the Project. Although
construction activities for the Project would generate noise
levels that may exceed the established exterior noise limit of
85 dBA for open space land uses, Section 4.12.110(d) of the
City’s Noise Ordinance states that construction noise levels
can exceed those standards discussed above so long as it
occurs between the hours of 10:00 A.M. and 3:00 P.M. Monday through Friday. MM NOI-1 would
require that the noisiest activities be limited to between the hours of 10:00 A.M. and 3:00 P.M.,
consistent with Section 4.12.110(d) of the City’s Noise Ordinance. In addition, under MM NOI-1,
the implementation of noise attenuation measures may include the use of noise barriers (e.g., sound
walls) or noise blankets. As a general rule, a sound wall is able to reduce noise by 5 dBA. In
addition, the requirement that construction staging areas and earthmoving equipment be located as
far away from noise and vibration-sensitive land uses as possible would also reduce construction-
Residents of homes and apartments
across South Bundy Drive would be
subject to varying levels of noise
throughout the duration of construction.
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3.6 NOISE
related noise levels. Further, MM NOI-1 would ensure that haul trucks associated with
construction activities are routed away from residences located along Dewey Street and adjacent
to South Bundy Drive/Centinela Avenue to the maximum extent feasible.
Further, the Project applicant would be required to comply with Section 4.12.110(c) of the Noise
Ordinance, which requires applicants of construction projects located within 500 feet of any
residential development, or other noise sensitive land uses, to submit a list of equipment and
construction activities prior to the issuance of a building permit. This list must include (1)
construction equipment to be used, such as pile drivers, jackhammers, pavement breakers, or
similar equipment; (2) construction activities such as 24-hour pumping, excavation or demolition;
and (3) a list of measures that will be implemented to minimize noise impacts on nearby residential
uses. When considering City’s thresholds for construction noise, compliance with existing City
noise regulations along with MM NOI-1 would reduce potential noise impacts to less than
significant with mitigation.
As stated above, the City of Los Angeles considers any construction activity that would exceed
existing ambient noise levels by 5 dBA or more at a sensitive receptor to result in a significant
noise impact. The residences across South Bundy Drive are in the City of Los Angeles. The Santa
Monica Airport 2016 CNEL Contour Study indicates that most of these residences are outside of
the 65 dBA CNEL for SMO (although jet fly-overs can generate higher noise levels). Additionally,
noise measurements along Bundy Drive (Sites 8 and 9) indicate that uses adjacent to South Bundy
Drive can experience ambient Leq noise levels of up to 71 dBA when airport and roadway noise
are combined. Thus, even with the noise attenuation measures implemented under MM NOI-1,
these residences could experience temporary construction-related noise levels of 88 dBA, which
is greater than 5 dBA above ambient noise levels. The highest noise levels would occur during
construction along the Project site’s eastern boundary, primarily from construction of the proposed
noise berm/wall, which involves earthmoving equipment. Construction noise levels would
decrease rapidly as construction activities moves toward the center of the Project site. Nonetheless,
even with the implementation of identified mitigation measures, noise impacts to the residences
along South Bundy Drive are conservatively considered to be significant and unavoidable when
compared against City of Los Angeles thresholds.
Mitigation Measures
To further reduce the noise levels resulting from construction of the Project for off-site sensitive
uses, the following mitigation measures would be implemented:
3.6-28 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
MM NOI-1 A Construction Noise Management Plan shall be implemented during Project
construction. The Plan would address noise and vibration impacts and outline
measures that would be used to reduce impacts. Measures would include:
• To the extent that they exceed the applicable construction noise limits,
excavation, foundation-laying, and conditioning activities shall be restricted to
between the hours of 10:00 AM and 3:00 PM, Monday through Friday, in
accordance with Section 4.12.110(d) of the Santa Monica Municipal Code.
• The construction contracts shall require implementation of the following
construction best management practices (BMPs) by all construction
contractors and subcontractors working in or around the Project site to reduce
construction noise levels:
o Contractors and subcontractors shall ensure that construction equipment is
properly muffled according to manufactures specifications or as required
by the City’s Department of Building and Safety, whichever is the more
stringent.
o Contractors and subcontractors shall place noise-generating construction
equipment and locate construction staging areas away from sensitive uses,
where feasible, to the satisfaction of the Department of Building and Safety.
o Contractors and subcontractors shall implement noise attenuation
measures which may include, but are not limited to, noise barriers or noise
blankets to the satisfaction of the City’s Department of Building and Safety.
• Contracts with its construction contractors and subcontractors shall include
the requirement that construction staging areas, construction worker parking
and the operation of earthmoving equipment within the project site, are located
as far away from vibration- and noise-sensitive sites as possible. Contract
provisions incorporating the above requirements shall be included as part of
the project’s construction documents.
• Contract specifications shall instruct that heavily loaded trucks used during
construction shall be routed away from residential streets to the extent possible.
Contract specifications shall be included in the Project’s construction
documents.
Airport Park Expansion Project 3.6-29
Final EIR – January 2018
3.6 NOISE
Residual Impact
Compliance with the City’s Noise Ordinance in conjunction with implementation of MM NOI-1
would reduce construction noise impacts resulting from the Project to less than significant.
However, there is no guarantee that implementation of MM NOI-1 would reduce construction
noise at residences across South Bundy Drive to below the City of Los Angeles’ adopted
construction noise thresholds. Therefore, when considering City of Los Angeles noise thresholds,
impacts of the Project would remain significant and unavoidable.
Would the proposed project result in exposure of persons to or generation of excessive ground-
borne vibration or ground-borne noise levels?
NOI-2 Construction of the Project would require the use of equipment that would
temporarily generate ground-borne vibration. Ground-borne vibration would
not occur at levels that would expose sensitive receptors to excess construction
vibration or potentially damage nearby buildings. Impacts would be less than
significant.
Impact Description (NOI-2)
Construction of the Project would occur in phases that would include demolition, grading and
excavation, and construction. During construction, ground-borne vibration would be generated
from various types of construction equipment such as drillers, loaders, jack hammers, and
bulldozers. No pile driving would be necessary to construct the Project.
Table 3.6-10. Estimated Peak Construction Vibration Levels at Sensitive Receptors
Construction
Activity
Vibration Level at
25 feet; in/sec
Vibration Level at
50 Feet; in/sec
Vibration Level at
100 Feet; in/sec
Caisson Drilling 0.089 0.042 0.019
Loaded Trucks 0.076 0.035 0.017
Jackhammer 0.035 0.016 0.008
Small Bulldozer 0.003 0.001 0.001
1 Source: Caltrans 2013. Transportation and Construction Vibration Guidance Manual – Table 18.
Periods of high vibration levels would occur primarily during demolition, excavation, and
construction of the sound berm and site foundation. Vibration levels would decrease as the distance
between the vibration source and the receptor increases, and would vary depending on the soil
type, ground strata, and construction characteristics of the sensitive receptor buildings.
3.6-30 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
There are no fragile historic structures in close proximity to the Project site that could be affected
by construction vibration. Ground-borne vibration from construction activities could potentially
be felt by surrounding sensitive uses, which include existing multi-family and single-family
residences east of South Bundy Drive and south of Dewey Street. However, vibration levels at
nearby sensitive receptors would be well below the threshold of 0.1 in/sec at all adjacent uses.
Furthermore, Section 4.12.070, Vibration, of the City’s Noise Ordinance states that vibration
caused by construction activity, moving vehicles, trains, and aircraft shall be exempt from the
restrictions set forth in the SMMC. Therefore, ground-borne vibration impacts would be less than
significant.
Would the proposed project result in a substantial permanent increase in ambient noise levels in
the project vicinity above existing levels without the project?
NOI-3 Operation of the Project could result in increased traffic noise. The Project
would also increase noise generated at Airport Park from sporting events and
crowds. However, operational impacts from increased noise levels would be less
than significant.
Impact Description (NOI-3)
Traffic Noise
Operation of the Project would generate new vehicle trips in the Project vicinity, contributing to
ambient noise levels from vehicle and roadway noise within the area. As discussed in Section
3.6.4, Impact Assessment and Methodology above, the change in roadway noise levels resulting
from the Project is calculated based on data provided in the Project’s Transportation Impact
Analysis (Appendix F) for the 15 study intersections during the P.M. peak period and six
neighborhood street segments during a 24-hour period.
The Transportation Impact Analysis concluded that Project traffic would increase the volume of
intersection traffic at the 15 study intersections during the P.M. peak period by as little as 1.4
percent and as high as 8.8 percent at the busiest intersection (future Intersection No. 13B, Donald
Douglas Loop South/Airport Avenue). The Project’s contribution to roadway traffic and related
noise would be higher in the immediate vicinity of the Project site and decrease as vehicles disperse
throughout the roadway network.
The values in Table 3.6-11 represents the increase in traffic noise levels attributable to the Project.
Based on the increase in traffic through a given intersection under Approval Year (2017) Plus Project
conditions, noise levels at study intersections are anticipated to increase by as much as 0.37 dB at
Airport Park Expansion Project 3.6-31
Final EIR – January 2018
3.6 NOISE
the relocated Donald Douglas Loop South/Airport Avenue intersection, as shown in Table 3.6-11.
Given the low noise level increases anticipated from new vehicle trips, the Project would result in a
negligible increase in traffic noise perceived from nearby residences, with the highest increase
occurring to residences along South Bundy Drive (+0.14 dB at the intersection of South Bundy Drive
and Airport Avenue). While this data is representative only of conditions during the P.M. peak hour,
the Project-related increase in traffic is expected to be less throughout other portions of the day
because the park is expected to experience its heaviest use during the afternoon period. Therefore,
sensitive uses in the Project vicinity would experience a negligible increase in Project-related traffic
noise that would be well below the thresholds of 1.5 dBA to 3 dBA CNEL under Approval Year
(2017) Plus Project conditions.
In addition, Table 3.6-11 provides the Project-related change in noise levels at these intersections
in 2025 under “Future Year Plus Project” conditions to infer the increase in traffic noise levels that
would occur on adjacent streets as a result of implementation of the Project and future cumulative
projects within the Project vicinity (refer to Table 3.0-1; Appendix F). Under future 2025
conditions, noise levels at study intersections are anticipated to increase by as much as 0.52 dB at
the relocated Donald Douglas Loop South/Airport Avenue intersection, due to an increase in
intersection traffic volumes at this intersection. Given this negligible noise increase and further
insignificant increases in noise at other studied intersections, cumulative increases in noise from
traffic would not exceed adopted City thresholds.
In addition to the P.M. peak period traffic volumes at the 15 study intersections, the Traffic Impact
Analysis conducted 24-hour vehicle counts for six street segments within the nearby
neighborhoods. The calculated increase in CNEL noise levels from Project-related traffic traveling
along these streets confirms the P.M. peak hour trip calculations at the 15 study intersections. Based
on existing roadway noise levels and modeled Approval Year (2017) Plus Project conditions, the
Project is anticipated to result in an increase in roadway noise along these street segments by as
low as 0.1 dBA CNEL along 23rd Street and Walgrove Avenue, with a maximum projected
increase in ambient roadway noise of 0.6 dBA CNEL along Dewey Street (Table 3.6-12).
Therefore, noise impacts from vehicle trips generated by the proposed Project would be less than
significant.
3.6-32 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
Table 3.6-11. Noise Increase from Project-Related Traffic at Study Intersections During the P.M. Peak Hour
In
t
e
r
s
e
c
t
i
o
n
No
.
1 North/South
Street Name
East/East Street
Name
Project-Related
Increase in Traffic
Volume Under
Approval Year (2017)
Plus Project (Vehicles
[% of total])
Project-Related
Increase in Traffic
Noise Under
Approval Year (2017)
Plus Project (dB, Leq)
Increase in Traffic
Volume Under Future
Year (2025) Plus
Project (Vehicles [%
of total])
Increase in Traffic
Noise Under Future
Year (2025) Plus
Project (dB, Leq)
1 Cloverfield Blvd I-10 WB Off-Ramp 73 (1.9%) 0.08 83 (2.2%) 0.09
2 Cloverfield Blvd I-10 EB On-Ramp 65 (2.4%) 0.10 80 (3.0%) 0.13
3 Cloverfield Blvd Pico Blvd 174 (4.6%) 0.20 209 (5.8%) 0.24
4 Cloverfield Blvd Ocean Park Blvd - 0.00 20 (1.2%) 0.05
5 23rd St Ocean Park Blvd 43 (1.8%) 0.08 78 (3.3%) 0.14
6 23rd St Dewey St 34 (1.7%) 0.07 54 (2.7%) 0.12
7 23rd St Airport Ave 41 (1.8%) 0.08 71 (3.2%) 0.14
8 Walgrove Ave Rose Ave 40 (1.6%) 0.07 90 (3.6%) 0.16
9 Centinela Ave Ocean Park Blvd 43 (1.5%) 0.06 93 (3.2%) 0.14
10 South Bundy Dr Ocean Park Blvd 122 (2.4%) 0.10 207 (4.1%) 0.17
11 South Bundy Dr National Blvd 98 (2.3%) 0.10 153 (3.6%) 0.15
12 Centinela Ave Airport Ave 129 (3.2%) 0.14 184 (4.6%) 0.20
13A1 Donald Douglas
Loop S (existing) Airport Ave - - - -
13B Donald Douglas
Loop S (relocated) Airport Ave 47 (8.8%) 0.37 67 (12.8%) 0.52
14 Centinela Ave Rose Ave 92 (2.5%) 0.11 162 (4.5%) 0.19
15 Centinela Ave Palms Blvd 66 (1.6%) 0.07 141 (3.4%) 0.15
1Increases in intersection volumes and associated noise levels for Intersection 13A not provided, as this intersection would be relocated approximately 485 feet south, becoming
Intersection.
Source: Appendix F; Transportation Impact Analysis (Appendix F).
Airport Park Expansion Project 3.6-33
Final EIR – January 2018
3.6 NOISE
Table 3.6-12. Noise Impacts from Project-related Traffic on Neighborhood Street
Segments
Segment
Increase in Traffic Volume Under
Approval Year (2017) Plus
Project (Vehicles [% of total])
Net change in dBA CNEL (2017)
23rd Street n/o Dewey Street 32 (0.1%) 0.1
Dewey Street w/o 23rd Street 47 (0.9%) 0.6
Walgrove Avenue s/o Airport
Avenue
96 (0.3%) 0.2
Rose Avenue w/o Walgrove
Avenue
34 (0.2%) 0.2
Rose Avenue e/o Walgrove Avenue 26 (0.2%) 0.2
Walgrove Avenue s/o Rose Avenue 35 (0.2%) 0.1
Source: Transportation Impact Analysis (Appendix F).
Park Noise
Operation of the Project with its additional sports fields and playgrounds would contribute new
sources of noise that would incrementally increase noise levels during the park’s operational hours.
While the existing Airport Park already generates noise sources typical of parks, such as children
playing, crowds cheering, and dogs barking, an incremental increase in noise sources would result
from the new park activities and programs, such as sports events, sports practice, picnics,
celebrations, and active play. The modifications and uses proposed as part of the Project include a
range of active and passive recreational amenities which would generate varying levels of noise,
the loudest of which are likely to result from sports events and games held on the proposed
synthetic turf sports fields (an area that is currently vacant and the former location of airplane tie-
downs). These events concentrate visitors into the area and can involve amplification of
announcements and music along with cheering from spectators. However, anticipated increases in
operational noise levels from such uses and activities are not expected to substantially increase
ambient noise levels, and uses would be consistent with that of the existing Santa Monica Airport
Park. As such, and given that park and recreational land uses are not considered sensitive receptors
to noise, operation of the Project would not generate noise which would affect users of the existing
Airport Park.
Despite the Project’s compatibility under the SMMC and CFR standards, and exemption from City
noise regulations per SMMC Chapter 4.12.030, Exemptions, park activities would have a
reasonable likelihood to generate noise which could be perceptible at nearby sensitive land uses,
including residences and educational uses. Types of noise generated by the park would be
3.6-34 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
potentially perceived as nuisance noise. The greatest noise levels generated by park activities
would come from sports events, in which spectators rather than players would generate the
majority of noise. In such case, a single shouting person can generate a noise level of
approximately 80-90 dBA from a distance of 3 feet (ACOUSTICS 2011), while a crowd of 20
screaming people can generate a noise level of approximately 69 dBA at a distance of 50 feet
(Culbertson, Adams & Associates, Inc. 2002). Use of a public address system can require six to
10 dB more than crowd noise to perform adequately during a sporting event, though this peak
noise level is infrequent and avoidable when the public address system is offset from peak crowd
noise. Given these factors, when considering the east sports field in combination with noise
generated at the existing park, maximum intermittent noise levels perceptible at the residences
located approximately 180 feet to the north and across South Bundy Drive from events at the
proposed east sports fields are not expected to exceed a maximum of 58 dBA, which is within the
acceptable noise levels for residential uses within the both the City of Santa Monica and City of
Los Angeles. For sports fields located farther to the west, noise levels experienced at the residences
across South Bundy Drive and Airport Avenue would be less than at the east sports field due to
the greater distance between the noise source and noise receptor.
The most prominent operational noise levels would be limited to the duration of the sports events
at the east sports field, and would be loudest at times in which the crowd is cheering, which would
occur at random intervals throughout the duration of the event and last only a few seconds or
moments at a time. Nuisance noise may also be generated and perceived following the end of such
events, when members of the crowd or sports team begin to disperse, in which generated noise
would again be temporary and unlikely to exceed standard exterior noise levels for residential uses.
Additionally, the estimated noise levels experienced by residences is conservative in that it does
not consider the proposed acoustical berm along the northeast corner of the Project, which would
serve to reduce roadway noise levels from South Bundy Drive at the park, as well as reduce noise
generated at the park on residences east of South Bundy Drive. Given that maximum noise levels
from park activities would be below 60 dB at the nearest sensitive uses and that such noise would
be temporary and sporadic, the Project would not cause a substantial increase in noise or generate
substantial nuisance noise and impacts are considered less than significant.
Airport Park Expansion Project 3.6-35
Final EIR – January 2018
3.6 NOISE
For a project located within an airport land use plan or, where such a plan has not been adopted
within two miles of a public airport or public use airport, the project would expose people residing
or working in the project area to excessive noise levels?
NOI-4 The Project would introduce new recreational land uses and visitors to an area
within the SMO AIA and could expose visitors and park goers to excessive
airport noise levels generated by SMO. However, impacts would be less than
significant.
Impact Description (NOI-4)
The Project would expand existing Airport Park by redeveloping paved surface areas and aviation-
related facilities within the SMO AIA with active and passive recreational amenities. All facilities
to be developed by the Project would be located within the AIA (see Figure 3.7-1), and as
previously discussed, would experience noise from airport operations. To minimize exposure of
park visitors to excessive airport noise, the Project has been designed to locate park facilities and
amenities where people would recreate outside of the 65 dB CNEL noise contour for the airport;
only portions of the proposed parking lot would be located within the 65 dB CNEL noise contour.
As the Project would locate recreational uses outside of the SMO’s 65 dB CNEL noise contour,
the Project would be consistent with the Los Angeles County ALUP, which defers regulations for
noise compatible land uses to Title 14 Section 150 of the CFR, which finds recreational uses as
compatible with airport uses; however, as previously discussed, the City noise standard for open
space and recreational uses is more restrictive than CFR standards. In addition, the location of the
65 dB CNEL Noise Contour means that park uses at the Project site are considered clearly
compatible with open space and recreational areas under the SMMC (Table 3.6-5). Furthermore,
the Project’s proposed acoustical sound berm would screen the park from runway and roadway
noise, thus further reducing noise levels from airport operations at the Project site when compared
to existing conditions and screening sensitive uses to the northeast from exposure to noise
generated by park operations.
As previously discussed, SMO currently plans to shorten the total length of Runway 3/21 from the
current 4,973 feet to 3,500 feet in early 2018 as part of the February 2017 Consent Decree between
the City and the FAA. Implementation of this action is estimated to reduce jet aircraft operations
by approximately 44 percent. As such, there would be a reduction in noise levels from aircraft
take-offs and landings when compared to existing conditions, particularly from jet aircrafts which
constitute the greatest number of airport noise violations. When compared to existing conditions,
implementation of the runway shortening project could reduce the ambient noise level by 0.2 dBA
3.6-36 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
CNEL to 4.5 dBA CNEL at locations within or near residential neighborhoods both to the east and
west of the airport (AECOM 2017). As such, the 65 dB CNEL contour would be expected to move
further towards the runway and create a larger area in the Project vicinity that is considered to be
clearly compatible for park and open space uses by the SMMC.
Given the compatibility of both the existing and proposed park uses with operational noise from
SMO, reductions in SMO noise exposure from development of the proposed acoustical sound
berm, and anticipated reductions in ambient noise levels from runway shortening, implementation
of the proposed Project would not expose users and visitors of the site to excessive noise levels.
Impacts are therefore considered less than significant.
Cumulative Impacts
Cumulative Construction Impacts
Would the proposed project result in exposure of persons to or generation of noise levels in excess
of standards established in the local general plan or noise ordinance, or applicable standards of
other agencies?
Would the project result in a substantial temporary or periodic increase in ambient noise levels in
the project vicinity above levels existing without the project?
Construction of the Project would potentially overlap with other future projects in the immediate
vicinity. It should be noted that the City has limited control over the timing or sequencing of future
development projects that may occur within the immediate vicinity of the Project site. Therefore,
any quantitative analysis that assumes multiple, concurrent construction projects would be entirely
speculative. Construction-period noise and ground-borne vibration for the Project and each future
development project (that has not yet been approved or built) would be localized.
Based on a review of Table 3.0-1, Pending, Approved, and Recently Constructed Projects in the
City of Santa Monica, there is one pending project in immediate proximity to the Project site that
would be likely to result in temporary cumulative increases in noise levels and ground-borne
vibration levels at the same sensitive receptors: the Airport Avenue Improvement Project (Project
No. A) (see Table 3.0-1; refer also to Figure 3.0-1). All other cumulative projects are too distant
from the Project site to result in cumulative noise impacts or are being completed with the
expressed goal of reducing noise levels in the Project vicinity. Since it is the intent of the City to
develop these two separate projects at the same time in order to minimize disruptions and develop
a cohesive set of improvements along Airport Avenue, it is expected that construction of this
related project would overlap with Project construction. During the time that these cumulative
Airport Park Expansion Project 3.6-37
Final EIR – January 2018
3.6 NOISE
projects are being constructed, the Project vicinity would experience increases in daytime noise
levels. Like the Project, it is assumed that construction of the Airport Avenue Improvement Project
would be limited to daytime hours, consistent with SMMC restrictions.
The contribution of the Project to the cumulative noise environment would occur during
demolition and removal of paved areas, realignment of the Donald Douglas Loop South, and
grading/excavation of an estimated 32,400 cubic yards followed by construction of the proposed
park facilities, recreational amenities, and the acoustical sound berm. Construction activities would
be limited to an approximately 12-month period. As noted above, with MM NOI-1, the Project’s
contribution to cumulative construction impacts are less than significant when compared to City
of Santa Monica thresholds and significant and unavoidable when compared to City of Los
Angeles thresholds. It is reasonable to assume that the simultaneous construction of these two
projects would generate noise levels that are higher than the noise levels generated by the
independent construction of each of the projects. Even so, because the City of Santa Monica allows
for construction noise to exceed ambient noise levels by 20 dBA from 10:00 A.M. to 3:00 P.M.,
impacts are expected to remain less than significant when compared to City of Santa Monica
thresholds. However, as construction of the Project alone would exceed ambient noise levels by
more than 5 dBA at the residences across South Bundy Drive, impacts would continue to be
significant and unavoidable when compared to City of Los Angeles thresholds. Because the
Airport Avenue Improvement Project extends from South Bundy Drive east to 23rd Street, the
City has options to further reduce cumulative noise impacts on sensitive receptors, such as phasing
construction of the two projects so that construction activities do not occur in the same area
simultaneously.
Would the proposed project result in exposure of persons to or generation of excessive ground-
borne vibration or ground-borne noise levels?
As previously stated, ground-borne vibration levels would decrease as the distance between the
vibration source and the receptor increases. Thus, potential vibration impacts due to construction
would be limited to the vicinity around a construction site. The Airport Avenue Improvement
Project (Project No. A) (see Table 3.0-1; refer also to Figure 3.0-1) is the only cumulative project
in immediate proximity to the Project site that would likely result in temporary cumulative
increases in ground-borne vibration levels at the same sensitive receptors. All other cumulative
projects are too distant from the Project site to result in cumulative vibration impacts. The Project’s
vibration levels at nearby sensitive receptors would be well below the threshold of 0.1 in/sec at all
adjacent uses. As further discussed under Impact NOI-2, above, there are no fragile historic
structures in close proximity to the area of the Project or applicable cumulative project sites that
3.6-38 Airport Park Expansion Project
Final EIR – January 2018
3.6 NOISE
could be affected by construction vibration. Cumulative ground-borne vibration from concurrent
construction activities could potentially be felt by surrounding sensitive uses. However,
Section 4.12.070, Vibration, of the City’s Noise Ordinance states that vibration caused by
construction activity, moving vehicles, trains, and aircraft shall be exempt from the restrictions set
forth in the SMMC. Therefore, impacts from cumulative construction projects and associated
ground-borne vibrations would be less than significant.
Would the proposed project result in a substantial permanent increase in ambient noise levels in
the project vicinity above existing levels without the project?
Cumulative Operational Impacts
Cumulative noise impacts would occur primarily as a result of increased traffic on local roadways
due to the Project and the proposed Airport Avenue Improvement Project. Cumulative traffic-
generated noise impacts have been assessed based on the difference between existing roadway
noise levels and future noise levels with the Project and cumulative development. The noise levels
associated anticipated increases in traffic noise under future (2025) conditions include all
development projects to occur by 2025 and inherently consider cumulative impacts, which are
identified in Table 3.6-11. However, the only cumulatively considered project within the
immediate Project vicinity which is anticipated to contribute towards cumulative noise impacts is
the Airport Avenue Improvement Project. Given the Project’s incremental increase in traffic
volumes and minimal amount of proposed future development within the area, anticipated
increases in traffic volumes within the vicinity of the Project are expected to result in a maximum
increase in noise levels by an estimated 0.52 dB at the relocated Donald Douglas Loop
South/Airport Avenue intersection (Intersection No. 13B), an increase which is
inaudible/imperceptible to most people and would not exceed the City of Santa Monica or City of
Los Angeles thresholds of significance. Further, operation of the Airport Avenue Improvement
Project would not involve additional noise beyond roadway noise, as it is a transportation
infrastructure project to improve mobility and access and would not introduce new land uses.
Overall, cumulative operational noise levels would be maintained at acceptable levels and impacts
would be less than significant.
Airport Park Expansion Project 3.6-39
Final EIR – January 2018
3.6 NOISE
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3.6-40 Airport Park Expansion Project
Final EIR – January 2018
Airport Park Expansion Project 3.7-1
Final EIR – January 2018
3.7 TRANSPORTATION AND TRAFFIC
This section analyzes the potential environmental effects of the Project on transportation and
traffic. This section was prepared based on the Santa Monica Airport Park Expansion
Transportation Impact Analysis (Transportation Impact Analysis) prepared by Fehr & Peers
Transportation Consultants (Fehr & Peers 2017) (refer to Appendix F). The Transportation Impact
Analysis contains detailed analyses of local traffic circulation issues, including potential increases
in congestion at intersections and neighborhood street segments in the Project vicinity, within the
City of Santa Monica (City) and the City of Los Angeles. This analysis also addresses potential
impacts on regional transportation facilities, particularly at access points to Interstate 10 (I-10)
(also known as the Santa Monica Freeway), and alternative modes of transportation, including
public transit, pedestrian, and bicycle impacts that could result from operation of the Project.
3.7.1 Environmental Setting
Regional Highway and Street System
Regional access to the Project site is provided by I-10 and the San Diego Freeway (I-405). I-10 is
located approximately 0.75 miles north of the Project site and provides east/west access across the
City, from the Pacific Coast Highway (PCH) to the west to the City of Los Angeles to the east.
The I-10 connects to the I-405 at the I-10/I-405 interchange, located approximately one mile
northeast of the Project site. I-10 freeway access nearest to the Project site is available via
interchanges at Cloverfield Boulevard, Centinela Avenue, and South Bundy Drive. The I-405 is
located approximately 1 mile east of the Project site and provides north-south access throughout
the west Los Angeles Basin. The I-405 freeway access nearest to the Project site is available via a
northbound off-ramp and southbound on-ramp at National Boulevard.
Local Street Network in Project Vicinity
The Project site is situated on Santa Monica Municipal Airport (SMO) property at the southeast
corner of the City (Figure 3.7-1). The Project site is bordered by the aviation-uses of SMO to the
north, South Bundy Drive to the east, the existing Airport Park and Airport Avenue to the south,
and the Barker Hangar event venue to the west. The Project site is located at the northwest corner
of Airport Avenue and South Bundy Drive, with approximately 520 feet of Project site frontage
along South Bundy Drive (not including existing Airport Park, which has approximately 200 feet
of frontage along South Bundy Drive) and 550 feet along Airport Avenue (not including existing
Airport Park, which has approximately 1,200 feet of frontage along Airport Avenue). Access to
the Project site is available via the existing Donald Douglas Loop South roadway. Donald Douglas
3.7 TRANSPORTATION AND TRAFFIC
3.7-2 Airport Park Expansion Project
Final EIR – January 2018
Loop South is a two-lane street. South
Bundy Drive is a four-lane street, and
Airport Avenue is a two-lane street. The
intersection of Airport Avenue and South
Bundy Drive is signalized with left-turn
pockets and pedestrian crosswalks. The
intersection of Airport Avenue and
Donald Douglas Loop South is served by
a four-way stop with pedestrian
crosswalks. Currently, there are no
dedicated left-turn lanes on Airport
Avenue at the intersection of Donald
Douglas Loop South. Airport Avenue
east of Donald Douglas Loop South is
lined with landscaping, including trees and large palms and supports public sidewalks on both
sides. The portion of Airport Avenue west of Donald Douglas Loop South—where the Project
site’s west paved surface area fronts Airport Avenue—is void of landscaping and does not provide
a formal sidewalk, although a wide area of pavement used for vehicle parking can accommodate
pedestrian movement. Airport Avenue is a minor east/west street providing direct access to the
southern parking lot for the existing Airport Park, running east from 23rd Street & Walgrove
Avenue to South Bundy Drive. The narrow road provides one travel lane in each direction with no
on-street parking and no center-turn lane.
South Bundy Drive is a four-lane primary north/south roadway that provides surface street access
to the Project site from the east. Bundy Drive intersects with I-10 less than one mile north of the
Project site. Immediately south of Airport Avenue, South Bundy Drive becomes Centinela
Avenue.
Donald Douglas Loop South is a two-lane access road that intersects with Airport Avenue and
provides vehicular access to the existing park’s northern 58-space parking lot, to the SMO
Administration Building, and to the airport itself. The road provides a sidewalk on the east side
and is landscaped with large palm trees and provides one lane of travel in each direction with no
on-street parking. Donald Douglas Loop South leads to the airfield and is gated just beyond the
existing Airport Park parking lot, restricting access to this area for official vehicles only.
Airport Avenue is a minor east/west two-lane street which
provides access to the Project site via Donald Douglas Loop.
Shown here is the Airport Avenue’s intersection with Donald
Douglas Loop South.
F
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LEGEND Bus Transit Bicycle FacilitiesBig Blue Bus Line and Number Bus Stop#bSanta Monica Airport Existing Santa Monica Airport Park Project Site School Fire Station Neighborhood Boundary Park City of Santa Monica City of Los Angeles Breeze Bike Share Hub Bike Parking Class 2 Bike Lane Class 3 Bike LaneF0800SCALE IN FEET N 3.7-1FIGURE
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3.7-3
3.7 TRANSPORTATION AND TRAFFIC
3.7-4 Airport Park Expansion Project
Final EIR – January 2018
City Circulation Element Street Classifications
The City of Santa Monica General Plan Land Use and Circulation Element (LUCE) categorizes
the City’s street system according to its use by various modes, such as walking, biking, transit, and
automobile (City of Santa Monica 2010). These street categories include Boulevard, Special
Streets, Downtown Commercial, Neighborhood Commercial, Major Avenue, Secondary Avenue,
Minor Avenue, Industrial Avenue, Neighborhood Street, Shared Street, Parkway, Pathway,
Bikeway, Highway, and Alley. City streets in the Project vicinity are described below, as
categorized by the Santa Monica LUCE:
Boulevard – Boulevards are regional transportation corridors with continuous mixed use and
commercial land uses. Boulevards provide access for all forms of transportation but emphasize
transit and walking. Regional auto traffic is accommodated here in order to minimize regional
traffic on parallel local streets. Pico Boulevard is the only Boulevard-classified street in the Project
vicinity.
Commercial: Neighborhood – These streets provide access for all transportation and supporting
neighborhood retail. Commercial Neighborhood streets in the Project vicinity include Ocean Park
Boulevard (east of 25th Street).
Avenue: Major – These streets serve regional automobile trips and provide access for all modes of
transportation. They are designed to discourage regional auto traffic from using Secondary or
Minor Avenues. The Major Avenues in the Project vicinity include Centinela Avenue and
Cloverfield Boulevard (Pico Boulevard to Santa Monica Boulevard).
Avenue: Secondary – These streets distribute auto trips onto Minor Avenues and Neighborhood
Streets, often serving regional bicycle trips. Secondary Avenues in the Project area include Ocean
Park Boulevard (20th Street to 25th Street) and 23rd Street and Cloverfield Boulevard (Ocean Park
Boulevard to Pico Boulevard).
Avenue: Minor – These streets serve local auto and bicycle trips. Airport Avenue is the only Minor
Avenue in the Project vicinity.
Neighborhood Street – These streets primarily serve abutting buildings. Neighborhood Streets in
the Project vicinity include Ocean Park Place, Oak Street, Hill Place, Hill Street, Ashland Place,
Ashland Avenue, Pier Avenue, Marine Place, Marine Street, Navy Street, and Dewey Street.
Highway – These streets serve primarily regional auto traffic. Intersections with direct connections
to highways may accommodate a high level of congestion to discourage the use of City streets for
cut-through trips. Highways in the Project vicinity include the 1-10 and I-405.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-5
Final EIR – January 2018
These functional street classifications differ from the City’s previous Circulation Element. While
the 2010 LUCE has adopted a new classification system, the significance criteria for Level of
Service (LOS) analysis have not yet been revised. According to the City’s previous classification
system, each type of street provides for a general level of traffic movement in the City. The street
classifications include, arterial, collector, feeder, and local streets. Arterial streets carry the
majority of traffic traveling through the City and are generally developed as commercial corridors.
Collector streets are intended to provide movement of traffic between arterials and neighborhoods.
Feeder streets are similar to collector streets but are intended to carry fewer vehicles, and local
streets provide access from the other street facilities directly to residences and some neighborhoods
serving commercial uses. These classifications are used to determine LOS thresholds, described
later in this chapter.
The City of Los Angeles maintains its own street classification system. The Los Angeles city
streets surrounding the Project are classified below as designated in Mobility Plan 2035, An
Element of the General Plan adopted by the Los Angeles City Council in January 2016:
• Boulevard II – Ocean Park Boulevard (east of Centinela Avenue).
• Avenue I – Bundy Drive/Centinela Avenue, National Boulevard, and Pico Boulevard (east
of Centinela Avenue).
• Avenue III – Rose Avenue (west of Walgrove Avenue).
• Collector – Walgrove Avenue, Palms Boulevard, and Rose Avenue (east of Walgrove
Avenue).
• Local Street – Standard – Dewey Street.
For specific descriptions of the physical characteristics of streets outside the immediate Project
vicinity, refer to Appendix F.
Public Transit Services in the Project Vicinity
The Project vicinity is moderately well-served by public transit provided by the City of Santa
Monica’s Big Blue Bus and the Los Angeles County Metropolitan Transportation Authority
(Metro).
Bus stops nearest the Project site are on or near South Bundy Drive & Airport Avenue
(approximately 250 feet southeast of the Project site), Bundy Drive & National Boulevard
(approximately 500 feet northeast of the Project Site), Ocean Park Boulevard & Bundy Drive
(approximately 0.5 miles northeast of the Project site), and Pico Boulevard & Bundy Drive
(approximately 0.8 mile northeast of the Project site). These stops provide access to Big Blue Bus
Lines 7, 8, 14, 16, and 44 (i.e., the Santa Monica College [SMC] Bundy Campus/Airport Arts
3.7 TRANSPORTATION AND TRAFFIC
3.7-6 Airport Park Expansion Project
Final EIR – January 2018
Campus Connector Shuttle). There are
three rapid bus routes that operate within a
2-mile radius of the Project site: Big Blue
Bus Rapid 3, Big Blue Bus Rapid 7, and
Metro Rapid 733. Additionally, the Project
Site is located approximately 1.5 miles
from the Bundy Drive Station for the
Exposition (Expo) Light Rail (LTR),
which would provide transit access to the
Project site through a direct transfer onto
Big Blue Bus Line 14. At this time, only
two bus lines can be accessed within
0.25 mile of the Project site (see Figure 3.7-1), Big Blue Bus Lines 14 and 44 (the SMC Campus
Connector Shuttle).1 The bus lines that can be accessed within walking distance (0.25 miles) to the
Project site are discussed below. Big Blue Bus Line 14 has a service frequency or headways of
30 minutes or less, with peak hour headways of approximately 10 minutes during weekday and
weekend peak periods. Bus routes that can be accessed within 1 and 2 miles of the Project site are
further discussed within Appendix F.
Big Blue Bus Line 8 (Ocean Park Boulevard) – Line 8 runs from 7th Street and Olympic Boulevard
through Downtown Santa Monica to UCLA via Main Street, Ocean Park Boulevard, National
Boulevard, and Westwood Boulevard. In the Project vicinity, Line 8 operates on Santa Monica
Boulevard and Broadway with headways of 15 to 30 minutes during the weekday peak hours and
30 minutes during the weekend peak hours. The closest stop is located on Bundy Drive and Ocean
Park Boulevard, approximately 0.5 mile north of the Project site.
Big Blue Bus Line 14 (Centinela Avenue) – Line 14 runs from Playa Vista to the Brentwood
neighborhood of Los Angeles via Centinela Avenue, Bundy Drive, and San Vicente Boulevard.
Headways are approximately 15 minutes during weekday and weekend peak periods. Line 14
maintains two stops within immediate vicinity of the Project site, one at South Bundy Drive and
National Boulevard approximately 0.2 mile northeast of the Project site and another at South
Bundy Drive and Airport Avenue, located directly across South Bundy Drive (approximately
200 feet) from existing Airport Park.
Big Blue Bus Line 14 is the bus route that City residents would ultimately utilize to access Airport
Park, however, bus transfers would be required for riders from the nearby Santa Monica
1 0.25 miles is generally considered acceptable walking distance for pedestrians from transit stops to destinations.
The Big Blue Bus provides 6 bus lines within the Project
area, with Big Blue Bus Lines 14 and 44 (SMC Campus
Connector Shuttle) providing stops within 0.25 mile for the
Project site.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-7
Final EIR – January 2018
neighborhoods (e.g., Sunset Park Neighborhood, Pico Neighborhood) to access Airport Park. For
instance, residents of the Pico Neighborhood would require a transfer from Line 7 (discussed
above) to Line 14 at the intersection of Pico Boulevard and Bundy Drive. Similarly, residents of
the Sunset Park neighborhood would require a transfer from Line 8 (discussed above) to Line 14
at the intersection of South Bundy Drive and Ocean Park Boulevard. Therefore, although these
bus lines generally maintain headways of 10 minutes during peak hours, travel times from nearby
City neighborhoods may take up to 30 minutes due to required transfers.
Big Blue Bus Line 16 (23rd Street) – Line 16 runs from Marina Del Rey through downtown Santa
Monica to the Sawtelle neighborhood of Santa Monica. Headways are approximately 10 minutes
on weekdays. Line 16 does not operate on weekends. The stop closest to the Project site is at
Walgrove Avenue and Rose Avenue, approximately 0.6 mile southeast of the Project site. The
pedestrian facilities on Airport Avenue between this bus stop and the Project site are poor.
Big Blue Bus Line 44 (Santa Monica College Campus Connector Shuttle) – Line 44 runs from the
17th Street/SMC Expo Line station to the SMC Main Campus, and continues on to the SMC Bundy
Campus, with stops along 14th Street, 17th Street, Ocean Park Boulevard, South Bundy Drive, and
the SMC Bundy Campus. The purpose of Line 44 is to connect the 17th Street/SMC Expo Line
station and the two SMC campuses. Service headways of about 10 minutes are provided during
weekday peak periods and about 15 minutes during weekday off-peak periods. Line 44 does not
operate on weekends. Line 44 also only runs only in the Fall and Spring semesters. Thus, it is not
a reliable bus route fir City residents seeking to access the Project site. The stop closest to the
Project site is at the SMC Bundy Campus on Airport Avenue approximately 150 feet south of the
Project site.
Within the Project vicinity, the Expo/Bundy Station (left) is an elevated light rail station of the Metro Expo Line
located approximately 1.5 miles north of the Project site. Big Blue Bus Line 14, which maintains bus stops at the
Expo/Bundy Station, provides a direct bus connection from the Expo Line Expo/Bundy station to bus stops
located at Bundy Drive and National Avenue (right) (500 feet northeast of the Project Site) and South Bundy Drive
and Airport Avenue, directly across Airport Avenue from Airport Park. The distance of the Bundy/National bus
stop to park entrances would be reduced with the introduction of two new pedestrian entryways along South
Bundy Drive, including the Main Bundy Entryway.
3.7 TRANSPORTATION AND TRAFFIC
3.7-8 Airport Park Expansion Project
Final EIR – January 2018
Public Parking in the Project Vicinity
This discussion is based in part on the Parking Study for Santa Monica Airport (Parking Study)
prepared by Gibson Transportation Consulting, Inc. (Gibson 2017) (refer to Appendix F). There
is ample free day-time parking at SMO. Airport parking is restricted from 3:00 A.M. to 5 A.M. every
night, but permits for parking during this period are available from the Airport Administration
Office. In the vicinity of the Project site, public parking is provided in eight lots totaling 882 spaces
that would generally be available to visitors to Airport Park (see Table 3.7-1). Additional public
and private parking is available in the immediate Project vicinity, but would generally not be
available to visitors of Airport Park as the lots serve the employees and students of the SMC Bundy
Campus, or are restricted to the private use of the cultural/event venues in the Project vicinity. The
SMO Airport campus has surface parking lots available for use by both tenants and visitors. These
lots can be accessed from Airport Avenue or Donald Douglas Loop South. On-street parking is
generally unavailable in the Project vicinity.
Pedestrian and Bicycle Facilities in the Project Vicinity
Pedestrian Facilities
Sidewalks on South Bundy Drive and Airport Avenue (where present adjacent to the existing Airport
Park) are approximately 6 feet wide. Sidewalks along the northeastern extent of Donald Douglas
Loop South are approximately 8 feet wide. The portion of Airport Avenue west of Donald Douglas
Loop South—where the Project site’s west paved surface area fronts Airport Avenue—does not
provide a sidewalk, although a wide area of pavement used for vehicle parking can accommodate
informal pedestrian movement. Sidewalks are inconsistent and not well developed along Airport
Avenue from Donald Douglas Loop South to 23rd Street. In the Sunset Park neighborhood, 6-foot
sidewalks exist on both sides of 23rd Street and tree-lined sidewalks are generally accessible in the
residential neighborhoods. Signalized intersections in the Project vicinity have marked or textured
crosswalks and pedestrian countdown signals. There are unsignalized mid-block pedestrian
crossings on Airport Avenue and adjacent to the Project site and further west, across from the Airport
Arts Campus. All intersections have accessible compliant curb ramps.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-9
Final EIR – January 2018
Table 3.7-1. Parking Available in the Project Vicinity
Parking Lot Name and Address Parking Spaces Available
Public Parking (Available to Visitors of Airport Park)
Lot A: 3100-3200 Donald Douglas Loop South 178
Lot D: Located at 3200-3400 Airport Avenue 134
Lot F: Located at 3050 Airport Avenue 117 spaces available on weekdays and most weekend
days
Lot G: Located at 3026 Airport Avenue 191 spaces available on weekdays and most weekend
days
Lot H: Located at 3000 Airport Avenue 49
Lot L: Located at 3013 Airport Avenue 75
Lot N: Located at 3025 Airport Avenue (not a formal
parking lot) Approximately 20
Lot B1: Located across 3200 Donald Douglas Loop
South (exclusively serves Airport Park) 58
Lot B2: Located at 3201 Airport Avenue (exclusively
serves Airport Park) 60
Public/Private Parking (Unavailable to Visitors of Airport Park)
Lot C1: Located east of 3400 Airport Avenue 175
Lot C2: Located on the SMC Bundy Campus and east
of 3171 S. Bundy Drive (serves SMC staff and
students)
408 parking spaces available
Lot C3: Located on the SMC Bundy Campus and west
of 3171 S. Bundy Drive (serves SMC staff and
students)
242 parking spaces available
Lot E: Located at 3100 Airport Avenue 134 parking spaces available
Lot I1: Located to the east of 2800 Airport Avenue,
exclusively serves the SMC Airport Art Campus 48 parking spaces available
Lot I2: Located to the west of 2800 Airport Avenue,
exclusively serves the SMC Airport Art Campus 115 parking spaces available
Lot K1: Located to the east of 3021 Airport Avenue,
exclusively serves Barker Hangar tenants and visitors Parking not available to the public, utilized for events
Lot K2: Located to the west of 3021 Airport Avenue,
exclusively serves Barker Hangar tenants and visitors
Approximately 50 spaces provided but not available to
the public, utilized for events
Lot K3: Located at 3021 Airport Avenue, exclusively
servers Barker Hangar tenants and visitors
Approximately 11 parking spaces provided but not
available to the public, utilized for events.
Source: Gibson Transportation Consulting, Inc., 2017.
3.7 TRANSPORTATION AND TRAFFIC
3.7-10 Airport Park Expansion Project
Final EIR – January 2018
Bicycle Facilities
The City has 45 miles of bicycle facilities, consisting of designated bike lanes or paths (referred to
as Class I and II facilities) and designated routes along streets (Class III facilities) (City of Santa
Where present, sidewalks in the Project vicinity are generally 8-10 feet in width and characterized by limited
street improvements such as street trees (top). Consequently, these sidewalks are generally suitable for free
flowing pedestrian movement. However, sidewalks along Airport Avenue west of Donald Douglas Loop are
poorly developed and often consist of paved surfaces that also accommodate parked vehicles (bottom).
Thus, there is currently a poor pedestrian connection between the City’s Sunset Park neighborhood and
Airport Park. As shown in both pictures, Airport Avenue is a Class III bicycle route designated with
“sharrows”. Source: Google 2017
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-11
Final EIR – January 2018
Monica 2015a). Within the Project area, bicycle improvements are somewhat limited. There are
no Class I or Class II facilities that link the site to nearby neighborhoods or to the Expo LTR Bundy
Station. In addition, regional access to the site is along major boulevards or avenues that carry
relatively high volumes of traffic. For instance, South Bundy Drive has no dedicated bicycle lanes,
limited lane or sidewalk width to accommodate bicyclists, and high volumes of vehicle traffic
throughout the day, particularly during the A.M. and P.M. weekday peak hours. Existing facilities
within 0.5 miles of the Project site are identified below and outlined within Figure 3.7-1.
Additional designated future bicycle routes with sharrow markings are proposed in the City’s
20-Year Bicycle Implementation Plan. The Project vicinity has some on-street bike amenities, with
additional improvements planned as a part of approved future Projects (e.g., Airport Avenue
Improvement Project).
Class II Bicycle Facilities – Class II bicycle facilities are marked bicycle lanes that are located on-
street but have pavement striping and markings that separate the lane from vehicular traffic as well
as demarcation with green paint when such lanes approach intersections. On streets with on-street
parking, the bicycle lane is located between the parking lane and the outermost travel lane. The
following street segments in the Project vicinity have Class II bicycle facilities:
• 23rd Street – dedicated bicycle lanes in both directions from Ocean Park Boulevard to the
north to its intersection with Airport Avenue, approximately 0.7 miles southwest of the
Project site;
• Ocean Park Boulevard – dedicated bicycle lanes in both directions from Main Street to
Centinela Avenue; approximately 0.7 miles north of the Project site and
• Rose Avenue – from Walgrove Avenue to Morningside Way, approximately 0.2 miles east
of the Project site.
Class III Bicycle Facilities – Class III bicycle facilities are designated on-street routes that do not
have striped separation from traffic, but may have pavement sharrow markings or signs indicating
a bicycle route and instructing motorists to share the road. Street segments in the Project vicinity
with Class III bicycle facilities include:
• Airport Avenue – from Bundy Drive to 23rd Street, adjacent to the east side of the Project
site; and
• Ocean Park Boulevard – from Bundy Drive to Centinela Avenue; approximately 0.65
miles north of the Project site.
With these bicycle facilities, the Project site can be accessed from the 23rd Street and the City’s
Sunset Park neighborhood via a Class III bicycle route with sharrows on Airport Avenue. As
discussed above, 23rd Street provides a Class II bicycle facility, and in turn, Ocean Park Boulevard
3.7 TRANSPORTATION AND TRAFFIC
3.7-12 Airport Park Expansion Project
Final EIR – January 2018
also is a Class II bicycle facility.
Although Airport Avenue currently
only supports a Class III shared bicycle
facility, the connected bicycle network
of Airport Avenue, 23rd Street, and
Ocean Park Boulevard provide a
bicycle connection between Airport
Park and the rest of the City’s bicycle
network. In addition to these facilities,
the City has recently marked various
streets as shared – vehicle/bicycle lanes
and included bicycle detection zones at
signalized intersections. These lanes
have been painted with sharrow
markings. Streets with these markings include Airport Avenue, Ashland Avenue, and 28th Street.
Planning is currently underway for complete sidewalks and a Class I, 2-way, separated cycle way
on the north side of Airport Avenue, extending from South Bundy Drive to 23rd Street, as part of
the Airport Avenue Improvement Project.
Bicycle parking is available throughout the City and in the Project vicinity, including in many of
the parking structures, on-street racks, and associated with numerous public and private facilities.
For example, there are on-street bicycle racks adjacent to the existing sports field on Airport
Avenue at Airport Park.
Citywide Bikeshare Program (“Breeze”) - The Santa Monica Bikeshare program consists of 500
bikes and 80 bikeshare stations. These public bikes allow residents, visitors, and employees to ride
a bicycle for their travel needs within the City. Bikeshare linked with transit, including nearby Big
Blue Bus routes and the Expo LRT, provides a high-quality alternative to driving. The Breeze
Bikeshare station nearest the Project site is located adjacent to the existing Airport Park, at the
intersection of Donald Douglas Loop South and Airport Avenue (3027 Airport Avenue) and has
10 bicycle racks (‘Santa Monica Bike Share’ 2017). This station would be removed temporarily
during Project construction, and replaced upon completion of the Project. There is an additional
Breeze Bike Share station on the SMC Bundy Campus (3171 South Bundy Drive) located
approximately 0.1 miles southwest of the Project site with 9 bike racks. The City of Los Angeles
does not operate any bike share stations in the Project vicinity.
The two way cycle track included in the proposed Airport Avenue
Improvement Project (similar to the one shown above) will greatly
improve bicycle access to the Project site.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-13
Final EIR – January 2018
Existing Pedestrian and Bicycle Traffic Volumes
Streets and sidewalks in the Project vicinity support low to moderate volumes of pedestrian and
bicycle traffic. Pedestrian and bicycle use is generally lower in the Project vicinity due to its
distance from heavily populated neighborhoods and the downtown. For example, a review of
existing pedestrian counts captured in late 2016 shows that pedestrian and bicyclist crossings total
approximately 229 at Bundy Drive and Airport Avenue and 209 at Bundy Drive at Ocean Park
Boulevard during peak weekday morning and evening hours combined; the highest level of activity
observed occurred at the intersection of Cloverfield and Pico, with more than 769 crossings during
peak weekday morning and evening hours combined. Table 3.7-2 shows the morning peak hour
bicycle volumes at Cloverfield and Pico, as well as Ocean Park Boulevard and Bundy Drive and
Bundy Drive and Airport Avenue, nearer to the Project site.
Table 3.7-2. Pedestrian and Bicycle Traffic in the Project Vicinity during Weekday Peak
A.M. Hours (7:30-9:15 A.M.)
Notes: Data was collected on November 2nd and November 9th, 2016 between the hours of 7:30 and 9:30 A.M., and between the
hours of 5:00 and 7:00 P.M.
Source: Fehr and Peers 2017 – Appendix F.
Intersection Direction of Traffic
Across Intersection
Total Volume of
Pedestrians
Total Volume of
Bicyclists
Cloverfield & Pico
N 70 36
S 116 11
E 80 18
W 32 12
Ocean Park & Bundy
N 4 17
S 28 17
E 11 7
W 12 8
Bundy & Airport
N 0 0
S 34 3
E 0 12
W 25 25
3.7 TRANSPORTATION AND TRAFFIC
3.7-14 Airport Park Expansion Project
Final EIR – January 2018
Future Transportation Improvements
Proposed Project (Airport Park Expansion)
As described in Section 2, Project Description, the Project includes the realignment of Donald
Douglas Loop South to the western perimeter of the proposed park expansion. This realignment
will provide access to the Park as well as SMO facilities.
Airport Avenue Improvement Project
As introduced above, the Airport Avenue
Improvement Project is a planned project
(unrelated to the proposed Project) along Airport
Avenue from South Bundy Drive to 23rd Street
(see Table 3.0-1, Cumulative Related Project No.
A). Construction of the Airport Avenue
Improvement Project is planned to coincide with
construction of the Project (estimated
completion in late 2019) and is anticipated to include sidewalk improvements, bike lanes, retaining
walls, striped crosswalks and curb ramps, street lighting, street trees, and amenities such as
benches, signage and trash containers. Airport Avenue runs from east to west between 23rd
Street/Walgrove Avenue and Bundy Drive. It is approximately 0.85 miles in length and varies
from 25’-30’ curb to curb in width. When completed, this Project will improve pedestrian and
bicycle connectivity between the Project vicinity and neighborhoods north and west of SMO.in
the vicinity of the Project site. A depiction of the physical improvements planned under the Airport
Avenue Improvement Project is found in the discussion of cumulative impacts at the end of this
section (Figure 3.7-6).
Intersection Operations and Level of Service
Because traffic flow on urban streets is most constrained at intersections, traffic flow analyses
focus on operating conditions of critical intersections during peak travel periods. Intersection
operation and congestion can be described by measuring the level of service (LOS) of an
intersection. LOS is a qualitative method for characterizing the operational conditions at an
intersection generally accounting for measures such as speed, delays, travel time, freedom to
maneuver, traffic interruptions, and comfort and convenience. In rating intersection operations,
LOS A through F are used, with LOS A indicating free-flow operations and LOS F indicating
congested operations. The City of Santa Monica considers LOS D as the minimum desirable LOS
at arterial intersections and LOS C as the minimum desirable LOS at collector street intersections.
Key Improvements of the Airport Avenue
Improvement Project:
Pedestrian and Bikeway Improvements:
- New two-way 12-foot wide 2-way bicycle
lane on north side of Airport Avenue
- New sidewalk upgrades and crosswalk
improvements on Airport Avenue from the
SMC Arts Campus to 23rd Street
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-15
Final EIR – January 2018
Table 3.7-3. Level of Service Criteria for Signalized Intersections
LOS Interpretation
Control
Delay Per
Vehicle 1
A Excellent; No vehicle waits longer than one red light and no approach phase is
fully used. ≤ 10
B Very Good; An occasional approach phase is fully utilized and many drivers begin
to feel somewhat restricted within groups of vehicles. > 10 – 20
C Good; Occasionally drivers may have to wait through more than one red light and
backups may develop behind turning vehicles. > 20 – 35
D
Fair; Delays may be substantial during portions of the rush hours, but enough
lower volume periods occur to permit clearing of developing lines, preventing
excessive backups.
> 35 – 55
E Poor; Represents the most vehicles intersection approaches can accommodate
resulting in long lines of waiting vehicles through several signal cycles. > 55 – 80
F
Failure; Backups from nearby locations or on cross streets may restrict or prevent
movement of vehicles out of the intersection approaches, result in tremendous
delays with continuously increasing queue lengths.
> 80
Note: 1 Control Delay in seconds per vehicle.
Source: (Highway Capacity Manual (HCM), Transportation Research Board 2010)
Existing Trip Generation
The trip generation of Airport Park’s existing uses is shown in Figure 3.7-2 and Tables 3.7-4 and
3.7-5. Airport Park currently consists of 8.3 total acres, including a 3-acre sports field, a 1-acre
dog park, approximately 1.1 acres of parking/circulation, and approximately 3.2 acres of open park
space.
Trips generated by the park’s existing dog park use were estimated based on observations
conducted at three dog parks in northern California, using a study conducted by TJKM
Transportation Consultants for the Supplemental Traffic and Circulation Impact Analysis for the
Proposed Homes at Deer Hill Project For the City of Lafayette (January 23, 2015). The results of
these observations are also similar to a study conducted by Fehr & Peers prior to the development
of the existing Airport Park at Joslyn Park.
Trips generated by the park’s soccer field assumes that the field is divided into three separate
practice areas during the weekday P.M. peak hour. The estimate of trips generated by the park’s
existing field was further refined based on driveway counts and field observations conducted April
28 and 29, 2017 during peak field reservation times, according to the field reservation schedule
provided by the City of Santa Monica. These data were used to calibrate estimates of pick-up and
drop-off traffic for typical weekday soccer practice.
L
F
4
1212
5
BARKERBARKER
HANGARHANGAR
MAR VISTAMAR VISTA
ELEMENTARYELEMENTARY
10
10
VIRGINIA AVENUEVIRGINIA AVENUE
PARKPARK
GANDARAGANDARA
PARKPARK
CLOVER
PARK
GANDARA
PARK
VIRGINIA AVENUE
PARK
PENMAR
RECREATION CENTER VENICE
RESERVOIR
SITE
GRANTGRANT
ELEMENTARYELEMENTARY
EDISONEDISON
ELEMENTARYELEMENTARY
WALGROVE
AVENUE
ELEMENTARY
SANTA MONICA
COLLEGE
BUNDY CAMPUS
EDISON
ELEMENTARY
GRANT
ELEMENTARY
MAR VISTA
ELEMENTARY
PICOPICO
MARMAR
VISTAVISTA
WEST LOS ANGELESWEST LOS ANGELES
SUNSET PARKSUNSET PARK
PICO
SUNSET PARK
VENICE
MAR
VISTA
WEST LOS ANGELES
S
O
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H
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N
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U
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PALMS BOULEVARDPALMS BOULEVARD
3
1
S
T
S
T
R
E
E
T
OCEAN PARK BOULEVARDOCEAN PARK BOULEVARD
EXP
O
S
I
T
I
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N
B
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E
V
A
R
D
EXP
O
S
I
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B
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L
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V
A
R
D
WEST OL YWEST OLYMPIC BOULEVARD
2
3
R
D
S
T
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T
2
3
R
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NATIONAL BOULEVARDNATIONAL BOULEVARD
T
2
0
T
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T
1
8
T
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F
I
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L
D
B
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A
R
D
PICO BOULEVARDPICO BOULEVARD
DONALD DOUGLASDONALD DOUGLAS
LOOP SOUTHLOOP SOUTH
S
O
U
T
H
C
E
N
T
I
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E
L
A
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PALMS BOULEVARD
DONALD DOUGLAS
LOOP SOUTH
DONALD DOUGLAS
LOOP NORTH
AIRPORT AVENU
E
ROSE AVENUE
OCEAN PARK BOULEVARD
EXP
O
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N
B
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WEST OL Y
2
3
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2
8
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NATIONAL BOULEVARD
PICO BOULEVARD
C
L
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F
I
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D
B
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V
A
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D
SANTA MONICASANTA MONICA
AIRPORTAIRPORT
SANTA MONICA
AIRPORT
BARKER
HANGAR
1
2
4
9
126
8
3
5 10
11
14
15
13A7
LEGEND
Santa Monica Airport
Existing Santa Monica Airport Park
Project Site
Study Intersection and Number
School
Fire Station
Fairview Branch Library
Park
City of Santa Monica
City of Los Angeles
##
F
L
Study Intersection Worst Peak Hour
Level of Service
(Circle = Santa Monica Jurisdiction;
Square = Los Angeles Jurisdiction)
Excellent/Good (A-C)
Fair (D)
Poor/Failure (E-F)
6 – 23rd Street and Dewey Street
8 – Walgrove Avenue and Rose Avenue
9 – Centinela Avenue and
Ocean Park Boulevard
10 – Bundy Drive and Ocean Park Boulevard
11 – Bundy Drive and National Boulevard
14 – Centinela Avenue and Rose Avenue
15 – Centinela Avenue and Palms Boulevard
Notes: Refer to Table 3.13-1 for LOS definitions and Table 3.13-2
for Existing (2013) Intersection LOS information.
0 1,200
SCALE IN FEET
N
Existing Levels of Service 3.7-2
FIGURE
3.7-16
L
F
4
1212
5
BARKERBARKER
HANGARHANGAR
MAR VISTAMAR VISTA
ELEMENTARYELEMENTARY
10
10
VIRGINIA AVENUEVIRGINIA AVENUE
PARKPARK
GANDARAGANDARA
PARKPARK
CLOVER
PARK
GANDARA
PARK
VIRGINIA AVENUE
PARK
PENMAR
RECREATION CENTER VENICE
RESERVOIR
SITE
GRANTGRANT
ELEMENTARYELEMENTARY
EDISONEDISON
ELEMENTARYELEMENTARY
WALGROVE
AVENUE
ELEMENTARY
SANTA MONICA
COLLEGE
BUNDY CAMPUS
EDISON
ELEMENTARY
GRANT
ELEMENTARY
MAR VISTA
ELEMENTARY
PICOPICO
MARMAR
VISTAVISTA
WEST LOS ANGELESWEST LOS ANGELES
SUNSET PARKSUNSET PARK
PICO
SUNSET PARK
VENICE
MAR
VISTA
WEST LOS ANGELES
DONALD DOUGLASDONALD DOUGLAS
LOOP SOUTHLOOP SOUTH
SANTA MONICASANTA MONICA
AIRPORTAIRPORT
SANTA MONICA
AIRPORT
BARKER
HANGAR
1
2
4
9
126
8
3
5
10
11
14
15
13A7
S
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PALMS BOULEVARDPALMS BOULEVARD
3
1
S
T
S
T
R
E
E
T
OCEAN PARK BOULEVARDOCEAN PARK BOULEVARD
EXP
O
S
I
T
I
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N
B
O
U
L
E
V
A
R
D
EXP
O
S
I
T
I
O
N
B
O
U
L
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V
A
R
D
WEST OL YWEST OLYMPIC BOULEVARD
2
3
R
D
S
T
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T
2
3
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B
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N
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E
NATIONAL BOULEVARDNATIONAL BOULEVARD
T
2
0
T
H
S
T
R
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E
T
1
8
T
H
S
T
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T
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F
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D
PICO BOULEVARDPICO BOULEVARD
S
O
U
T
H
C
E
N
T
I
N
E
L
A
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N
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V
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B
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L
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V
A
R
D
PALMS BOULEVARD
DONALD DOUGLAS
LOOP SOUTH
DONALD DOUGLAS
LOOP NORTH
AIRPORT AVENU
E
ROSE AVENUE
OCEAN PARK BOULEVARD
EXP
O
S
I
T
I
O
N
B
O
U
L
E
V
A
R
D
T
WEST OL Y
2
3
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D
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T
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T
2
8
T
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1
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NATIONAL BOULEVARD
PICO BOULEVARD
C
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F
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L
D
B
O
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V
A
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D
LEGEND
Santa Monica Airport
Existing Santa Monica Airport Park
Project Site
Study Intersection and Number
School
Fire Station
Fairview Branch Library
Park
City of Santa Monica
City of Los Angeles
##
F
L
Approval Year Intersection Level of Service
(Circle = Santa Monica Jurisdiction;
Square = Los Angeles Jurisdiction)
Excellent/Good (A-C)
Fair (D)
Poor/Failure (E-F)
Approval Year (2017) Impacts
No Measurable Impact
Less than Significan Impact
Significant
Note: Impacts are less than significant for all
Los Angeles Intersections.
0 1,200
SCALE IN FEET
N
Proposed Project Approval Year (2017)
Level of Service 3.7-3
FIGURE
3.7-17
3.7 TRANSPORTATION AND TRAFFIC
3.7-18 Airport Park Expansion Project
Final EIR – January 2018
Table 3.7-4. Existing Intersection Levels of Service (2017) (City of Santa Monica Analysis
Methodology – Highway Capacity Manual [HCM])
No. Intersection Juris. Class Peak
Hour
Existing Conditions (2017)
V/C Delay LOS
1 Cloverfield Boulevard &
Westbound I-10 Off-Ramp
SM A A.M. 0.526 40 D
A P.M. 0.825 23 C
2 Cloverfield Boulevard &
Eastbound I-10 On-Ramp
SM A A.M. 0.545 22 C
A P.M. 0.905 25 C
3 Cloverfield Boulevard &
Pico Boulevard
SM A A.M. 0.653 41 D
A P.M. 0.727 33 C
4 Cloverfield Boulevard &
Ocean Park Boulevard
SM A A.M. 0.528 9 A
A P.M. 0.557 13 B
5 23rd Street &
Ocean Park Boulevard
SM A A.M. 0.810 45 D
A P.M. 0.677 27 C
6 23rd Street &
Dewey Street
SM C A.M. 0.318 15 C
C P.M. 1.296 ** F
7 23rd Street &
Walgrove Avenue
SM C A.M. 0.517 27 D
C P.M. 0.397 22 C
8 Walgrove Avenue &
Rose Avenue
LA C A.M. 0.619 74 E
C P.M. 0.397 22 C
9 Centinela Avenue &
Ocean Park Boulevard
SM
LA
A A.M. 0.554 30 C
A P.M. 0.696 65 E
10 Bundy Drive &
Ocean Park Boulevard
LA A A.M. 0.937 83 F
A P.M. 0.917 87 F
11 Bundy Drive &
National Boulevard
LA A A.M. 0.937 93 F
A P.M. 0.801 24 C
12 Centinela Avenue &
Airport Avenue
SM
LA
A A.M. 0.799 15 B
A P.M. 0.911 43 D
13A Donald Douglas Loop
South & Airport Avenue
SM C A.M. 0.319 9 A
C P.M. 0.529 11 B
14 Centinela Avenue &
Rose Avenue LA A A.M. 0.743 19 B
A P.M. 0.779 12 B
15 Centinela Avenue &
Palms Boulevard
LA A A.M. 0.772 42 D
A P.M. 0.910 48 D
Source: Fehr & Peers 2017 – Appendix F.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-19
Final EIR – January 2018
Table 3.7-5. Existing Intersection Levels of Service (2017) (City of Los Angeles Analysis
Methodology – Critical Movement Analysis [CMA])
Number Intersection Juris. Class Peak
Hour
Operating Conditions
V/C LOS
8 Walgrove Avenue & Rose
Avenue
LA C A.M. 1.028 F
C P.M. 0.899 D
9 Centinela Avenue & Ocean
Park Boulevard
LA A A.M. 0.781 C
A P.M. 0.680 B
10 Bundy Drive & Ocean Park
Boulevard
LA A A.M. 0.835 D
A P.M. 1.041 F
11 Bundy Drive & National
Boulevard
LA A A.M. 0.821 D
A P.M. 0.762 C
12 Centinela Avenue & Airport
Avenue
LA A A.M. 0.705 C
A P.M. 0.840 D
14 Centinela Avenue & Rose
Avenue
LA A A.M. 0.792 C
A P.M. 0.925 E
15 Centinela Avenue & Palms
Boulevard
LA A A.M. 1.014 F
A P.M. 1.039 F
DEFINITIONS
V/C – Volume-to-Capacity Ratio – This ratio is based on the amount of traffic traveling through the intersection, the lane
geometries, and other factors affecting capacity such as one-street parking, bus operations near the intersections, and
pedestrian volumes at the street crosswalks.
Delay – Average stopped delay per vehicle, in seconds.
* -- Average stopped delay per vehicle, in seconds
** -- Indicated oversaturated conditions, delay cannot be calculated
CLASS
A – Arterial Intersection – High capacity intersection which delivers traffic at the highest level of service possible.
C – Collector Intersection – Low to moderate capacity intersection which delivers traffic from local streets to arterial streets.
LEVEL OF SERVICE
Refer to definitions in Table 3.7-3.
Note: 2017 traffic volume count data prepared by Fehr & Peers. Counts were collected in fall 2016 and early 2017 (when school
was in session) for weekday A.M. and P.M. peak hours.
Source: Fehr & Peers 2017 – Appendix F
Airport Park’s existing uses generate an estimated 674 daily trips, including 41 trips (23
inbound/18 outbound) during the A.M. peak hour and 149 trips (91 inbound/58 outbound) during
the P.M. peak hour. The driveway counts conducted for this project suggest that park activity may
be higher on the weekends, but the general traffic levels on adjacent and nearby streets is lower.
Existing Intersection Operation
The Project’s Transportation Impact Analysis (Appendix F) examined 15 intersections and six
neighborhood street segments in the Project vicinity that could be potentially affected by Project-
generated traffic. Per City traffic study guidelines, the 15 study intersections have been analyzed
using the Highway Capacity Manual (HCM) operations methodology, which has been adopted by
3.7 TRANSPORTATION AND TRAFFIC
3.7-20 Airport Park Expansion Project
Final EIR – January 2018
the City as its analysis methodology. Seven of the 15 study intersections lie within shared
jurisdiction between the City of Santa Monica and the City of Los Angeles, including three
signalized intersections. An additional four intersections lie within the City of Los Angeles. These
seven signalized intersections have also been analyzed using the Critical Movement Analysis
(CMA) methodology, the City of Los Angeles’ adopted analysis methodology. The study
examined the intersections for each of the traffic scenarios. These intersections and their existing
LOS are identified in Figure 3.7-2 and Tables 3.7-4 and 3.7-5. It should be noted that the HCM
and CMA methods of LOS analysis, as adopted by the City of Santa Monica and the City of Los
Angeles, respectively, are different methods of estimating LOS. Though both use rating systems
A through F, their results are not directly comparable.
To evaluate LOS at these 15 intersections, traffic volume data for both the weekday morning
(between 7:30 A.M. and 9:30 A.M.) and evening (5:00 P.M. to 7:00 P.M.) peak periods as well as
weekend midday peak period (1:00 P.M. to 5:00 P.M.) were obtained from the most recent 2016
and 2017 traffic counts conducted by Fehr & Peers (Appendix F). Counts were collected in the fall
of 2016 and spring of 2017 (when school was in session) for weekday A.M. and P.M. peak hours.
In accordance with the City’s adopted impact analysis, the “Operational Analysis” method from
HCM was employed to perform LOS analysis at all signalized study intersections within Santa
Monica’s jurisdiction. The HCM operational method determines two key operating characteristics
of signalized intersections. The first characteristic is the average stopped delay, experienced per
vehicle. The second is the volume-to-capacity (V/C) ratio at intersections based on the amount of
traffic traveling through the intersection, the lane geometries, and other factors affecting capacity
such as on-street parking, bus operations near the intersection, and pedestrian volumes at the street
crosswalks. These characterizations are used to evaluate the operation of each signalized
intersection, which is described generally in terms of LOS.
The Project site is somewhat disconnected from the rest of the City due to its location at the
southeast corner of SMO property. Since the early 1920s, SMO has formed a notable, one-mile-
long barrier to north-south circulation through the City, and physically separated land uses on
either side of the airport. The existing transportation network has long been designed to
circumnavigate SMO. Even so, due to its size, SMO hinders accessibility from the other portions
of the City to the Project site. The City’s north-south roadways that circumnavigate SMO are 23rd
Street and South Bundy Drive. As a result of north-south movement being restricted to these
roadways in the vicinity of these roadways, poor LOS (i.e., congestion) often forms along these
roadways.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-21
Final EIR – January 2018
Traffic also congests at primary vehicular routes to the I-10 or I-405 that carry high traffic volumes
or the intersections of Bundy Drive & Ocean Park Boulevard. Of the 15 intersections studied, 10
operate at “excellent” to “fair” (LOS A–D), while 5 have a LOS that are currently categorized as
“poor” or “failure” (LOS E or F) during at least one of the peak hours examined in the
Transportation Impact Analysis (Appendix F). Under the City of Santa Monica’s HCM-based
methodology, intersections within the Project vicinity that currently operate at poor LOS include:
6. 23rd Street & Dewey Street (LOS F during the P.M. peak hour)
8. Walgrove Avenue & Rose Avenue (LOS E during the A.M. peak hour)
9. Centinela Avenue & Ocean Park Boulevard (LOS E during the P.M. peak hour)
10. Bundy Drive & Ocean Park Boulevard (LOS F during both A.M. and P.M. peak hours)
11. Bundy Drive & National Boulevard (LOS F during the A.M. peak hour)
The results of the analysis of existing weekday morning and evening peak hour conditions at the
study intersections using the CMA methodology are summarized in Table 3.7-5. As shown, three
of the seven signalized intersections located in or shared with the City of Los Angeles operate at
acceptable LOS (LOS D or better) during all analyzed peak hours. The four study intersections
that currently operate at poor conditions during at least one of the analyzed peak hours under the
existing conditions scenario are:
8. Walgrove Avenue & Rose Avenue (LOS F during the A.M. peak hour)
10. Bundy Drive & Ocean Park Boulevard (LOS F during the P.M. peak hour)
14. Centinela Avenue & Rose Avenue (LOS E during the P.M. peak hour)
15. Centinela Avenue & Palms Boulevard (LOS F during both the A.M. and P.M. peak hours)
3.7.2 Regulatory Framework
Federal Regulations
Americans with Disabilities Act of 1990
Titles I, II, III, and V of the Americans with Disabilities Act (ADA) have been codified in Title 42
of the United States Code (USC), beginning at Section 12101. Title III prohibits discrimination on
the basis of disability in places of public accommodation (i.e., businesses and non-profit agencies
that serve the public) and commercial facilities (i.e., other businesses). This regulation includes
Appendix A to Part 36, Standards for Accessible Design, which establishes minimum standards
3.7 TRANSPORTATION AND TRAFFIC
3.7-22 Airport Park Expansion Project
Final EIR – January 2018
for ensuring accessibility when designing and constructing a new facility or altering an existing
facility.
Examples of key guidelines include detectable warning for pedestrians entering traffic where there
is no curb, a clear zone of 48 inches for the pedestrian travelway, and a vibration-free zone for
pedestrians.
State Regulations
Statewide Transportation Improvement Program
The California Transportation Commission (CTC) administers transportation programming.
Transportation programming is the public decision-making process, that sets priorities and funds
Projects envisioned in long-range transportation plans. It commits expected revenues over a multi-
year period to transportation Projects. The State Transportation Improvement Program (STIP) is a
multi-year Capital Improvement Program of transportation Projects on and off the State Highway
System, funded with revenues from the State Highway Account and other funding sources. STIP
programming occurs every two years, with the release of a fund estimate. Once the fund estimate
for the STIP is adopted, the California Department of Transportation (Caltrans) and other regional
planning agencies prepare transportation improvement plans. Caltrans manages the operation of
State Highways, including the freeways passing through the Los Angeles Region.
Senate Bill (SB) 743
To further the state’s commitment to the goals of SB 375, AB 32, and AB 1358 to reduce
greenhouse gas emissions, Governor Brown signed SB 743 on September 27, 2013. SB 743 adds
Chapter 2.7, Modernization of Transportation Analysis for Transit-Oriented Infill Projects, to
Division 13 (Section 21099) of the Public Resources Code. SB 743 establishes Transit Priority
Areas (TPAs) and other key provisions, including reforming aesthetics and parking CEQA
analyses for urban infill Projects and eliminating the measurement of automobile delay, or LOS,
as a metric that can be used for measuring traffic impacts in TPAs. Under SB 743, the focus of
transportation analysis will shift from driver delay to reduction of GHG emissions, creation of
multimodal networks, and promotion of a mix of land uses.
Specifically, SB 743 requires the Governor’s Office of Planning and Research (OPR) to amend
the CEQA Guidelines (Title 14 of the California Code of Regulations sections and following) to
provide an alternative to LOS for evaluating transportation impacts. OPR released a revised
proposal for changes to the CEQA Guidelines in January 2016. OPR's changes to the CEQA
Guidelines propose that projects utilize VMT as the replacement metric for LOS in the context of
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Airport Park Expansion Project 3.7-23
Final EIR – January 2018
CEQA. However, OPR has not yet adopted these draft CEQA Guidelines. Once the CEQA
Guidelines are amended to include those alternative criteria, auto delay will no longer be
considered a significant impact under CEQA. Measurements of transportation impacts may
include “vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates,
or automobile trips generated.” (Ibid.) OPR also has discretion to develop alternative criteria for
areas that are not served by transit, if appropriate. (Id. at subd. (c).)
Pursuant to SB 743, OPR released a Draft of Updates to the CEQA Guidelines in August 2014.
OPR’s Draft of Updates proposes VMT as the replacement metric for LOS in the context of
CEQA. While OPR emphasizes that a lead agency has the discretionary authority to establish
thresholds of significance, the Draft of Updates suggest criteria that indicate when a Project may
have a significant, or less than significant, transportation impact on the environment. For instance,
a Project that results in VMTs greater than the regional average for the land use type (e.g.
residential, employment, commercial) may indicate a significant impact. Alternatively, a Project
may have a less than significant impact if it is located within 0.5 mile of an existing major transit
stop, or results in a net decrease in VMTs compared to existing conditions.
The public comment period on OPR’s Draft of Updates ended in November 2014, and on May 1,
2015 OPR released the Summary of Feedback. It is anticipated that further revisions to the Draft
of Updates will be forthcoming prior to adoption of amendments to the CEQA Guidelines.
Regional Regulations
Southern California Association of Governments
SCAG is the designated MPO for six Southern California counties (Los Angeles, Ventura, Orange,
San Bernardino, Riverside, and Imperial), and is federally mandated to develop plans for regional
transportation, land use and growth management, hazardous waste management, and air quality.
The City is one of many jurisdictions comprising the SCAG.
To address regional planning issues, SCAG has a number of adopted strategies and plans to
implement California’s Sustainable Communities and Climate Protection Act (SB 375), and
recommend actions local jurisdictions can take to implement regional sustainability goals. The key
principles of these strategies include: locating new employment centers and neighborhoods near
major transit systems to reduce vehicle trips and peak- congestion; creating mini-communities
around transit stations, with small businesses, housing and restaurants within walking distance to
reduce automobile travel; focusing future growth in urban centers and existing cities to reduce
vehicle miles traveled and preserve rural and other natural areas; and preserving established single-
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Final EIR – January 2018
family neighborhoods and existing natural and green spaces by accommodating new development
with existing urbanized areas and downtowns.
In April 2016, SCAG adopted the 2016–2040 RTP/SCS, which includes goals to increase mobility
and enhance sustainability for the region’s residents and visitors. SCAG’s 2016–2040 RTP/SCS
provides growth forecasts that are used in the development of air quality-related land use and
transportation control strategies by the SCAQMD. The RTP/SCS includes a strong commitment
to reducing GHG emissions from transportation sources and emphasizes the crucial linkages and
interrelationships between the economy, the regional transportation system, and land use.
Strategies for achieving goals of available, safe, sustainable, and affordable transportation include:
1) investing in bus, light rail, and heavy rail transit; passenger and high-speed rail; pedestrian and
bicycle transportation corridors; and infrastructure and transportation demand management (ex.
carpooling to reduce demand for individual transport); 2) encouraging public participation in the
planning processes; and 3) educating the public about available transportation methods available
in the region.
The RTP/SCS specifically encourages future growth to occur within existing high quality transit
areas (HQTA), which are described as generally walkable transit districts or corridors that are
within 0.5 mile of a major transit stop or a transit corridor with 15-minute or less service frequency
during peak commute hours. The Project site falls within a HQTA as described by SCAG. The
RTP/SCS approach to sustainably manage growth and transportation demand would reduce the
distance and barriers between new housing, jobs, and services and would reduce vehicle travel and
GHG emissions. Overall, the strategies and policies in the RTP/SCS are projected to exceed the
GHG emission-reduction targets set forth by the California Air Resources Board under SB 375.
Los Angeles County Metropolitan Transportation Authority
The Long Range Transportation Plan (LRTP) for Los Angeles County, prepared by Metro, notes
that there is very limited ability to add capacity to regional highways and freeways over the next
25 years. Instead key efforts would focus on increasing the efficiency of the existing network and
encouraging greater reliance on carpooling and transit use.
Metro also invests heavily in the regional rail system, as the Expo LRT is a funded component of
Metro’s LRTP. Additionally, efforts would be undertaken to increase the efficiency of major City
streets through technical enhancements, providing bus priorities, and improving interchanges
between freeways, and arterial streets.
Metro’s Congestion Management Program (CMP) is a state-mandated program that was enacted
by the State Legislature with the passage of Proposition 111 in 1990. The CMP designates certain
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-25
Final EIR – January 2018
freeway segments and arterial roadways as CMP facilities. Generally, it is intended to address the
impact of local growth on the regional transportation system. Metro’s 2010 CMP for Los Angeles
County designates certain freeway segments and arterial roadways as CMP facilities. I-10 at
Lincoln Boulevard is the only designated CMP freeway monitoring location within Santa Monica.
The mainline freeway monitoring location nearest to the Project is I-10 at Lincoln Boulevard.
Based on the incremental Project trip generation estimates and Project trip assignment, the Project
would not add enough new traffic to exceed the freeway analysis criteria at this location. Because
incremental Project-related traffic in any direction during either weekday peak hour is projected
to be below the minimum criterion of 150 1-way vehicles per hour, Project impacts on the CMP
regional freeway system are considered to be insignificant and no further CMP freeway analysis
is required. Four intersections in the City are designated CMP arterial monitoring locations:
• Lincoln Boulevard and Santa Monica Boulevard
• Lincoln Boulevard and Pico Boulevard
• Cloverfield Boulevard and Santa Monica Boulevard
• 26th Street and Wilshire Boulevard
Local Regulations
City of Santa Monica Municipal Code Article 9, Chapter 9.28, Section 140, Bicycle Parking
The Santa Monica Municipal Code (SMMC) requires all new development to provide a minimum
number of bicycle parking spaces based on the primary uses of the site. Bicycle spaces must be
provided for both short-term and long-term parking needs. For example, in accordance with SMMC
Section 9.28.140, for public parks and recreation facilities, short-term bicycle parking spaces shall
be required for 5 percent of the maximum daily attendance and one long-term bicycle space shall be
provided per 20 employees. This section of the SMMC also requires bicycle parking to be provided
in a safe, secured, well-lit, and accessible location on the Project site with adequate signage.
City of Santa Monica Municipal Code Article 9, Chapter 9.53, Transportation Demand
Management
The purpose of the City’s TDM Ordinance is to proactively manage traffic congestion, reduce
automobile dependence, and enhance transportation choices by requiring trip reduction plans. The
ordinance applies to employers with 10 employees or more, including City staff, and developers
of Projects with 7,500 sf of floor area 16 units, or mixed use Project with 16 units or more. Under
the City’s TDM Ordinance, employers and developers shall strive to achieve an Average Vehicle
Ridership (AVR) employers and developers shall strive to achieve the AVR for their respective
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Final EIR – January 2018
land use designation. In accordance with SMMC 9.53.040 (AVR Targets), for Institutional/Public
Lands the Project vicinity, the target AVR is 1.6.
Under the City’s TDM Ordinance, employers with 10 to 49 employees are required to provide each
of their employees with information about carpooling/vanpooling, transit, air pollution, bicycle
routes and facility, walking and pedestrian safety, and alternatives to driving alone to work every
day. Employers of 50 or more employees are required to prepare an Emission Reduction Plan, which
shall include the option of 1) purchase of mobile source emission reduction credits or 2) preparation
and implementation of Employee Trip Reduction Plan to achieve the applicable AVR target.
Additionally, developers of Projects are required to prepare and implement a TDM plan that would
include physical and programmatic elements to reduce single occupancy vehicle trips and achieve
the targeted AVR. Annual monitoring is a requirement of the developer TDM Plan.
Santa Monica General Plan Land Use and Circulation Element
The General Plan LUCE for the City of Santa Monica was reviewed for objectives and policies that
would be applicable to the proposed Project. Objectives and policies presented in the LUCE of the
General Plan related to traffic that are potentially relevant to the proposed Project are listed below.
Goal LU2: Integrate Land Use and Transportation for Greenhouse Gas Emissions Reduction
Policy LU2.5 Vehicle Trip Reduction. Achieve vehicle trip reduction through
comprehensive strategies that 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.
Policy LU3.3 Focus on Local-Serving Uses. Emphasize uses which address local-serving
needs and daily resources necessary to reduce vehicle trips and vehicle miles traveled.
Goal LU4: Complete Sustainable Neighborhoods
Policy 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.
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Final EIR – January 2018
Policy LU4.4 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.
Policy LU4.7 Pedestrian, Bicycle, and Transit Access. Emphasize pedestrian and bicycle
access throughout the City, with a special focus on neighborhood gathering areas. Provide
direct and convenient bicycle and pedestrian connections between destinations. Prioritize
land use patterns that generate high transit ridership at major transit stops.
Goal LU8: Reduction of Vehicle Trips/Management of Congestion
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.
Policy LU8.2 Comprehensive Parking Management. Comprehensively manage parking
and parking policies to address housing affordability, congestion management, and air
quality goals. Facilitate the creation of shared parking, particularly within activity centers,
transit districts, and near Expo light-rail stations. Use pricing and other innovative
strategies to manage parking availability.
Goal LU15: Enhance Santa Monica’s Urban Form
Policy LU15.5 Pedestrian and Bicycle Connectivity. Encourage the design of sites and
buildings to facilitate easy pedestrian- and bicycle-oriented connections and to minimize
the separation created by parking lots and driveways.
Policy S2.1 Implement the VMT reduction policies of the Land Use and Circulation
Element of the General Plan including, but not limited to: focusing new growth in mixed-
use, transit-oriented districts; focusing new growth along existing corridors and nodes;
supporting the creation of complete, walkable neighborhoods with goods and services
within walking distance of most homes; and, promoting and supporting a wide range of
pedestrian, bicycle and transit improvements in the city.
Policy S2.3 Advance the No Net New Trips goal in the Land Use and Circulation
Element with TDM Projects such as expanded rideshare programs, parking management
strategies, as well as development impact fees for public transit infrastructure.
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3.7-28 Airport Park Expansion Project
Final EIR – January 2018
Goal T3: Ensure that Santa Monica’s Streets are Pleasant for all Users
Policy T3.1. Include elements that contribute to quality from the user’s perspective, not
just throughput for each mode.
Policy T5.5. Prioritize property access from transit, walking and bicycling over auto access.
Goal T6: Enable Everyone to Walk Comfortably Everywhere in Santa Monica
Policy T6.4 Use a combination of physical improvements and programs to promote
walking.
Goal T8: Provide a beautiful and attractive pedestrian environment throughout the City of Santa
Monica
Policy T8.4 Design buildings to prioritize pedestrian access from the street, rather than
from a parking lot
Goal T9: Create a Complete Network of High-quality Bicycle Facilities
Policy T9.9. Require large property development (defined as greater than one typical city
block) to provide through access for bicyclists and pedestrians.
Goal T19: Create an Integrated Transportation and Land Use Program that Seeks to Limit Total
Peak Period Vehicle Trips with a Santa Monica Origin or Destination
Policy T19.2. Impose appropriate TDM requirements for new development.
Goal T21: Use All Available Tools to Make the Most Effective Possible Use of the Transportation
System
Policy T21.3. TDM program requirements shall be triggered for new development
consistent with the LUCE performance standards.
Sunset Park Neighborhood Goals and Policies
Goal N17: Ensure that walking and bicycling are safe and comfortable on Sunset Park streets at
all times of day.
Policy N17.1. Implement the Sunset Park policies and actions detailed in the Circulation
Element. Implementation of the bicycle facility through the Santa Monica College campus
along the 17th Street corridor should be prioritized.
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Airport Park Expansion Project 3.7-29
Final EIR – January 2018
Santa Monica 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 that will improve 75 percent of the City’s bicycle network as well as a long
term 20-year Vision Plan. The implementation priorities include both bikeway and program
investments. Recommended programs include: events, awareness, information, education,
encouragement, enforcement and supporting programs. Recommended bikeway investments
include facility improvements such as new bicycle parking and network improvements that are
critical to the development of a high-quality continuous bikeway “backbone” and bicycle
treatments. The Bike Action Plan’s 5 year Implementation Plan identifies Airport Avenue between
23rd Street and South Bundy Drive as a second priority bikeway needing installation wayfinding
signs and shared lane markings, as part of the 4.85 mile Marine/Navy/Ozone/Dewey/Airport
Bikeway improvement from Barnard Way to Bundy. 23rd Street was also identified as a secondary
priority bikeway. Additionally, the 5-year Vision Plan outlines a 3.0 mile recreational loop (shared
use path) roughly circumnavigating Santa Monica Airport, Airport Park, and Clover Park as a
recommended bikeway project. The implementation plan also prioritized construction of an
intersection improvement at 23rd Street and Dewey Street to improve sightlines and enhance
bicycle and pedestrian crossings between Dewey Street and Airport Avenue and at the intersection
of 23rd Street and Ashland Avenue. Further, the SMC Bundy Campus (located directly across from
the existing Airport Park) was identified as a critical connection.
3.7.3 Impact Assessment and Methodology
Thresholds for Determining Significance
Appendix G of 2017 CEQA Guidelines provides a set of screening questions that address impacts
with regard to transportation/traffic. Specifically, the Guidelines state that a proposed Project may
have a significant impact on transportation/traffic if:
a) The Project would conflict with an applicable plan, ordinance or policy establishing
measures of effectiveness for the performance of the circulation system, taking into account
all modes of transportation including mass transit and non-motorized travel and relevant
components of the circulation system, including but not limited to intersections, streets,
highways and freeways, pedestrian and bicycle paths, and mass transit;
b) The Project would conflict with an applicable congestion management program, including,
but not limited to level of service standards and travel demand measures, or other standards
established by the county congestion measurement agency for designated roads or
highways;
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Final EIR – January 2018
c) The Project would result in a change in air traffic patterns, including either an increase in
traffic levels or a change in location that results in substantial safety risks;
d) The Project would substantially increase hazards due to a design feature (e.g., sharp curves
or dangerous intersections) or incompatible uses (e.g., farm equipment);
e) The Project would result in inadequate emergency access; and/or
f) The Project would conflict with adopted policies, plans, or programs regarding public
transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of
such facilities.
Non-Applicable Threshold(s):
Threshold (c) Air Traffic Patterns: While the Project site is located adjacent to SMO, development
is proposed in an area which has been designated non-aviation land. The Project site is located
within airport influence area for SMO (see section 3.8, Land Use), however Project would not
change air traffic patterns. As discussed in Section 3.5, Land Use and Planning, of this EIR, the
Project site is located outside of the runway approach zone and designated runway protection zones
(RPZs) for SMO (see Figure 3.7-1). As described in Section 3.7, Hazards and Hazardous
Materials, the Project would require a Federal Aviation Administration (FAA) Part 77 Clearance
Permit to be submitted to and approved by the FAA to ensure airport land use compatibility.
Through this process, the Project would be required to avoid new development that may cause
airspace obstructions and to reduce safety risks associated with airport hazards and accidents. The
Project site is located outside of the designated RPZs for SMO and would not introduce objects
into the established flight paths. The Project proposes the development of ground-level recreational
uses and small structures that would not otherwise interfere with the operation of aircraft. The
Project would increase the amount of lighting within the vicinity of the existing runway lighting.
The 70-foot high light standards for the sports fields fall within the FAA’s purview in Part 77 of
the Federal Aviation Regulations obstruction clearance regulations and require submittal of a Form
7460-1 to the FAA. In accordance with FAA Part 77, the FAA would review both the proposed
structures and lighting as part of its Form 7460-1 review responsibilities. With FAA review and
approval of a Part 77 Clearance Permit, the Project’s proposed improvements would occur in
accordance with FAA Part 77. All construction associated with the Project would be compatible
with existing airport uses. Therefore, further analysis of this issue in this EIR is not required.
Based on Appendix G of the CEQA Guidelines, the City of Santa Monica applies the following
significance thresholds with respect to traffic impacts:
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Final EIR – January 2018
Operational Traffic Analysis Thresholds – Intersections
The City of Santa Monica has established criteria for assessing whether Project-related traffic
increases result in significant impacts on operating conditions of intersections. The significance
criteria, which are summarized in Table 3.7-6, depend on the previous 1984 LUCE classification
of the streets at the intersection (i.e., arterial, collector, or local streets) and the operating conditions
of the intersection under both the Approval Year (2017) and Future Year (2025) Plus Project traffic
conditions.2 Therefore, the existing significance criteria based on the previous LUCE street
classifications are used. The potential significance of a Project’s impact is measured by either the
change in average vehicular delay (measured in seconds) or by a change in the intersection
operating conditions to unacceptable conditions.
If the Project LOS is F, however, significance is defined in terms of a change in V/C ratio (as
calculated by the HCM operational method), since the average vehicular delay cannot be
calculated using the HCM operational method if the intersection exhibits oversaturated traffic
conditions.
Using the City of Santa Monica significance criteria, a project would not be considered to have a
significant impact at an intersection if, for example, it is on an arterial street operating at LOS D
with the addition of project traffic and the incremental change in the average vehicle delay is less
than 15 seconds. If the intersection is operating at LOS E after the addition of project traffic and
the average vehicle delay increases by any amount, however, this would be considered a significant
project impact. All impacts on intersections projected to operate at LOS F are based on the V/C
ratio, with project-related increases of 0.005 or greater considered significant.
The City of Los Angeles has also established threshold criteria to determine significant traffic
impact of a proposed project in its jurisdiction. Under the Los Angeles Department of
Transportation (LADOT) guidelines, an intersection would be significantly impacted with an
increase in V/C ratio equal to or greater than 0.04 for intersections operating at LOS C, equal to
or greater than 0.02 for intersections operating at LOS D, and equal to or greater than 0.01 for
intersections operating at LOS E or F after the addition of project traffic. Intersections operating
at LOS A or B after the addition of the project traffic are not considered significantly impacted
regardless of the increase in V/C ratio.
2 The significance criteria are based on the previous street classifications of the 1984 LUCE. The 2010 LUCE has adopted a different typology
for streets within the city, but the significance criteria have not yet been revised to reflect the new nomenclature.
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Final EIR – January 2018
Table 3.7-6. City of Santa Monica and Los Angeles Significant Impact Criteria for
Intersections
Baseline Scenario Baseline plus Project Scenario
City of Santa Monica
If LOS = A, B, or C Significant Impact If:
Collector street intersection
Average vehicle delay increase is ≥ 15 seconds
or
LOS becomes D, E, or F
Arterial intersection
Average vehicle delay increase is ≥ 15 seconds
or
LOS becomes E or F
If LOS = D Significant Impact If:
Collector street intersection Any net increase in average seconds of delay per vehicle
Arterial intersection
Average vehicle delay increase is ≥ 15 seconds
or
LOS becomes E or F
If LOS = E Significant Impact If:
Collector street intersection Any net increase in average seconds of delay per vehicle Arterial intersection
If LOS = F Significant Impact If:
Collector street intersection HCM V/C ratio net increase is ≥ 0.005 Arterial intersection
City of Los Angeles
Final V/C Ratio Significant Impact If:
If LOS = C Project-related Increase in V/C is ≥ 0.040
If LOS = D Project-Related Increase in V/C is ≥ 0.020
If LOS = E or F Project-Related Increase in V/C is ≥ 0.010
DEFINITIONS:
HCM – Highway Capacity Manual. V/C – Volume-to-Capacity Ratio – This ratio is based on the amount of traffic traveling
through the intersection, the lane geometries, and other factors affecting capacity such as one-street parking, bus operations near
the intersections, and pedestrian volumes at the street crosswalks. Delay – Average stopped delay per vehicle, in seconds
LOS: Refer to Table 3.7-3 for definitions.
Note: Functional street classifications for Santa Monica intersections in this table is from the City’s previous Circulation
Element. The 2010 LUCE has adopted a different typology for streets within the City but the significance criteria have not yet
been revised.
Source: Fehr & Peers 2017 – Appendix F.
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Final EIR – January 2018
As previously stated, a key provision of SB 743, passed in September 2013, is the elimination of
vehicle delay and LOS as a CEQA significance criterion in urban areas. The basic reason for this
change at the State level is the recognition that there can be conflicts between improvements that
benefit automobiles versus those that benefit other modes of transportation in urban areas (e.g.,
widening streets to improve automobile LOS can often be to the detriment of pedestrians), that
continued reliance on automobiles is at odds with state objectives to reduce GHGs (through
reductions in vehicle miles of travel), and that mitigation for increased vehicle delay often involves
measures which may increase auto use and discourage alternative forms of transportation. When
employed in isolation, LOS can lead to ad hoc roadway expansions that deteriorate conditions on
the network as a whole, or discourage transportation improvements that improve street function
overall by providing better level of service for vehicles, but decreasing service for transit
pedestrians or bicycles. Among the issues with vehicle LOS identified by the Governor’s Office
of Planning and Research (OPR) are the following:
• LOS is biased against “last in” development;
• LOS scale of analysis is too small;
• LOS mitigation is problematic (e.g., physical constraints limit roadway capacity upgrades);
• LOS mischaracterizes transit, bicycle and pedestrian improvements as detrimental to
transportation (i.e., improvements for pedestrians may result in degraded vehicle LOS);
• Use of LOS thresholds implies false precision; and,
• As a measurement of delay, LOS measures motorist convenience, but not a physical impact
to the environment.
According to the legislative intent contained in SB 743, changes to the current practice of using
LOS are necessary to, “More appropriately balance the needs of congestion management with
statewide goals related to infill development, promotion of public health through active
transportation, and reduction of greenhouse gas emissions.”
Pursuant to SB 743, OPR released a revised proposal for changes to the CEQA Guidelines in
January 2016. OPR’s changes to the CEQA Guidelines propose that Projects utilize VMT as the
replacement metric for LOS in the context of CEQA. However, since OPR has not yet adopted
these draft CEQA Guidelines, this EIR continues to evaluate the Project using the City’s adopted
significance criteria of auto delay (i.e., LOS).
Operational Traffic Analysis Thresholds - Neighborhood Street Segments
The City of Santa Monica also has adopted significance thresholds used to evaluate potential traffic
impacts on neighborhood (i.e., residential) street segments. Since the Project site is located in
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3.7-34 Airport Park Expansion Project
Final EIR – January 2018
proximity to the Sunset Park neighborhood, a street segment impact analysis was performed to
assess the impacts along streets in the Project vicinity under typical weekday conditions. The
analyzed segments were chosen for their proximity to the Project and the operational constraints
of the road network in this area. Because there are limited north-south streets between Bundy
Drive/Centinela Avenue and Lincoln Boulevard in the vicinity of the Project, 23rd Street and
Walgrove Avenue experience relatively high volumes of cut-through traffic. The selected analysis
segments represent critical entry points to the surrounding neighborhoods through which Project-
related traffic may travel. The analysis was conducted for the following segments:
1. 23rd Street north of Dewey Street
2. Dewey Street west of 23rd Street
3. Walgrove Avenue south of Airport Avenue
4. Rose Avenue west of Walgrove Avenue
5. Rose Avenue east of Walgrove Avenue
6. Walgrove Avenue south of Rose Avenue
For the Project, a transportation impact to neighborhood street segments would be significant
based on the thresholds in Table 3.7-7.
Table 3.7-7. City of Santa Monica Impact Criteria for Collector, Feeder, and Local Street
Segments
Street Classification A traffic impact is significant if the Base Average Daily Traffic Volume
(ADT) is:
Collector Street greater than 13,500 and
there is a net increase*
of one trip or more in
ADT due to project
related traffic
greater than 7,500 but
less than 13,500 and the
project related traffic
increases* the ADT by
12.5% or the ADT
becomes 13,500 or
more
less than 7,500 and the
project related traffic
increases* the ADT by
25%
Feeder Street greater than 6,750 and
there is a net increase*
of one trip or more in
ADT due to project
related traffic
greater than 3,750 but
less than 6,750 and the
project related traffic
increases* the ADT by
12.5% or the ADT
becomes 6,750 or more
less than 3,750 and the
project related traffic
increases* the ADT by
25%
Local Street greater than 2,250 and
there is a net increase*
of one trip or more in
ADT due to project
related traffic
greater than 1,250 but
less than 2,250 and the
project related traffic
increases* the ADT by
12.5% or the ADT
becomes 6,750 or more
less than 1,250 and the
project related traffic
increases* the ADT by
25%
* Average Daily Traffic Volume "increase" denotes adverse impacts; "decrease" denotes beneficial impacts.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-35
Final EIR – January 2018
Further, the City of Los Angeles has established threshold criteria that are used to determine if a
project has a significant traffic impact on the street system based on an increase in the projected
final average daily traffic volumes, as indicated below:
Projected Average Daily Traffic
with Project (Final ADT)
Project-Related Increase in ADT
Less than 1,000 120 trips or more
1,000 or more 12 percent or more of final ADT
2,000 or more 10 percent or more of final ADT
3,000 or more 8 percent or more of final ADT
Operational Traffic Analysis – Regional Facilities
The 2010 Congestion Management Program for Los Angeles County requires that when an
environmental impact report is prepared for a proposed Project, traffic and transit impact analyses
be conducted for select regional facilities based on the quantity of Project traffic expected to use
these facilities (Los Angeles County Metropolitan Transportation Authority, June 2010). The CMP
guidelines require that the geographic scope of the study area to be analyzed is the first issue to be
addressed. The criteria for determining the study area for CMP arterial monitoring intersections
and for freeway monitoring locations are:
• All CMP arterial monitoring intersections where the proposed Project will add 50 or more
trips during either the A.M. or P.M. weekday peak hours of adjacent street traffic.
• All CMP mainline freeway monitoring locations where the proposed Project will add 150
or more trips, in either direction, during either the A.M. or P.M. weekday peak hours.
• A significant Project-related CMP impact would be identified if:
• the Project would generate increase traffic by 2 percent (V/C greater than 0.02) on a CMP
facility causing it to operate at LOS F or if the facility is already at LOS F, the Project
traffic causes an incremental change in the V/C ratio of 0.02 or greater.
Operational Traffic Analysis Thresholds – Alternative Transportation Facilities
Operational impacts to alternative transportation facilities would be considered potentially
significant if the Project would conflict or hinder the goals of plan, programs, or policies
supporting alternative transportation.
Construction Traffic Analysis Thresholds
Construction traffic impacts from Project construction trucks, construction vehicles, etc., would
be considered potentially significant if Project construction would materially interfere with the
area traffic flow, cause unsafe conditions, or introduce substantial truck traffic through a residential
area.
3.7 TRANSPORTATION AND TRAFFIC
3.7-36 Airport Park Expansion Project
Final EIR – January 2018
Methodology
Operational Traffic – Intersection Analysis
The analysis presented below summarizes the results of the Transportation Impact Analysis
prepared for the Project by Fehr & Peers (see Appendix F). The scope of the Transportation Impact
Analysis conforms to standards set forth by both the City of Santa Monica and the City of Los
Angeles. The roadways, intersections, and other transportation systems included in the
Transportation Impact Analysis were identified by Fehr & Peers in joint process with both the City
of Santa Monica staff and LADOT, based on the magnitudes and specific locations of Project-
generated demand on transportation systems, particularly traffic and the potential for newly
generated trips to impact streets and roadways in the Project area. Previous area circulation studies
were considered to ensure that potentially affected facilities were included in the analysis.
Peak hour traffic impacts for the Project were evaluated during typical weekday morning
(7:30 A.M. to 9:30 A.M.) and afternoon (5:00 P.M. to 7:00 P.M.) peak periods. In order to evaluate
the potential traffic impacts of the proposed Project on the surrounding street system, traffic
forecast estimates of the Project’s Approval Year (2017) and Future Year (2025) were developed
both with and without the anticipated Project-generated traffic.
To evaluate the potential impacts of the proposed Project on the surrounding street system, it was
necessary to develop estimates of Approval Year (2017) and Future Year (2025) traffic forecasts
in the area both without and with Project traffic:
• As part of the City’s LUCE update, the City developed its first comprehensive, citywide
Transportation Demand Forecast Model (TDFM). The TDFM was recently calibrated to a
base year of 2013, based on 2013 land use data and 2013 traffic counts. The City of Santa
Monica’s land use data is supplemented by Southern California Association of
Governments (SCAG) traffic analysis zone (TAZ)-based data for areas in the City of Los
Angeles bordering the City of Santa Monica. The TDFM forecasts future conditions for
the City’s transportation network in the form of traffic volumes for daily, as well as A.M.,
P.M. , and weekend midday peak hours. The model contains the major roadways in the City
and considers the trip reduction effects of walking, bicycling, parking, and transit,
including the Expo Line. The model also includes all identified development projects and
street network changes. The TDFM contains a number of enhancements that allow it to
capture the effects of land use and circulation element policy initiatives on traffic
congestion. These enhancements include the effects of sustainable development patterns
(e.g., mixed-use and transit-oriented development), urban streetscape design factors,
alternative transportation networks, parking management, and TDM programs. To analyze
level of service, post-processed model volumes are loaded into the City of Santa Monica’s
VISTRO database.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-37
Final EIR – January 2018
• To develop the Approval Year scenario without the Project, the existing traffic volumes
were increased based on the set of known cumulative projects. A field check was conducted
to ensure that the under-construction cumulative projects were not open during the 2017
counts. The cumulative projects currently under construction were all conservatively
assumed to open by the end of the Approval Year (2017) scenario and cumulative project
trips were added to existing volumes collected in both late 2016 and early 2017. Trip
generation for the cumulative projects was estimated based on a combination of TDFM trip
generation rates, previously conducted transportation studies, and the Trip Generation
Manual, 9th Edition (Institute of Transportation Engineers, [ITE] 2012). Cumulative
project trip distribution and assignment was informed by the Transportation Demand
Forecast Model (TDFM). These projected traffic volumes, referred to as Approval Year
No Project projections, represent the conditions expected during the project’s Approval
Year and provide the baseline for the Approval Year plus Project traffic impact analysis.
• To develop the Future Year (2025) Scenario without the Project, the land use file in the
TDFM was updated to include the list of approved and pending (proposed) projects. These
projects are conservatively assumed to all be completed between 2013 (TDFM baseline)
and Future Year (2025). Outside of the City of Santa Monica, the land use and through
trips were developed using linear interpolation based on the LUCE forecast (2030). These
projected traffic volumes, referred to as Future Baseline projections, represent the
conditions expected during year 2025 and provide the baseline for the Future plus Project
traffic impact analysis.
• The traffic generated by the Project was estimated and assigned to the surrounding street
system. The Project traffic was added to the Approval Year No Project scenario and Future
Baseline projections to form the Approval Year plus Project and Future Year plus Project
traffic projection scenarios, respectively.
Once these traffic volume projections were developed, LOS analysis was conducted for the study
intersections. The difference between no Project and plus Project scenarios represents the
incremental changes in traffic attributable to the Project itself. As described above, in accordance
with the City of Santa Monica’s adopted impact analysis, the "Operational Analysis" method from
HCM was employed to perform signalized and unsignalized intersection LOS analysis at all
signalized study intersections.
The seven signalized intersections located in or sharing jurisdiction with the City of Los Angeles
were also analyzed per the requirements in Transportation Impact Study Guidelines (LADOT,
December 2016). According to Transportation Impact Study Guidelines, signalized intersections
located in the City of Los Angeles are analyzed using the CMA method of intersection capacity
calculation (Transportation Research Board, 1980). Under the CMA methodology, LOS for each
intersection is determined by summing the highest V/C ratios for corresponding movements. The
V/C ratio is then matched to the appropriate LOS.
3.7 TRANSPORTATION AND TRAFFIC
3.7-38 Airport Park Expansion Project
Final EIR – January 2018
It should be noted that the HCM and CMA methods of LOS analysis, as adopted by the City of
Santa Monica and the City of Los Angeles, respectively, are different methods of estimating LOS.
Though both use rating systems A through F, their results are not directly comparable.
Approval Year (2017) and Future Year (2025) No Project Conditions
CEQA Guidelines Section 15125 directs that an EIR “must include a description of the physical
environmental conditions in the vicinity of the Project, as they exist at the time the notice of
preparation is published, or if no notice of preparation is published at the time environmental
analysis is commenced, from both a local and regional perspective. These environmental settings
will normally constitute the baseline physical conditions by which a lead agency determines
whether an impact is significant.”3
However, the CEQA Guidelines and the Courts have recognized that the date for establishing an
environmental baseline cannot be rigid. The California Supreme Court determined that “[n]either
CEQA nor the CEQA Guidelines mandate a uniform, inflexible rule for determination of the
existing conditions baseline. Rather, an agency enjoys the discretion to decide, in the first instance,
exactly how the existing physical conditions without the Project can most realistically be
measured, subject to review, as with all CEQA factual determinations, for support by substantial
evidence.”4 The Supreme Court further stated that “Environmental conditions may vary from year
to year and in some cases it is necessary to consider conditions over a range of time periods. In
some circumstances, peak impacts or recurring periods of resource scarcity may be as important
environmentally as average conditions. Where environmental conditions are expected to change
quickly during the period of environmental review for reasons other than the Project, Project
effects might reasonably be compared to predicted conditions at the expected date of approval,
rather than to conditions at the time analysis is begun.”5
In compliance with CEQA case law, this EIR uses the Project’s anticipated Approval Year (2017)
as the baseline environmental setting. The purpose of establishing the Project’s approval year as
the baseline for the traffic impact analysis is to develop a more accurate representation of traffic
conditions that are expected to change over the time period in which the EIR is being prepared. A
number of Court decisions have supported this alternative use of baseline traffic levels – The Court
of Appeal ruled that “…for instance, where the issue involves an impact on traffic levels, the EIR
might necessarily consider the normal increase in traffic over time. Since the environmental review
process can take a number of years, traffic levels as of the time the Project is approved may be a
3 (14 Cal. Code Reg. 15125 [a])
4 Communities for a Better Environment v. South Coast Air Quality Management District (2010) 48 Cal.4th 310, 320
5 Communities for a Better Environment, supra, 48 Cal.4th at p. 328
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-39
Final EIR – January 2018
more accurate representation of the existing baseline against which to measure the impact of the
Project.”6 Additionally, the Supreme Court stated that “to the extent a departure from the ‘norm[]’
of an existing conditions baseline promotes public participation and more informed decision
making by providing a more accurate picture of a proposed Project's likely impacts, CEQA permits
the departure. Thus, an agency may forego analysis of a Project's impacts on existing
environmental conditions if such an analysis would be uninformative or misleading to decision
makers and the public”.7 Because an environmental baseline that differs from the date of the NOP
is reasonable and results in a more accurate environmental analysis of traffic impacts, this EIR
uses the estimated time of Project approval (2017) as the baseline for analyzing traffic impacts. In
addition, this EIR uses future year 2025 as the future baseline for analyzing cumulative traffic
impacts.
Project Trip Generation Methodology
The estimated Project trip generation is shown in Table 3.7-8. Project trip generation was estimated
by subtracting the trip generation associated with existing park land to be renovated and adding
the additional park land and park facilities that are proposed in the Project. City staff reviewed the
assumptions of park use and trip generation estimates.
Approximately 1.5 acres of the existing park will be renovated to accommodate the 60 to 80
community garden plots. One acre that currently accommodates the existing 58-space northern
parking lot will be re-developed with additional recreational amenities as part of the Project, while
approximately 12 acres of non-aviation land adjacent to the existing park will be developed as part
of the Project. To determine the Project’s net increase in trip generation, these trips from existing
uses were subtracted from the estimated Project trips (Table 3.7-8).
The trip generation rate for a developed park was taken from the San Diego Association of
Governments (SANDAG) Brief Guide of Vehicular Traffic Generation Rates for the San Diego
Region (2002).
Trips generated by the Project’s pickleball courts assumed four players per court. The courts are
expected to be more intensely used during daylight hours, with demand tapering off beginning
around the P.M. peak hour.
6 Save Our Peninsula Committee v. Monterey County Board of Supervisors (2001) 87 Cal.App.4th 99, 125-126, and
Pfeiffer v. City of Sunnyvale City Council (“Pfeiffer”), Case No. H036310
7 Neighbors for Smart Rail v. Exposition Metro Line Construction Authority (2013) 57 Cal. 4th 439.
3.7 TRANSPORTATION AND TRAFFIC
3.7-40 Airport Park Expansion Project
Final EIR – January 2018
Table 3.7-8. Project Trip Generation
Land Use Size Daily
Trips
A.M. Peak Hour Trips P.M. Peak Hour Trips
In Out Total In Out Total
Proposed Uses
City Park (to be renovated) -1.5 acres (75) (2) (1) (3) (3) (3) (6)
City Park (Developed, new)1 1.0 acres 51 1 1 2 2 2 4
Pickleball courts4 3 courts 224 12 8 20 8 8 16
Community gardens5 80 plots 192 8 8 16 8 8 16
Soccer Fields (new)3 2 fields 136 0 0 0 40 28 68
Net New Total 528 19 16 35 55 43 98
Notes:
1 Trip generation rate from Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, SANDAG, April 2002.
The existing 8.3-acre (total) Airport Park is comprised of a 3-acre sports field, a 1-acre dog park, approximately 1.1 acres of
parking/circulation, and approximately 3.2 acres of open park space. Approximately 1.5 acres of the existing park will be
converted to the proposed community gardens.
2 Trips estimated based on observations conducted at three dog parks in Lafayette, CA.
http://lovelafayette.org/home/showdocument?id=3138 TJKM Associates. Supplemental Traffic and Circulation Impact Analysis
for the Proposed Homes at Deer Hill Project, January 23, 2015.
3 Trip generation developed through a series of assumptions regarding potential utilization of the soccer fields. The generation
assumes the use of the existing field divided into 3 separate practice areas; the two new fields are assumed to be used as single
fields during the weekday P.M. peak hour. No field use is anticipated for the A.M. peak hour, per Santa Monica Community &
Cultural Services. The existing field trip generation was refined based on counts and field observations conducted April 28-29,
2017 during peak field reservation times compared with the field reservation schedule.
4 The use of pickleball courts is based on information from the USA Pickleball Association, assuming 4 players per court, and
less-than-full utilization of courts during the P.M. peak hour.
5 Trip generation for the community gardens assumes that 10% of the available plots will be visited by auto drivers during the
A.M. and P.M. peak hours.
Trips generated by the Project’s community gardens assumes that 10 percent of available plots
will be visited by drivers during the A.M. and P.M. peak hours.
Finally, trips generated by the park’s soccer field uses were estimated through a series of
assumptions regarding the potential utilization of those fields. The generation assumes that the two
new fields will be used as single, full-size fields during the weekday P.M. peak hour. No field use
is anticipated for the weekday A.M. peak hour. The estimate of trips generated by the park’s
proposed fields was further refined based on existing driveway counts and field observations
conducted April 28 and 29, 2017 during peak reservation times for the park’s existing fields,
according to the field reservation schedule provided by the City of Santa Monica. These data were
used to calibrate estimates of pick-up and drop-off traffic for typical weekday soccer practice.
For a conservative analysis, no trip credit was taken for aviation related uses on SMO property.
The Project is expected to generate an estimated net increase of 528 daily trips, including 35 net
new trips (19 inbound/16 outbound) during the A.M. peak hour and 98 net new trips (55 inbound/43
outbound) during the P.M. peak hour.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-41
Final EIR – January 2018
Street Segment Significant Impact Criteria
A street segment impact analysis was performed to assess the impacts along streets adjacent to the
Project under typical weekday conditions. The analysis was conducted for the following segments,
which are illustrated in Figure 1 of Appendix F:
1. 23rd Street north of Dewey Street
2. Dewey Street west of 23rd Street
3. Walgrove Avenue south of Airport Avenue
4. Rose Avenue west of Walgrove Avenue
5. Rose Avenue east of Walgrove Avenue
6. Walgrove Avenue south of Rose Avenue
New weekday daily traffic volume counts (ADT) were collected at these locations in March 2017.
The daily traffic count data is provided in Appendix F. The City of Santa Monica impact criteria
applied to evaluate potential traffic impacts on street segments are based on the existing daily
traffic and the projected level of increase that can be attributed to the Project. The significant
impact criteria for collector, feeder, and local streets are provided in Table 3.7-7. For the purpose
of applying these criteria, Airport Avenue was treated as a collector street.
Project Traffic Distribution and Trip Assignment
The trip distribution pattern was informed by a select zone analysis of the Project using the City’s
TDFM. Following consultation with City of Santa Monica staff, it was determined to be
appropriate for distributing new trips generated by the Project. The park serves both its immediate
surrounding neighborhoods as well as those in the general area around the City of Santa Monica.
The following distribution pattern, shown in Figure 6 of Appendix F, was used:
• 20 percent to and from the northwest (western and central Santa Monica)
• 15 percent to and from the north (eastern Santa Monica and West Los Angeles)
• 15 percent to and from the northeast (Westwood, Rancho Park, Palms)
• 20 percent to and from the southeast (Mar Vista and Culver City)
• 15 percent to and from the south (Mar Vista and Culver West)
• 15 percent to and from the west (southern Santa Monica and Venice)
3.7 TRANSPORTATION AND TRAFFIC
3.7-42 Airport Park Expansion Project
Final EIR – January 2018
The Project trip turning movements, based on the distribution above, are shown in Figure 6 of
Appendix F. Vehicle access to the Project will continue to be from the existing 60-space parking
lot accessed directly via Airport Avenue, as well as from the newly relocated intersection of
Donald Douglas Loop South and Airport Avenue, west of the current intersection location. The
traffic to be generated by the Project was assigned to the street network using the distribution
pattern described in Figure 6 of Appendix F. Several freeway intersections closest to the Project
site are located within the jurisdiction of the City of Los Angeles (i.e., the I-10 Freeway
interchange with both Centinela Avenue and South Bundy Drive, and the I-405 Freeway
interchange with National Boulevard). Due to the Project’s relatively limited trip generation,
distribution patterns towards the City of Santa Monica, and the greater number of vehicles that
would be required to trigger significant impacts based on the City of Los Angeles’ for assessing
thresholds of significance when determining traffic impacts under the CMA Impact methodology,
the LADOT did not request evaluation of these interchanges during coordination with the LADOT.
Operational – Regional Facilities & CMP Transit Analysis
The analysis of the Project’s impacts on regional facilities is based on the CMP guidelines
established in the 2010 CMP for Los Angeles County which analyze impacts to Arterial
Intersections, and Mainline Freeway Locations, and the CMP Highway and Roadway system.
Potential increases in transit person trips generated by the Project were estimated as follows.
Section B.8.4 of the CMP provides a methodology for estimating the number of transit trips
expected to result from a proposed Project based on the Projected number of vehicle trips. This
methodology assumes an Average Vehicle Ridership (AVR) factor of 1.4 in order to estimate the
number of person trips to and from the Project site and then provides guidance regarding the
percent of person trips assigned to public transit depending on the type of use (commercial/other
versus residential) and the proximity to transit services.8 To estimate Project-generated transit
trips, person trips should be multiplied by one of these factors:
3.5 percent of Total Person Trips Generated for most cases, except:
• 10 percent primarily Residential within 1.4 mile of a CMP transit center
• 15 percent primarily Commercial within 1.4 mile of a CMP transit center
• 7 percent primarily Residential within 1.4 mile of a CMP multi-modal transportation center
8 On and after January 1, 2016, Employers shall strive to achieve and Developers shall achieve the City of Santa
Monica AVR Targets established per SMMC Section 9.53.040. In accordance with SMMC 9.53.040 (AVR Targets),
for Institutional/Public Lands the Project vicinity, the target AVR is 1.6. The methodology applied for CMP herein
is consistent with the CMP analysis guidelines.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-43
Final EIR – January 2018
• 9 percent primarily Commercial within ¼ mile of a CMP multi-modal transportation center
• 5 percent primarily Residential within ¼ mile of a CMP transit corridor
• 7 percent primarily Commercial within ¼ mile of a CMP transit corridor
• 0 percent if no fixed-route transit services operate within one mile of the Project
Operational Traffic Analysis – Alternative Transportation Facilities
The analysis of the Project’s impacts on alternative transportation facilities reviews to what extent
the Project would disrupt, interfere, or conflict with existing alternative transportation facilities
and program, plans, and policies supporting alternative transportation. As part of this analysis,
connectivity of the Project site via transit, bicycle and pedestrian facilities with the residential
neighborhoods within the City was reviewed for feasibility and convenience and ease of access,
as well as safety. This included review of transit line service frequency (headways), transit
operation in both peak and non-peak periods, direct transit access (i.e., need for transfers), and the
suitability of planned bicycle and pedestrian facilities to provide access to the site for City
residents.
Construction Traffic
The analysis of the Project’s construction impacts considers heavy truck traffic generated from
excavation, construction vehicles, and material and equipment delivery over the duration of the
11- to 12-month construction period. Additionally, the analysis evaluates the potential for
construction related impacts to traffic flows, reduction in lane capacities, parking availability,
delays or alterations of transit service, and impacts to pedestrian and bicycle circulation.
3.7.4 Project Impacts and Mitigation Measures
Construction Impacts
Would traffic impacts associated with construction activities materially interfere with the area
traffic flow, cause unsafe conditions, or introduce substantial truck traffic through a residential
area?
T-1 Construction of the Project would create potentially significant short-term
impacts in the Project vicinity due to traffic lane and sidewalk closures, transit
delays, and disruption of pedestrian and bicycle circulation, associated with
operation of heavy trucks, demolition of paved surface areas adjacent to
Airport Avenue, construction vehicles, and construction fencing, particularly
3.7 TRANSPORTATION AND TRAFFIC
3.7-44 Airport Park Expansion Project
Final EIR – January 2018
in combination with construction traffic generation by nearby cumulative
pending development; impacts would be less than significant with mitigation.
Impact Description (T-1)
The precise construction timeline for the Project depends on the timing of Project approval. For
the purposes of the EIR, construction work is assumed to begin in 2019, with the expanded portion
of the park opening to the public in 2020. Demolition of existing uses on the Project site would
occur over approximately one month, excavation and grading would occur for a period of one to
two months, and construction of the park and recreational amenities, and associated infrastructure
would occur over approximately 11 to 12 months, with occupancy and operation anticipated in
2020.
Construction Project traffic would include haul trucks, cement trucks, equipment and material
delivery trucks, and construction worker vehicles. Specifically, during the excavation phase, haul
trucks would export an estimated 5,000 cubic yards (cy) of soil at a rate of approximately
278 double-trailer haul “end dump” trucks per day (10 trucks per hour, 4 hours per day, 18 cubic
yards per load). Haul truck timing and frequency would be dictated by the availability of truck
haulers during the timeframe of work activity. This phase would also involve vehicles to provide
materials, support excavation, and transport employees. Construction worker vehicles, materials
deliveries, and other construction-related trips are expected to add dozens of often heavy truck
trips per day to area streets throughout the construction period. In total, construction traffic could
range up to a maximum of 278 vehicle trips per day over 4 to 8 weeks of excavation during which
heavy truck traffic could comprise a majority of heavy truck trips during this phase of construction.
Demolition of Donald Douglas Loop South would occur in a manner to provide continued access
to airport uses north of Airport Park. The construction haul route would be determined in
coordination with City staff and residential streets would be avoided. Construction related
increases in traffic would be short-term in nature and lower in volume than the operational vehicle
trips associated with the proposed Project. Therefore, it would not contribute significantly to long-
term traffic congestion.
However, increased construction traffic on streets, particularly large haul trucks and other heavy
equipment (e.g., cement trucks and cranes), may disrupt traffic flows, reduce lane capacities, and
generally slow traffic movement. In addition, such traffic could interfere with or delay transit
operations and disrupt pedestrian and bicycle circulation. Other potential construction-related
impacts include idling, parked or queued heavy trucks that could potentially obstruct visibility.
Project construction may also require the temporary or extended closure of adjacent traffic lanes
and sidewalks on surrounding streets (i.e., Airport Avenue) to accommodate excavation for utility
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-45
Final EIR – January 2018
installation, operation of construction equipment, installation of Project improvements, etc.
Depending on final construction plan details, such lane and sidewalk closures could extend from
a single day to several weeks. Project construction activities (e.g., lane closures) could also cause
delays or rerouting of existing transit service.
As a result, construction impacts are considered potentially significant. Implementation of
mitigation measure MM T-1 would require preparation of a Construction Impact Mitigation Plan
to address construction traffic routing and control, vehicular and pedestrian safety,
pedestrian/bicycle access and parking, street closures, and construction parking. This Plan would
be prepared to address traffic impacts that could occur during Project construction, which is
anticipated to occur over 21 months. Implementation of mitigation measure MM T-1 would reduce
the Project’s construction traffic impact to less than significant with mitigation.
Mitigation Measures
MM T-1 The City shall prepare, implement and maintain a Construction Impact Mitigation
Plan for review and approval prior to issuance of a building permit to address and
manage traffic during construction and shall be designed to:
• Prevent traffic impacts on the surrounding street network
• Minimize parking impacts both to public parking and access to private parking
to the greatest extent practicable
• Ensure safety for both those constructing the Project and the surrounding
community
• Prevent substantial truck traffic through residential neighborhoods
• Provide for coordination with adjacent or nearby construction Projects
The Construction Impact Mitigation Plan shall be subject to review and approval
by the following City departments: Public Works, Fire, Planning and Community
Development, and Police to ensure that the Plan has been designed in accordance
with this mitigation measure and meets City standards. This review shall occur
prior to issuance of grading or building permits. It shall, at a minimum, include the
following:
Ongoing Requirements throughout the Duration of Construction
• A detailed Construction Impact Mitigation Plan for work zones shall be
maintained. At a minimum, this shall include parking and travel lane
configurations; warning, regulatory, guide, and directional signage; and area
sidewalks, bicycle lanes, and parking lanes. The plan shall include specific
information regarding the Project’s construction activities that may disrupt
3.7 TRANSPORTATION AND TRAFFIC
3.7-46 Airport Park Expansion Project
Final EIR – January 2018
normal pedestrian and traffic flow and the measures to address these
disruptions. Such plans shall be reviewed and approved by the Strategic and
Transportation Planning Division prior to commencement of construction and
implemented in accordance with this approval.
• Work within the public right-of-way shall be performed between 9:00 A.M. and
4:00 P.M. This work includes dirt and demolition material hauling and
construction material delivery. Work within the public right-of-way outside of
these hours shall only be allowed after the issuance of an after-hours
construction permit.
• Streets and equipment shall be cleaned in accordance with established Public
Works Department requirements.
• Trucks shall only travel on a City-approved construction route. Truck
queuing/staging shall not be allowed on Santa Monica streets. Limited queuing
may occur on the construction site itself.
• Materials and equipment shall be minimally visible to the public; the preferred
location for materials is to be onsite, with a minimum amount of materials
within a work area in the public right-of-way, subject to a current Use of Public
Property Permit.
• Any requests for work before or after normal construction hours within the
public right-of-way shall be subject to review and approval through the After
Hours Permit process administered by the Building and Safety Division.
• Provision of off-street parking for construction workers, which may include the
use of a remote location with shuttle transport to the site, if determined
necessary by the City of Santa Monica.
Project Coordination Elements That Shall Be Implemented Prior to
Commencement of Construction
• The City shall advise the traveling public of impending construction activities
(e.g., information signs, portable message signs, media listing/notification, and
implementation of an approved Construction Impact Mitigation Plan).
• The City shall provide timely notification of construction schedules to all
affected agencies (e.g., MTA, Big Blue Bus, Police Department, Fire
Department, Public Works Department, and Planning and Community
Development Department) and to all owners and residential and commercial
tenants of property within a radius of 500 feet.
• The City shall coordinate construction work with affected agencies in advance
of start of work. Approvals may take up to two weeks per each submittal.
Residual Impacts
Implementation of MM T-1 would reduce Project construction impacts on the street network. By
requiring haul trips to be restricted between 9:00 A.M. and 4:00 P.M., peak early morning and
afternoon construction truck trips would be reduced, which would reduce impacts on the
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-47
Final EIR – January 2018
surrounding street network during morning and evening commutes. By developing parking and
access plans, construction of the Project would generate reduced impacts on public roadways, and
with designated haul routes approved prior to the commencement of construction, MM T-1 would
prevent substantial truck traffic in residential neighborhoods. Implementation of MM T-1 would
reduce Project construction traffic impacts to less than significant levels.
Operational Impacts – Intersections
Would the Project conflict with an applicable plan, ordinance or policy establishing measures of
effectiveness for the performance of the circulation system, taking into account all modes of
transportation including mass transit and non-motorized travel and relevant components of the
circulation system, including but not limited to intersections, streets, highways and freeways?
Would the proposed Project result in a decrease in LOS of affected intersections according to
established thresholds?
T-2 The Project would generate new vehicle trips to the existing street network
that would result in an exceedance of the City of Santa Monica LOS thresholds
at three intersections under Approval Year (2017) Plus Project conditions, at
four intersections under Future Year (2025) Plus Project conditions, and at
two street segments under Existing (2017) ADT No feasible mitigation
measures are available to eliminate these impacts; therefore, the Project would
generate significant and unavoidable impacts on intersections.
Impact Description (T-2)
The analysis of the Project’s impacts on the local street network system (i.e., intersections) is based
on using LOS as the significance criteria as set forth in adopted standards of the City of Santa
Monica and City of Los Angeles (see Table 3.7-6 and Table 3.7-7).9
9 As discussed in Section 3.7.3 Impact Assessment and Methodologies above, because OPR’s guidelines for SB 743
implementation are still in draft form and not yet adopted, the City continues to analyze traffic impacts based on the
adopted LOS methodology and associated significance criteria.
3.7 TRANSPORTATION AND TRAFFIC
3.7-48 Airport Park Expansion Project
Final EIR – January 2018
Approval Year (2017) Plus Project Analysis
The Project would generate a net increase of 35 trips during the A.M. peak hour, and 98 trips during
the P.M. peak hour as shown in Table 3.7-8. To evaluate the impacts of the Project on 15
intersections LOS under Approval Year (2017) conditions, the Project’s net trip generation was
added to the Approval Year (2017) No Project traffic forecasts to create the Approval Year (2017)
Plus Project forecasts (refer to Table 3.7-9).
As shown in the table, Project-generated traffic would exceed the City of Santa Monica’s adopted
LOS thresholds of significance at three intersections. Specifically, Project-generated traffic would
create significant impacts at the following intersections under Approval Year (2017) Plus Project
conditions:
• 23rd Street and Dewey Street, approximately 0.7 mile southwest of the site (LOS F during
the P.M. peak hour);
• 23rd Street and Walgrove Avenue, approximately 0.6 mile southwest of the site (LOS D in
the A.M. peak hour, increase in delay); and
• Bundy Drive and Ocean Park Boulevard, approximately 0.5 mile north of the site (LOS F
in both A.M. and P.M. peak hours).
Project changes to V/C ratios or vehicle delays on these three impacted intersections would range
from a barely measurable (less than one percent change in V/C ratio) at Bundy Drive & Ocean
Park Boulevard during the P.M. peak hour to an increased delay of up to 1.3 seconds at the 23rd
Street and Dewey Street intersection during the P.M. peak hour. As discussed above, SMO creates
a one-mile-long barrier to north-south traffic flow in the vicinity, with north-south traffic
accommodated only by 23rd Street and South Bundy Drive. In addition, 23rd Street has a jog in the
4-way stop-controlled intersection where it intersects with Dewey Street and becomes Walgrove
Avenue. This jog in the roadway reduces the overall volume of traffic that can be accommodated
by 23rd Street. Therefore, these two roadways have a high traffic flow during the peak hour periods
and the three impacted intersections currently operate at congested conditions (LOS D or F during
one or more of the peak hours) under existing conditions. Thus, the addition of even a small
number of vehicle trips would result in significant impacts. Therefore, based on the City’s adopted
LOS criteria, the Project would result in significant impacts on three intersections under Approval
Year (2017) conditions. As discussed below, due to the lack of available feasible mitigation
measures, these impacts are considered significant and unavoidable. As shown in Table 3.7-10,
no significant impacts would occur to intersections under the jurisdiction of the City of Los
Angeles.
L
F
4
1212
5
BARKERBARKER
HANGARHANGAR
MAR VISTAMAR VISTA
ELEMENTARYELEMENTARY
10
10
VIRGINIA AVENUEVIRGINIA AVENUE
PARKPARK
GANDARAGANDARA
PARKPARK
CLOVER
PARK
GANDARA
PARK
VIRGINIA AVENUE
PARK
PENMAR
RECREATION CENTER VENICE
RESERVOIR
SITE
GRANTGRANT
ELEMENTARYELEMENTARY
EDISONEDISON
ELEMENTARYELEMENTARY
WALGROVE
AVENUE
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SANTA MONICA
COLLEGE
BUNDY CAMPUS
EDISON
ELEMENTARY
GRANT
ELEMENTARY
MAR VISTA
ELEMENTARY
PICOPICO
MARMAR
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WEST LOS ANGELESWEST LOS ANGELES
SUNSET PARKSUNSET PARK
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SUNSET PARK
VENICE
MAR
VISTA
WEST LOS ANGELES
DONALD DOUGLASDONALD DOUGLAS
LOOP SOUTHLOOP SOUTH
SANTA MONICASANTA MONICA
AIRPORTAIRPORT
SANTA MONICA
AIRPORT
BARKER
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LEGEND
Santa Monica Airport
Existing Santa Monica Airport Park
Project Site
Study Intersection and Number
School
Fire Station
Fairview Branch Library
Park
City of Santa Monica
City of Los Angeles
##
F
L
Future Year Intersection Level of Service
(Circle = Santa Monica Jurisdiction;
Square = Los Angeles Jurisdiction)
Excellent/Good (A-C)
Fair (D)
Poor/Failure (E-F)
Future Year (2025) Impacts
No Measurable Impact
Less than Significan Impact
Significant
Note: Impacts are less than significant for all
Los Angeles Intersections.
0 1,200
SCALE IN FEET
N
Proposed Project Future Year (2025)
Level of Service 3.7-4
FIGURE
3.7-49
3.7 TRANSPORTATION AND TRAFFIC
3.7-50 Airport Park Expansion Project
Final EIR – January 2018
Table 3.7-9. Analysis of Project Impacts under Approval Year (2017) Conditions (City of
Santa Monica Analysis Methodology – HCM)
No. Intersection Class Peak
Hour
Approval No Project Approval + Project V/C or
Delay
Increase
Significant
Impact? V/C Delay LOS V/C Delay LOS
Airport Park Expansion Project
1
Cloverfield Boulevard &
Westbound I-10 Off-
Ramp
A
A.M. 0.566 47 D 0.566 47 D 0 No
P.M. 0.837 25 C 0.839 25 C 0 No
2
Cloverfield Boulevard &
Eastbound I-10 On-
Ramp
A A.M. 0.550 23 C 0.550 23 C 0 No
P.M. 0.928 27 C 0.928 27 C 0 No
3 Cloverfield Boulevard &
Pico Boulevard A A.M. 0.662 44 D 0.663 44 D 0 No
P.M. 0.755 34 C 0.755 35 C 1 No
4 Cloverfield Boulevard &
Ocean Park Boulevard A A.M. 0.527 9 A 0.527 9 A 0 No
P.M. 0.563 14 B 0.563 14 B 0 No
5 23rd Street &
Ocean Park Boulevard A A.M. 0.820 47 D 0.821 48 D 1 No
P.M. 0.688 27 C 0.688 27 C 0 No
6 23rd Street &
Dewey Street C A.M. 0.320 15 C 0.324 15 C 0 No
P.M. 1.317 ** F 1.330 ** F 0.013 Yes
7 23rd Street &
Walgrove Avenue C A.M. 0.511 27 D 0.530 28 D 1 Yes
P.M. 0.395 22 C 0.435 23 C 1 No
8 Walgrove Avenue &
Rose Avenue C A.M. 0.626 75 E 0.626 75 E 0 No
P.M. 0.716 27 C 0.716 27 C 0 No
9 Centinela Avenue &
Ocean Park Boulevard A A.M. 0.736 27 C 0.736 27 C 0 No
P.M. 0.707 65 E 0.709 65 E 0 No
10 Bundy Drive &
Ocean Park Boulevard A A.M. 0.949 90 F 0.950 90 F 0.001 No
P.M. 0.936 96 F 0.941 98 F 0.005 Yes
11 Bundy Drive &
National Boulevard A A.M. 0.953 100 F 0.954 ** F 0.001 No
P.M. 0.813 25 C 0.823 27 C 2 No
12 Centinela Avenue &
Airport Avenue A A.M. 0.811 16 B 0.815 16 B 0 No
P.M. 0.925 48 D 0.938 54 D 6 No
13A SMC/Museum Driveway
& Airport Avenue C A.M. 0.319 9 A 0.323 9 A 0 No
P.M. 0.529 11 B 0.554 11 B 0 No
13B
Donald Douglas Loop
South (reloc.) & Airport
Avenue
C
A.M. -- -- -- 0.267 8 A -- --
P.M. -- -- -- 0.427 10 A -- --
14 Centinela Avenue &
Rose Avenue A A.M. 0.755 20 B 0.757 20 C 0 No
P.M. 0.794 13 B 0.798 14 B 1 No
15 Centinela Avenue &
Palms Boulevard A A.M. 0.783 42 D 0.784 43 D 1 No
P.M. 0.923 51 D 0.927 52 D 1 No
Notes:
* Average stopped delay per vehicle, in seconds.
** Indicates oversaturated conditions. Delay cannot be calculated.
A Arterial intersection,
C Collector intersection
Source: Fehr & Peers 2017 – Appendix F.
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-51
Final EIR – January 2018
Table 3.7-10. Analysis of Project Impacts under Approval Year (2017) Conditions (City of
Los Angeles Analysis Methodology – CMA)
No. Intersection Juris. Control
Type
Peak
Hour
Approval No
Project
Approval +
Project
V/C or
Delay
Change
Significant
Impact? V/C LOS V/C LOS
Airport Park Expansion Project
8 Walgrove Avenue &
Rose Avenue LA Signal A.M. 1.033 F 1.035 F 0.002 No
P.M. 0.911 E 0.914 E 0.004 No
9 Centinela Avenue &
Ocean Park Boulevard LA Signal A.M. 0.790 C 0.790 C 0.000 No
P.M. 0.693 B 0.694 B 0.001 No
10 Bundy Drive &
Ocean Park Boulevard LA Signal A.M. 0.849 D 0.851 D 0.001 No
P.M. 1.066 F 1.073 F 0.007 No
11 Bundy Drive &
National Boulevard LA Signal A.M. 0.837 D 0.838 D 0.001 No
P.M. 0.775 C 0.786 C 0.011 No
12 Centinela Avenue &
Airport Avenue LA Signal A.M. 0.717 C 0.721 C 0.004 No
P.M. 0.855 D 0.874 D 0.019 No
14 Centinela Avenue &
Rose Avenue LA Signal A.M. 0.808 D 0.809 D 0.001 No
P.M. 0.942 E 0.949 E 0.006 No
15 Centinela Avenue &
Palms Boulevard LA Signal A.M. 1.027 F 1.029 F 0.003 No
P.M. 1.052 F 1.054 F 0.002 No
Source: Fehr & Peers 2017 - Appendix F.
Future Year (2025) Plus Project Analysis
The Project would generate net increase of 35 trips during the A.M. peak hour, and 98 trips during
the P.M. peak hour (refer to Table 3.7-8). To evaluate the impacts of the proposed Project on
intersection LOS under Future Year (2025) conditions, the Project’s net trip generation was added
to the Future Year (2025) No Project traffic forecasts to create the Future Year (2025) Plus Project
forecasts. Table 3.7-11 compares the Future Year (2025) No Project and Future Year (2025) Plus
Project forecasts for the study intersections. As shown in the table, Project-generated traffic would
exceed City adopted LOS thresholds of significance at four of the 15 study intersections.
Specifically, the Project would create significant impacts at the following four intersections under
Future Year (2025) Plus Project conditions:
• 23rd Street and Dewey Street, approximately 0.7 mile southwest of the site (LOS F in the
P.M. peak hour);
• 23rd Street and Airport Avenue, approximately 0.6 mile southwest of the site (LOS D in
the A.M. peak hour, increase in delay);
• Bundy Drive and Ocean Park Boulevard, approximately 0.7 mile north of the site (LOS F
in both A.M. and P.M. peak hours); and
• Centinela Avenue and Airport Avenue, approximately 0.25 mile northeast of the site
(LOS E in the P.M. peak hours).
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3.7-52
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-53
Final EIR – January 2018
Table 3.7-11. Analysis of Project Impacts under Future Year (2025) Conditions (City of
Santa Monica Analysis Methodology – HCM)
No. Intersection Class Peak
Hour
Future Year (2025) Future Year plus
Project (2025)
V/C or
Delay
Increase
Significant
Impact? V/C Delay LOS V/C Delay LOS
Airport Park Expansion Project
1
Cloverfield Boulevard &
Westbound I-10 Off-
Ramp
A
A.M. 0.566 46 D 0.566 46 D 0 No
P.M. 0.840 25 C 0.842 25 C 0 No
2
Cloverfield Boulevard &
Eastbound I-10 On-
Ramp
A A.M. 0.568 24 C 0.568 24 C 0 No
P.M. 0.930 28 C 0.930 28 C 0 No
3 Cloverfield Boulevard &
Pico Boulevard A A.M. 0.670 45 D 0.671 45 D 0 No
P.M. 0.759 35 D 0.759 35 D 0 No
4 Cloverfield Boulevard &
Ocean Park Boulevard A A.M. 0.536 10 A 0.536 10 A 0 No
P.M. 0.563 14 B 0.563 14 B 0 No
5 23rd Street &
Ocean Park Boulevard A A.M. 0.828 49 D 0.829 49 D 0 No
P.M. 0.695 28 C 0.695 28 C 0 No
6 23rd Street &
Dewey Street C A.M. 0.327 15 C 0.331 16 C 1 No
P.M. 1.327 ** F 1.340 ** F 0.013 Yes
7 23rd Street &
Walgrove Avenue C A.M. 0.556 29 D 0.575 30 D 1 Yes
P.M. 0.448 24 C 0.488 25 C 1 No
8 Walgrove Avenue &
Rose Avenue C A.M. 0.637 81 F 0.637 81 F 0 No
P.M. 0.726 27 C 0.726 27 C 0 No
9 Centinela Avenue &
Ocean Park Boulevard A A.M. 0.739 27 C 0.739 27 C 0 No
P.M. 0.723 71 E 0.725 71 E 0 No
10 Bundy Drive &
Ocean Park Boulevard A A.M. 0.969 ** F 0.970 ** F 0.001 No
P.M. 0.953 ** F 0.958 ** F 0.005 Yes
11 Bundy Drive &
National Boulevard A A.M. 0.958 ** F 0.959 ** F 0.001 No
P.M. 0.820 27 C 0.830 28 C 1 No
12 Centinela Avenue &
Airport Avenue A A.M. 0.816 16 B 0.820 17 B 1 No
P.M. 0.931 50 D 0.944 56 E 6 Yes
13A SMC/Museum Driveway
& Airport Avenue C A.M. 0.338 9 A 0.330 9 A 0 No
P.M. 0.551 11 B 0.561 11 B 0 No
13B
Donald Douglas Loop
South (reloc.) & Airport
Avenue
C
A.M. -- -- -- 0.274 8 A -- --
P.M. -- -- -- 0.437 10 A -- --
14 Centinela Avenue &
Rose Avenue A A.M. 0.779 24 C 0.781 24 C 0 No
P.M. 0.807 15 B 0.811 15 B 0 No
15 Centinela Avenue &
Palms Boulevard A A.M. 0.789 44 D 0.790 45 D 1 No
P.M. 0.932 53 D 0.937 54 D 1 No
Notes:
* Average stopped delay per vehicle, in seconds.
** Indicates oversaturated conditions. Delay cannot be calculated.
A Arterial intersection
C Collector intersection
Source: Fehr & Peers 2017 - Appendix F
3.7 TRANSPORTATION AND TRAFFIC
3.7-54 Airport Park Expansion Project
Final EIR – January 2018
Project changes to V/C ratios or vehicle delays would range from a barely measurable (less than
one percent change in V/C ratio) at 23rd Street and Dewey Street during the P.M. peak hour to an
increased delay of up to 6 seconds at the Centinela Avenue and Airport Avenue intersection during
the P.M. peak hour. As noted above, congestion on 23rd Street and Centinela/South Bundy Drive
are primarily a function of limited north-south routes around SMO and it should be noted that the
four impacted intersections currently operate at congested conditions (LOS D or F during one or
more of the peak hours), and as such, the addition of even a small number of vehicle trips would
result in significant impacts. Therefore, based on the City’s adopted LOS criteria, the proposed
Project would result in significant impacts on 4 intersections under Future Year (2025) conditions.
As discussed below, due to the lack of available feasible mitigation measures, these impacts are
considered significant and unavoidable. As shown in Table 3.7-12, no significant impacts would
occur to intersections under the jurisdiction of the City of Los Angeles.
Table 3.7-12. Analysis of Project Impacts under Future Year (2025) Conditions (City of
Los Angeles Analysis Methodology – CMA)
No.
Intersection Juris.
Control
Type Peak
Hour
Future No
Project
Future +
Project V/C or
Delay
Change
Significant
Impact? V/C LOS V/C LOS
Airport Park Expansion Project
8 Walgrove Avenue &
Rose Avenue LA Signal A.M. 1.061 F 1.064 F 0.002 No
P.M. 0.935 E 0.939 E 0.004 No
9 Centinela Avenue &
Ocean Park Boulevard LA Signal A.M. 0.795 C 0.795 C 0.000 No
P.M. 0.707 C 0.708 C 0.001 No
10 Bundy Drive &
Ocean Park Boulevard LA Signal A.M. 0.871 D 0.872 D 0.001 No
P.M. 1.073 F 1.080 F 0.007 No
11 Bundy Drive &
National Boulevard LA Signal A.M. 0.840 D 0.842 D 0.001 No
P.M. 0.783 C 0.793 C 0.011 No
12 Centinela Avenue &
Airport Avenue LA Signal A.M. 0.722 C 0.726 C 0.004 No
P.M. 0.863 D 0.882 D 0.019 No
14 Centinela Avenue &
Rose Avenue LA Signal A.M. 0.821 D 0.823 D 0.002 No
P.M. 0.960 E 0.966 E 0.006 No
15 Centinela Avenue &
Palms Boulevard LA Signal A.M. 1.037 F 1.039 F 0.003 No
P.M. 1.070 F 1.072 F 0.002 No
Source: Fehr & Peers 2017 - Appendix F.
Street Segment Impact Analysis
Total daily Project-generated trips were assigned to the street network. The analyzed segments
were chosen for their proximity to the Project and the operational constraints of the road network
in this area. Because there are limited north-south streets between Bundy Drive/Centinela Avenue
and Lincoln Boulevard in the vicinity of the Project, 23rd Street and Walgrove Avenue experience
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-55
Final EIR – January 2018
relatively high volumes of cut-through traffic. The selected analysis segments represent critical
entry points to the surrounding neighborhoods through which project-related traffic may travel.
The intersection of 23rd Street/Walgrove Avenue & Airport Avenue has a signed turning restriction
prohibiting left turns from Airport Avenue from 7:00 to 9:00 A.M. and from 3:00 to 6:00 P.M. The
daily traffic assignment for neighborhood impact analysis incorporates assumptions about traffic
turning left at this location over the course of the day, while the peak-hour intersection analysis
assumes the left turns are prohibited. The existing and projected daily street segment traffic
volumes are presented in Table 3.7-13.
Table 3.7-13. Approval Year (2017) Street Segment Impact Analysis
No. Segment Juris. Type
Existing
(2017)
ADT
Allowable
Increase
Project
Trips
Existing
(2017)
Plus
Project
%
Increase
Significant
Impact?
Airport Park Expansion Project
1 23rd St. n/o Dewey
St. SM Collector 22.257 1 Trip 32 22.289 0% Yes
2 Dewey St. w/o 23rd
St SM Local 4.662 1 Trip 47 4.709 1% Yes
3 Walgrove Ave s/o
Airport Ave LA Collector 27.416 8% 96 27.512 0% No
4 Rose Ave w/o
Walgrove Ave LA Collector 13.978 8% 34 14.012 0% No
5 Rose Ave e/o
Walgrove Ave LA Collector 9.470 8% 26 9.496 0% No
6 Walgrove Ave s/o
Rose Ave LA Collector 16.518 8% 35 16.553 0% No
Notes: Classifications are based on City of Santa Monica street classifications in the Land Use & Circulation
Element (LUCE). The most recent LUCE incorporates a different classification scheme, but new impact criteria
have not yet been adopted; therefore, this study applies to the previous classifications.
Table 3.7-13 presents a summary of Project segment impacts, according to each jurisdiction’s
impact criteria. As shown, application of the appropriate significance criteria for neighborhood
traffic impacts indicates that the Project would create significant traffic impacts at up to two
locations; both are located in the City of Santa Monica:
1. 23rd Street north of Dewey Street
2. Dewey Street west of 23rd Street
The segment of 23rd north of Dewey Street is classified as a collector street. The segment of
Dewey Street between 21st Street and 23rd Street is classified as a local street. For collector streets
3.7 TRANSPORTATION AND TRAFFIC
3.7-56 Airport Park Expansion Project
Final EIR – January 2018
with a current ADT of greater than 13,500 and for local streets with a current ADT of greater than
2,250, a proposed project is considered to create a significant impact if there is a net increase in
ADT of one trip or more. The magnitude of the existing traffic level at both of these locations is
such that the addition of even a single daily trip is considered significant.
CMP Regional Transit
The estimates of transit usage presented in this section are based on the CMP analysis
methodology, which differs from the vehicle-trip methodology of the Trip Generation shown in
Table 3.7-8. The Project is expected to generate a net increase of approximately 35 trips in the
weekday A.M. peak hour and approximately 98 trips in the weekday P.M. peak hour, under both
Approval Year (2017) and Future Year (2025) conditions. Multiplying this by an AVR of 1.4
predicts that the Project would generate approximately 49 person trips in the weekday A.M. peak
hour and approximately 137 person trips in the weekday P.M. peak hour. Because the Project is
neither commercial nor residential, the transit ridership factor of 3.5 percent was applied to these
trips. As shown in Table 3.7-14, using the CMP methodology, the Project is expected to generate
approximately two new transit trips in the A.M. peak hour and approximately five new transit trips
in the weekday P.M. peak hour. This low level of ridership increase would not create a significant
impact on the regional transit system. The Project-related impacts on the regional transit system
would not be significant given the availability of high quality transit within 0.25-mile of the Project
site.
Table 3.7-14. Estimated Project-related Transit Ridership (Transit Persons per Peak
Hour)
Maximum Project
Generated Vehicle Trips2 Expected (AVR 1.4)3 Transit Ridership Factor
(3.5%)
A.M. Peak Hour 35 49 2
P.M. Peak Hour 98 137 5
1 The estimates of transit usage presented in this section are based on the CMP analysis methodology. Since the Project is neither
commercial nor residential, the transit ridership factor of 3.5% was applied to these trips.
2 The proposed Project is expected to generate a net increase of approximately 35 trips in the weekday A.M. peak hour, 98 trips in
the weekday P.M. peak hour
3 Applies the CMP guidelines (i.e., converting the vehicle trips to person trips by multiplying by a 1.4 AVR and assuming 3.5%
transit use)
Source: Fehr & Peers 2017 (Appendix F)
Mitigation Measures
Physical improvements were considered that could potentially reduce the traffic impacts at the
significantly impacted intersections under Approval Year (2017) Plus Project and Future Year
1
3.7 TRANSPORTATION AND TRAFFIC
Airport Park Expansion Project 3.7-57
Final EIR – January 2018
(2025) Plus Project conditions. However, these improvements are considered infeasible for the
reasons described below:
23rd Street and Dewey Street (P.M. peak hour)
This intersection is impacted during the P.M. peak hour under both Approval Year (2016) Plus
Project and Future Year (2025) Plus Project conditions. The demand at this intersection is
Projected to exceed capacity under both Approval and Future plus Project conditions. It operates
at LOS F under existing conditions. The critical movement is the stop-controlled eastbound right
turn from Dewey Street onto southbound 23rd Street. Installation of a traffic signal would be the
only effective means to reduce delay for the eastbound approach on Dewey Street; however, a
signal would substantially increase delay for the very heavy through volumes and would likely
exacerbate impacts at other nearby intersections. The end result would be a poor level of service
and increased delay for a greater number of vehicles at the intersection. Therefore, due to
secondary impacts, this mitigation measure is undesirable.
23rd Street and Airport Avenue (A.M. Peak Hour)
Traffic on the stop-controlled westbound right turn at this intersection presently experiences LOS
D during the A.M. peak hour as northbound flows along 23rd Street are heaviest. The addition of
Project trips to this intersection increases the delay by 1 second in both the Approval Year and
Future Year scenarios. Presently, left turns from Airport Avenue onto 23rd Street southbound are
prohibited by signage during the A.M. and P.M. peak periods. However, this movement is not
physically restricted and a small number of vehicles were recorded making this move under
existing conditions. Installation of a traffic signal would be the only effective means to reduce
delay for the westbound approach and could also facilitate left turns. However, a signal would also
substantially increase delay for the heavy northbound volumes and could introduce greater issues
in the P.M. peak hour when there is not presently an impact. As part of a separate Project for the
Airport Avenue improvements, the City of Santa Monica is evaluating the possibility of
reconfiguring this intersection. The alternatives may include signalization or channelization to
fully prohibit left turns from Airport Avenue onto 23rd Street. However, this Project analysis
suggests than an impact would be triggered even when no left turns are assumed, and that
secondary impacts of signalization would only increase delay at the intersection rather than
improve it.
Bundy Drive and Ocean Park Boulevard (P.M. Peak Hour)
This intersection operates at LOS F during the P.M. peak hour under existing conditions. Under
both Approval Year and Future Year conditions, the addition of Project trips increases the V/C by
3.7 TRANSPORTATION AND TRAFFIC
3.7-58 Airport Park Expansion Project
Final EIR – January 2018
0.008 during the P.M. peak hour. Demand at the eastbound, northbound, and southbound
approaches is high, with especially heavy eastbound right turns and northbound left turns. To some
degree, these movements are affected by downstream congestion as well. As noted above, SMO
creates a one-mile-long barrier to north-south traffic flow, disrupting the roadway grid system and
bisecting this area from north to south. Therefore, traffic is forced to navigate SMO on the two
north-south roadways adjacent to SMO, 23rd Street and South Bundy Drive. The constraints of the
road network in this area limit possible alternative routes that might otherwise help to disperse
traffic. Specifically, SMO creates a one-mile-long barrier to norths-south movement forcing north-
south traveling vehicles onto either South Bundy Drive or 23rd Street. Therefore, these potential
mitigation measures are deemed infeasible.
Centinela Avenue and Airport Avenue (P.M. Peak Hour, Future Year Only)
Under the Future No Project conditions, this intersection operates at LOS D. Under Future plus
Project conditions, the LOS degrades to LOS E. Much of the delay is incurred by the northbound
left turn and the southbound through movements, which increases as traffic exiting Airport Avenue
grows. Given the physical constraints at this location of grade, developed land (e.g., residential,
commercial, and recreational development), and the associated cost with acquiring developed
lands for the purposes of widening the intersections, there are no feasible physical mitigations.
Therefore, the impact is significant and unavoidable.
Street Segment Impact Mitigation Measures
The significant street segment impact identified for 23rd Street north of Airport Avenue occurs on
a street that is part of a travel corridor that provides the only channel for north/south through traffic
east of Lincoln Boulevard and west of Centinela Avenue. As such, this segment of 23rd Street,
while classified as a collector street, carries in excess of 25,000 vehicles per day. That traffic
volume, as well as the grade and width is such that typical neighborhood traffic calming
measures — such as those applied on Rose Avenue east of Bundy Drive and on 23rd Street north
of Ocean Park Boulevard (stop signs and speed humps) — are not considered appropriate. The
alternative that might be used on collector streets with relatively high volumes would be “speed
tables,” essentially raised areas that are lower, longer and wider than speed humps. In addition to
the grade of 23rd Street at this location, City policy discourages measures that reroute trips from
one local street to another. Furthermore, streets designated by the Fire Department as "Emergency
Response Routes" must remain free from design features that would slow fire trucks. Therefore,
the installation of speed tables is not considered feasible on this segment of 23rd Street due to
potential for secondary impacts to public safety.
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The City has implemented traffic calming measures on this segment of 23rd Street, including
narrowing the roadway and installing a raised, landscaped center median. It should be noted that,
at one time, stop signs were installed on this segment of 23rd Street to calm traffic but were found
to be problematic and have since been removed. Therefore, no further traffic calming measures
are considered feasible for this segment of 23rd Street and the impact is considered significant and
unavoidable.
The street segment impact identified on Dewey Street is based on the Project’s addition of one
daily trip to this street segment, per the City of Santa Monica’s strict significance impact criteria.
Full closure of the affected street segment would not be acceptable since it serves adjacent land
uses and carries substantial traffic volumes that would then need to shift to other nearby streets.
No mitigation measures would fully eliminate the potential for even a single Project trip to be
added to these street segments. Therefore, this impact is considered significant and unavoidable.
Residual Impacts
Based on the above, due to the potential for mitigation to incidentally increase delay at an
intersection or due to physical constraints that prevent the alternative north-south routes or the
widening of intersections, there are no feasible or desirable mitigation measures available to either
reduce or eliminate the significant impacts at the identified intersections. Therefore, impacts would
remain significant and unavoidable.
Operational Impacts – Regional Facilities
Would the proposed Project increase traffic demand on the CMP facility by 2 percent (V/C greater
than 0.02) causing it to operate at LOS F (V/C > 1.00) of if the facility is already at LOS F, would
the Project traffic cause an incremental change in the V/C ratio of 0.02 or greater?
T-3 The Project would not exceed thresholds at CMP-designated intersections
and/or freeway segments. The Project would therefore generate a less than
significant impact on regional transportation facilities.
Impact Description (T-3)
The 2010 Congestion Management Program (CMP) for Los Angeles County requires that when
an environmental impact report is prepared for a proposed Project, traffic and transit impact
analyses be conducted for select regional facilities based on the quantity of Project traffic expected
to use these facilities. The criteria for analyzing CMP arterial monitoring intersections and for
freeway monitoring locations are:
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• All CMP arterial monitoring intersections where the proposed Project will add 50 or more
trips during either the A.M. or P.M. weekday of adjacent street traffic.
• All CMP mainline freeway monitoring locations where the proposed Project will add 150
or more trips, in either direction, during either the A.M. or P.M. weekday peak hours.
CMP Arterial Intersections
The CMP arterial monitoring intersections nearest to the Project site are the intersections of Santa
Monica Boulevard & Bundy Drive (approximately 2.2 miles away) and Venice Boulevard &
Centinela Avenue (approximately 1.3 miles away). Neither of these are study intersections. Based
on the Project trip estimates, the Project would add fewer than 50 total trips at any of these
intersections during either the weekday A.M. or P.M. peak hours. Therefore, Project impacts on the
CMP arterial system are considered to be less than significant and no further CMP arterial analysis
is required.
As previously described, there are six different fixed-route bus lines within ¼-mile of the Project
site, and three express lines within two miles of the Project site. Together, these lines provide over
70 buses per hour during the weekday P.M. period.
CMP Mainline Freeway Locations
The CMP mainline freeway monitoring location nearest to the Project site is the I-10 at Lincoln
Boulevard. Based on the incremental Project trip generation estimates and Project trip assignment,
the Project would not add enough new traffic to exceed the freeway analysis criteria at this
location. Because incremental Project-related traffic in any direction during either weekday peak
hour is Projected to be below the minimum criterion of 150 1-way vehicles per hour, Project
impacts on the CMP regional freeway system are insignificant and no further CMP analysis is
required.
Would the Project substantially increase hazards due to a design feature, or incompatible use, or
result in inadequate emergency access?
T-4 The proposed realignment of and Project driveway at Donald Douglas Loop
South would not create hazardous conditions for vehicles, bicyclists, or
pedestrians; impacts would be less than significant.
Impact Description (T-4)
Vehicular access to the Project site would continue to be provided along Airport Avenue to the
existing south parking lot, as well as from the realigned segment of Donald Douglas Loop South,
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which would be relocated to the western site boundary to prevent bifurcation of the park. Traffic to
the Airport Administration building would be routed around the north side of the new parking area
following the re-alignment of the roadway. Turnarounds would be provided at two locations to
accommodate the movement of emergency vehicles. One turnaround would be located north of the
multi-use area, the other would be located north of the east sports field. The current north-south
segment of Donald Douglas Loop South would be vacated and converted into a pedestrian path.
Access would continue to be available off of Airport Avenue as well.
Pedestrian access would be provided at two new locations along Bundy Avenue, including at the
Main Bundy Entry and the Secondary Bundy Entry, and at six locations along Airport Avenue,
including a pedestrian path at the vacated alignment of Donald Douglas Loops South. Because there
are multiple bike and pedestrian access ways, and proper signage and street design requirements
would be undertaken during the construction of the realignment, the Project would not create
hazardous conditions for vehicles, bicyclists, or pedestrians, and impacts would be less than
significant.
In addition, the Project would be subject to the SMMC Section 9.04.10.08.060 (d) which states,
“the design, location or position of any parking layout, entry, driveway, approach, or access from
any street or alley shall be approved by the Parking and Traffic Engineer”. Site plan approval from
the City’s Transportation Management Division would ensure that site access provides sufficient
egress for trucks and emergency vehicles prior to approval. Therefore, the Project’s access design
features would generate less than significant impacts to potential risks of hazards to pedestrians
by vehicles and emergency access to the site.
Would the proposed Project result in a conflict with adopted policies, plans, or programs
regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance
or safety of such facilities?
T-5 The Project would not conflict with adopted City plans, policies, and programs
supporting alternative transportation. Therefore, the Project impacts would
be less than significant.
Impact Description (T-5)
The Project is located within an area that has some limits to connectivity with existing bike routes
and sidewalks that link the Project site to existing City neighborhoods. The Project would
incrementally increase traffic congestion at some area intersections, and does not include new or
expanded options for alternative transportation to serve the site. Due to the location of SMO, the
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City’s grid system is interrupted and access is generally more difficult in this area compared to
other locations within the City (e.g., Downtown). Bicycle facilities are somewhat limited in this
area, and certain roads, such as Airport Avenue have inconsistent bicycle and pedestrian facilities.
However, Airport Avenue is planned to receive upgrades to bicycle and pedestrian amenities
through the Airport Avenue Improvement Project, which would coincide with and serve the
demands for pedestrian and bicycle visitors to the park.
The Project site is served by two bus routes currently in operation within 0.25 mile of the Project
site, one of which is designed to connect the SMC campuses and runs during weekdays. Therefore,
the number of transit trips expected to result from the Project is estimated below according to the
methodology included in Section B.8.4 of the Los Angeles County CMP. This methodology
assumes an AVR factor of 1.4 in order to estimate the number of person trips to and from the
Project, with an upward adjustment to 2.2 AVR to be consistent with recent City policies and to
reflect the Project’s implementation of a TDM program consistent with the City’s TDM
Ordinance. This methodology then provides guidance regarding the percent of persons trips
assigned to public transit depending on the type of use (commercial/other versus residential) and
the proximity to transit services. As discussed above, the Project is expected to generate
approximately 2 transit person trips in the A.M. peak hour trips and 5 transit person trips in the P.M.
peak hour trips under the Approval Year (2017) conditions, which would not exceed the capacity
of the regional transit system. When transfers are considered as part of the CMP methodologies,
the Project’s increased demand for transit would be spread across 6 bus lines and the Expo LRT.
Area buses can carry approximately from 50 (standard) to 100 (double) passengers. While an
increase in transit demand would incrementally contribute to potential for overcrowding on some
peak period buses or trains, the high levels of transit service in the area would be able to
accommodate incremental increases in demand associated with the Project.
Airport Park is intended to provide City residents in nearby neighborhoods with a range of high-
quality recreational amenities. As discussed in the existing setting above, public transit to the site
is not as direct or convenient for most City residents as other areas of the City (e.g., Downtown).
Currently, transit from nearby neighborhoods could take up to 30 minutes and require at least one
transfer to reach the Project site. However, as the Project site is located within walking and biking
distance to neighborhoods and is served by bus transit on a regular schedule, the Project would be
consistent with the City’s goals and policies encouraging use of non-vehicle transportation and
siting recreational uses near neighborhoods, as discussed further below (see also, Section 3.5, Land
Use and Planning).
1
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Consistency with LUCE Policies
The primary goals of the LUCE with regard to alternative transportation within the City are
focused on shifting the number of trips made by single occupancy vehicle to transit, biking, and
walking trips. To increase the use of alternative modes of transportation, the LUCE supports the
creation of mixed use communities with attractive and safe pedestrian and bicycle networks that
are connected to key public transit services. The complete list of the Goals and Policies outlined
by the City of Santa Monica are described in Section 3.7.2 Local Regulations. As discussed, the
Project site is located in an area that is not as well served by alternative transportation compared
to downtown and other locations throughout the City. The 2010 LUCE lays out several goals
related to increasing public transportation and ensuring that walking and bicycling are safe and
comfortable at all times of day (Goal N15, Goal N17). Implementation of the Project would be
generally consistent with the City’s goals, policies, and programs for sustainability, alternative
transportation, transportation management, and GHG reduction, especially in conjunction with the
Airport Avenue Improvement Project.
One of the stated goals of the LUCE is the citywide goal of no net new P.M. peak hour vehicle trips
generated by land uses in the City of Santa Monica by 2030. As stated in the LUCE EIR, this goal
will be achieved by changing travel behavior associated with both existing and future development
in the City. The City’s trip reduction goals are citywide, understanding that individual new
development will inevitably generate vehicle trips while transportation demand improvements will
commensurately reduce vehicle trips. To achieve the goal of No Net New P.M. Peak hour trips, the
LUCE provides a framework for integrating land use and transportation to reduce vehicle trips;
encouraging walking, bicycling, and transit use; and creating active, pedestrian-oriented
neighborhoods. The LUCE goal of generating no net new P.M. peak hour trips is not a requirement
to be applied on a project-by-project basis. Rather, the intent of this goal is to reduce vehicle trips
for existing and future uses on a citywide basis through implementation of land use and
transportation policies, programs, and projects that support and invest in the transportation system.
The Project would not conflict with the City’s goal of No Net New P.M. Peak Hour trips and other
transportation goals established in the LUCE.
Specifically, the Project includes some features and amenities that respond to the City’s goals and
policies to increase the use of alternative modes of transportation such as the realignment of
Donald Douglas Loop South, providing two new pedestrian access points along South Bundy
Drive, and creating a continuous looping path network to traverse Airport Park. The LUCE
encourages new Projects to incorporate elements into Project design that would encourage walking
and bicycling. In addition, the project is being advanced in conjunction with planned
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improvements to Airport Boulevard Improvement Project, which would provide sidewalks,
streetscape improvements, and Class I bicycle lanes along Airport Avenue from South Bundy
Drive to 23rd Street, thus connecting the Project Site to the City’s bicycle network in the Sunset
Park and Pico neighborhoods.
Alternative transit options in the Project area are available. Travel to the Project site via public
transportation from nearby neighborhoods would take approximately 30 minutes and would
require at least one transfer during the peak traffic hour; peak hour headways in the Project vicinity
vary from 10 to 20 minutes. Off-peak headways of the transit lines in the area are often 30 minutes
or more. The general Project area is served by numerous transit routes, including three rapid transit
routes; most of the bus stops for these are located more and 0.25 mile of the Project site. Big Blue
Bus Lines 14 and 44 maintain bus stops within 0.25 mile of the Project Site, and Line 44 is the
SMC Campus Connector Shuttle, which offers a limited number of stops and service hours. The
Project site’s location within walking distance of bus stops for Line 14 would create some
opportunities for public transit use by future Project users, consistent with LUCE goals and
objectives.
The Sunset Park neighborhood is recognized for having walkable, pedestrian, and bicyclist
friendly streets; however, connectivity in the immediate vicinity of the Project site is somewhat
limited. 23rd Street is a Class II bike lane, and provides shaded, landscaped sidewalks making it a
vital connection to the rest of the City. After implementation of the proposed Airport Avenue
Improvement Project, which will create a Class I bike path and add sidewalks along Airport
Avenue, pedestrian and bike connectivity will be further enhanced adjacent to the Project site. The
location of the Project site in proximity to alternative modes of transportation would facilitate a
reduction in vehicle trips and VMT. Additionally, by rerouting Donald Douglas Loop South and
providing two new pedestrian access points along South Bundy Drive, the Project would improve
pedestrian connectivity in the Project area.
The Project is designed to support the City’s policies to create pedestrian activity and improve the
pedestrian experience (Goals LU4, LU8, T6, T9, B10, B14, T3, T19, and T21) by providing
widened sidewalks with attractive, pedestrian-oriented amenities such as outdoor seating and
landscaped streetscapes. With regard to bicycle amenities, the Project would include secured
parking for 45 bicycles at two new bike racks located at Bundy and the northern parking lot. The
Breeze Bike Share station currently located serving Airport Park at the intersection of Airport
Avenue and Donald Douglas Loop South would be removed during construction and replaced at
the relocated Donald Douglas Loop South driveway. Additionally, the Project would increase
recreation opportunities within the City.
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Final EIR – January 2018
The Project would also minimize VMT to and from the site by implementing a TDM plan that
would exceed the minimum requirements established in the City’s Transportation Demand
Management Ordinance. The final details of the TDM plan will be determined as part of the
Project’s Development Agreement process.
Since the Project is providing recreational areas within walking and bicycling distance from
neighborhoods and the Project site is served by regional transit services, the Project would result
in a less than significant impact regarding consistency with the adopted plans, policies, and
programs.
Cumulative Impacts
Would traffic impacts associated with construction activities materially interfere with the area
traffic flow, cause unsafe conditions, or introduce substantial truck traffic through a residential
area?
Based on Table 3.0-1 in Section 3.0.2, approved and/or pending Projects in the City are dispersed
throughout the City and would draw upon a workforce from all parts of the Los Angeles region.
Many, and likely most, of the construction workers are anticipated to arrive and depart the
individual construction sites during off-peak hours (i.e., arrive prior to 7:00 A.M. and depart
between 3:00 to 4:00 P.M.), thereby avoiding construction related trips during the A.M. and P.M.
peak traffic periods. In addition, the haul truck routes for the related Projects would be approved
by the City’s Transportation Management Division. The City’s established process would take into
consideration overlapping construction Projects and would balance haul routes to minimize the
impacts of cumulative hauling on any particular roadway. Therefore, cumulative construction
impacts would be less than significant.
Operational Traffic – Intersection
Would the Project conflict with an applicable plan, ordinance or policy establishing measures of
effectiveness for the performance of the circulation system, taking into account all modes of
transportation including mass transit and non-motorized travel and relevant components of the
circulation system, including but not limited to intersections, streets, highways and freeways?
Would the proposed Project result in a decrease in LOS of affected intersections according to
established thresholds?
The Future Year (2025) analysis of transportation and circulation represents a cumulative analysis
of potential traffic impacts through 2025. The analysis is based on the City’s TDFM, which takes
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into account anticipated future growth and circulation Projects, including the Expo LRT and street
network changes. As analyzed above, the intersections that would be significantly affected in
Future Year (2025) based upon City of Santa Monica Analysis Methodology, are: 23rd Street &
Dewey Street; 23rd Street & Airport Avenue; Bundy Drive and Ocean Park Boulevard; and
Centinela Avenue and Airport Avenue. As there are no feasible mitigation measures available, this
cumulative impact would remain significant and unavoidable.
Operational Traffic – Regional Facilities
Would the proposed Project increase traffic demand on the CMP facility by 2 percent (V/C greater
than 0.02) causing it to operate at LOS F (V/C > 1.00) of if the facility is already at LOS F, would
the Project traffic cause an incremental change in the V/C ratio of 0.02 or greater?
As described above, the proposed Project would not add more than 50 vehicle trips during the A.M.
and P.M. peak hours at the CMP arterial monitoring intersections Santa Monica Boulevard &
Bundy Drive and Venice Boulevard & Centinela Avenue. Furthermore, under Future Year (2025)
with Project conditions, the proposed Project would not cause these CMP arterial monitoring
stations to operate at LOS F or increase the d/c ratio by 0.02 or more. Finally, the Project would
not add more than 150 trips during the peak hours to the CMP mainline freeway segment, and
therefore, would not result in cumulative considerable impacts. As a result, the Project’s
cumulative impacts with regard to the CMP regional facilities would be less than significant.
Operational Traffic – Alternative Transportation
Would the proposed Project result in a conflict with adopted policies, plans, or programs
regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance
or safety of such facilities?
Alternative transportation access from the City’s neighborhoods to the Project site is somewhat
limited. However, with the incorporation of MM T-2 through MM T-4, in conjunction with
implementation of the Airport Avenue Improvement Project, connectivity is expected to greatly
improve over the next several years. The Airport Avenue Improvement Project planned along
Airport Avenue from South Bundy Drive to 23rd street would improve pedestrian and bikeway
connectivity near the Project site and would encourage the use of alternative transportation modes.
As part of the Airport Avenue Improvement Project, new 8-foot sidewalks would be installed on
both sides of the street, a new two-way 12-foot wide bicycle lane would be constructed on the
north side of Airport Avenue, and crosswalk improvements would be installed from the SMC Arts
Campus to 23rd Street (see Figure 3.7-6). Additionally, retaining walls, striped crosswalks, curb
3.7 TRANSPORTATION AND TRAFFIC
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Final EIR – January 2018
ramps, street lighting, street trees, and amenities such as benches, signage and trash containers
would be installed to improve the pedestrian and bicyclist experience (see Figure 3.7-6). When the
Airport Avenue Improvement Project is complete (estimated completion in late 2019, in
conjunction with the Project), the Project Site would be linked to the Sunset Park Neighborhood
and the existing City bike network through Class II or better bicycle facilities. Implementation of
the Airport Avenue Improvement Project would ensure compliance with LUCE and TDM
guidance to support alternative transportation modes through pedestrian-friendly design.
With the possibility of revised schedules and routing, implementation of MM T-3 could improve
Big Blue Bus service to the Project site. Implementation of MM T-4 could improve bicycle
connectivity by constructing a north-south bike path following the closure of SMO, and could
encourage bicycling with the addition of amenities such as showers and storage. Additonally, MM
T-4 proposes the expansion of the Breeze Bike Share Program by adding additional spaces at the
existing station and extending the program into nearby neighborhoods to further encourage
bicycling to the site. With other planned and pending transit and bike path improvements,
including those outlined in the Santa Monica Bike Action Plan, transportation service and options
within the City would be expanded. Therefore, the Project’s contribution to cumulative impacts
would be less than significant.
Figure 3.7-6. Airport Avenue Improvement Project
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Airport Park Expansion Project 4-1
Final EIR – January 2018
4.0 OTHER CEQA CONSIDERATIONS
This chapter presents the evaluation of additional environmental impacts analyses required by
California Environmental Quality Act (CEQA) that are not covered within the other chapters of
this EIR, including significant unavoidable environmental effects of the Project, irreversible
environmental changes, growth inducing impacts (including removal of obstacles to growth), and
resource areas that are found not to be significant. In particular, Section 15126 of the CEQA
Guidelines requires that all aspects of a project must be considered when evaluating its impact on
the environment, including planning, acquisition, development, and operation. Accordingly, in
addition to the analysis provided in Chapter 3.0, Environmental Impact Analysis and Mitigation
Measures, this EIR must identify growth inducing impacts and significant irreversible
environmental changes that would potentially result from implementation of the Airport Park
Expansion Project (Project).
4.1 UNAVOIDABLE SIGNIFICANT ENVIRONMENTAL EFFECTS
CEQA Guidelines Section 15126.2(b) requires that an EIR describe any significant impacts that
cannot be avoided, even with implementation of feasible mitigation measures. Where there are
significant impacts, their implications and the reasons why the Project is being proposed,
notwithstanding their effect, should be described.
Based on the analysis presented in this EIR, implementation of the Project would result in short-
term significant and unavoidable construction-related impacts to noise, and long term significant
and unavoidable impacts to transportation and traffic due to operation of the park. During
construction, even with the implementation of identified mitigation, the use of heavy-duty
construction equipment would exceed ambient noise levels at the residences across South Bundy
Drive by more than 5 dBA, thus exceeding the City of Los Angeles’ thresholds for construction
noise. Project construction would not exceed City of Santa Monica (City) thresholds for
construction noise. Operation of the Project and associated increases in the number of vehicle trips
would lead to changes in the volume-to-capacity (V/C) ratio, and the delay per vehicle at four
study intersections under the Future Year (2025) that would exceed City thresholds for intersection
operation and would be considered significant (Transportation Impact Analysis, Appendix F). The
following intersections in the City were projected to experience a significant increase in the V/C
ratio or vehicle delay during one or more analyzed peak hours: 23rd Street & Dewey Street (LOS
F during the P.M. peak hour), 23rd Street & Airport Avenue (LOS D during the A.M. peak hour),
Bundy Drive & Ocean Park Boulevard (LOS F during both the A.M. and P.M. peak hours), and
Centinela Avenue & Airport Avenue (LOS E during the P.M. peak hour). In addition, operation of
the Project would result in a significant increase in vehicle trips (i.e., more than one vehicle trip)
4.0 OTHER CEQA CONSIDERATIONS
4-2 Airport Park Expansion Project
Final EIR – January 2018
to two neighborhood street segments, 23rd Street north of Dewey Street and Dewey Street west of
23rd Street. No significant impacts were identified at intersections based on City of Los Angeles’
thresholds. Currently there are no feasible mitigation measures that are available to reduce these
impacts, so the impacts would remain significant and unavoidable. See Section 3.7, Transportation
and Traffic for more detailed information.
The reasons why the Project is being proposed, notwithstanding the significant impacts, are related
to the Project objectives stated in Section 2.0, Project Description. As indicated, the Project is
being proposed to fulfill the City’s long-standing objectives to develop non-aviation uses on Santa
Monica Municipal Airport (SMO) property south of the runway with recreational amenities as part
of a citywide effort to enhance and expand the City’s open space system by providing a broad
range of safe, high-quality recreational amenities for residents of all ages and abilities, with an
emphasis on maximizing the total square footage of sports fields available at Airport Park.
4.2 IRREVERSIBLE ENVIRONMENTAL CHANGES
CEQA Guidelines Section 15126.2(c) requires a discussion of “significant irreversible
environmental changes which would be caused by the Project should it be implemented. Uses of
nonrenewable resources during the initial and continued phases of the project may be irreversible
since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary
impacts and, particularly, secondary impacts (such as highway improvement which provides
access to a previously inaccessible area) generally commit future generations to similar uses. Also
irreversible damage can result from environmental accidents associated with the project.
Irretrievable commitments of resources should be evaluated to assure that such current
consumption is justified.”
Development of the Project would result in the irreversible alteration of the built environment and
the irreversible consumption of limited slowly, renewable resources and non-renewable resources
from construction and operation. Construction associated with the Project would involve the
consumption of building materials and energy, some of which are limited or slowly renewable
resources and non-renewable resources. Such resources may include certain types of lumber and
other forest products; raw materials such as steel; aggregate materials used in concrete and asphalt,
such as sand and stone; water; petrochemical construction materials, such as plastic; and
petroleum-based construction materials. In addition, fossil fuels would be consumed for
construction of the Project. The consumption of limited slowly renewable resources and
nonrenewable resources would continue throughout the Project’s operational lifetime as the
proposed recreational amenities would require resources such as water, fossil fuels for lighting,
and petroleum for vehicle trips to the Project site. While the existing energy-intensive, aviation-
4.0 OTHER CEQA CONSIDERATIONS
Airport Park Expansion Project 4-3
Final EIR – January 2018
related uses (e.g., Proteus Air) would be removed from the western portion of the Project site, this
EIR conservatively assumes that these uses would be relocated to another location at SMO and
that their consumption of non-renewable energy sources would continue until the airport’s closure
in 2028.
Although the Project would necessarily result in the consumption of such resources, the Project
would contribute to a land use pattern that would promote an overall reduction in resource
consumption. Particularly when considered in combination with the related Airport Avenue
Improvement Project, the Park’s location within the developed urban area of the City, availability
of transit and location along a future planed and funded Class I bicycle path that would provide
substantially improved bicycle connectivity with the City’s Sunset Park and Pico neighborhoods,
could increase public utilization of alternative transportation to access the Project site. In addition,
the Project includes the installation of bicycle racks, the replacement of an existing Breeze Bike
Share location, and the provision of two new pedestrian connections from South Bundy Drive,
which would incrementally increase the access to recreational amenities from several
neighborhoods. In this manner, residents may reduce reliance on vehicle trips to other recreational
facilities either inside or outside of the City. Therefore, the Project would be consistent with the
City’s strategy to reduce vehicle miles traveled and associated fossil fuel consumption, minimizing
reliance on this nonrenewable resource.
The Project would also comply with green building requirements included in the City’s Green
Building Standards. Sustainable design features would include energy-efficient lighting fixtures
that meet or exceed CALGreen Building Standards Code’s requirements, the use of synthetic turf
on sports fields, drought-tolerant plant species in less active areas of the park, and water efficient-
equipment and plumbing infrastructure. Energy efficient lighting, including LED technology and
sensible lighting controls will be used throughout the park. Best management practices would
include lighting controls that allow for full lighting output only during operational and occupied
times. Occupancy sensors would be incorporated to dim or turn-off lighting at the parking lots,
athletic fields, and pickleball courts after operational hours. The park would also include an onsite
stormwater treatment system designed to retain and treat stormwater in accordance with the City’s
Low Impact Development (LID) Ordinance. Therefore, the environmental effects of construction
and future operation would be reduced as compared with conventional building techniques.
Consumption of these limited or slowly renewable and non-renewable resources would occur with
any development in the region and are not unique to the Project. Additionally, because the Project
site does not contain nonrenewable resources, the Project would not directly impact or interrupt
4.0 OTHER CEQA CONSIDERATIONS
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Final EIR – January 2018
the production or delivery of such resources. The Project’s irreversible changes to the environment
would be less than significant.
4.3 GROWTH INDUCING IMPACTS
CEQA Guidelines Section 15126.2 (d) requires a discussion of the project’s potential to foster
economic or population growth, including ways in which a project could remove an obstacle to
growth, and potential significant irreversible changes. Growth does not necessarily create
significant physical changes to the environment. However, depending upon the type, magnitude,
and location of growth, it can result in significant adverse environmental effects. A project may be
growth inducing if it directly or indirectly fosters economic or population growth or the
construction of additional housing, removes obstacles to population growth, taxes community
service facilities to the extent that the construction of new facilities would be necessary, or
encourages or facilitation other activities that cause significant environmental effects. In general,
a project may foster physical, economic, or population growth in a geographic area if it meets any
one of the criteria identified below:
• The project results in the urbanization of land in a remote location (leapfrog development)
• The project removes an impediment to growth (e.g., the establishment of an essential public
service, or the provision of new access to an area)
• The project establishes a precedent-setting action (e.g., a change in zoning or general plan
amendment approval)
• Economic expansion or growth occurs in an area in response to the project (e.g., changes
in revenue base, employment expansion, etc.)
If a project meets any one of these criteria, it may be considered growth inducing. Generally,
growth inducing projects are either located at the edge of an urban area or in isolated, undeveloped,
or underdeveloped areas, necessitating the extension of major infrastructure, such as sewer and
water facilities or roadways, or encourage premature or unplanned growth. However, in urban
areas like the City, growth inducing projects typically involve major infrastructure improvements
or proposed plans or policies alleviating barriers to growth or increasing opportunities for
development.
To comply with CEQA, this EIR must discuss the ways in which the Project could promote
economic or population growth in the Project vicinity and how that growth would, in turn, affect
the surrounding environment (CEQA Guidelines Section 15126.2(d)). Under CEQA, this growth
is not to be considered necessarily detrimental, beneficial, or of significant consequence. Induced
growth is considered a significant impact only if it affects (directly or indirectly) the ability of
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Final EIR – January 2018
agencies to provide needed public services, or if it can be demonstrated that the potential growth,
in some other way, significantly affects the environment.
Population, Housing or Employment Generation
The Project would involve development of approximately 12 acres of new recreational amenities
on SMO property that is currently designated for non-aviation uses. The Project would not involve
development of new housing opportunities. There would be no net increase in residential
population that could potentially be substantially growth inducing. The Project would generate
short-term employment opportunities during construction. Because the Project is relatively small
scale in size, it can be reasonably assumed that the Project would draw all or the majority of
construction workers from the existing regional workforce. The Project could also incrementally
increase long term employment through increased demand for Park maintenance and management,
although existing City staff would likely perform most such functions with only minimal need for
additional hiring. Therefore, the Project would not be considered growth inducing as it would not
substantially affect long-term employment opportunities. The Project’s potential temporary
increase in population would represent an insignificant percentage of the City’s total population
and would not significantly increase the population of the City. Furthermore, the Project would
not have economic or social effects that would result in adverse physical changes or deterioration
of the surrounding area; no existing housing or population would be displaced. Potential impacts
associated with population, housing, and economic growth anticipated to occur with
implementation of the Project would be less than significant.
4.3.1 Removal of Obstacles to Growth
The Project would be located within a fully urbanized area of Santa Monica, which is well-served
by existing infrastructure. Major improvements to water, sewer, and circulation systems and
drainage connection infrastructure would not be needed. Because the Project constitutes
redevelopment within an urbanized area and does not require the extension of new infrastructure
through undeveloped areas, Project implementation would not remove an obstacle to growth.
Conversely, by committing approximately 12 acres of land formerly used for aviation purposes to
parks and recreational use, the Project would permanently prevent future development of the
Project site with other uses. The Project would not require a General Plan or zoning amendment
that would allow for redevelopment of residential, industrial, or commercial land uses, which are
typically associated with growth. The Project would not induce additional growth other than what
was already anticipated by the City and would not foster growth inducing impacts. Therefore,
potential impacts associated with removing obstacles to growth anticipated to occur with
implementation of the Project would be less than significant.
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4-6 Airport Park Expansion Project
Final EIR – January 2018
4.4 EFFECTS FOUND NOT TO BE SIGNIFICANT
CEQA Guidelines Section 15128 requires a statement briefly indicating the reasons that various
possible significant effects of a Project were determined not to be significant and were therefore
not discussed in detail in the EIR. Through the scoping process, the City determined that the Project
would have no impact or a less than significant impact on: Aesthetics, Agriculture and Forestry
Resources, Biological Resources, Cultural Resources, Geology and Soils, Hydrology and Water
Quality, Mineral Resources, Neighborhood Effects, Population and Housing, Public Services,
Recreation, Tribal Cultural Resources, and Utilities and Service Systems/Energy Conservation.
The impacts associated with these topic areas would be unsubstantial because the Project would
be developed in an urbanized area of the City. The Project would improve the visual character of
the site and would therefore have a beneficial impact on aesthetic resources in the area. The Project
site has been subject to substantial past grading and disturbance and is already fully developed
with buildings and paved surface areas that would be replaced, and as such, would not disturb
agricultural or forest areas, biological resources, or cultural resources which do not occur within
the Project site. Review of historic topography maps indicates that portions of the site supported a
relatively steep hillside that was subsequently graded and leveled to accommodate past uses. This
is evident from the steep cut slope along the Project site’s Bundy Avenue frontage as well as the
hillside and retaining walls below the homes east of South Bundy Drive. Aerial photographs
indicate that the site was fully developed with a municipal golf course by 1938, with associated
disturbance associated with grading of fairways, greens, sand traps and water features.
Additionally, the Project does not occur in an area containing mineral resources. The Project would
not notably alter the site geology, and would replace large impervious surface areas with
recreational amenities and landscaping, thus maintaining the site’s hydrology and potentially
reducing stormwater volume and the rate of runoff from the Project site. As discussed above, the
Project would not contribute to population and housing growth opportunities, and would utilize
City public services and utilities, including storm drainage and treatment facilities, which would
not exceed the capacity of existing systems. The Project would not significantly affect tribal
cultural resources and would have a beneficial impact on recreation for the Project vicinity and for
the City.
Aesthetics
The Project would not significantly affect any public scenic vistas or other scenic resources within
the Project site or surrounding areas. Due to existing development, expansive views of scenic
resources and scenic public views are generally not visible from the Project site or surrounding
area. Limited views of the Santa Monica Mountains may be visible from more elevated points
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Final EIR – January 2018
within the Santa Monica Airport boundaries. However, construction of the Project’s recreational
and open space areas would not obstruct existing views – the Project’s aboveground structures and
facilities (such as trees and new restrooms) would be shorter than surrounding development. Given
the Project site’s urbanized context, development under the Project would not substantially damage
scenic resources or degrade the existing visual character or quality of the Project site and its
surroundings. Construction activities and equipment on the Project site would be temporary and
would not cause a permanent impact to visual character of the Project site or surrounding areas.
As the proposed lighting standards to accommodate game play at night would be fitted with anti-
glare features such as baffles, louvers, and side shields to reduce light spillover. The Project would
include the installation of security, wayfinding, architectural, and field lighting systems for park
visitors, with an emphasis on providing adequate light levels for safety and security and to
minimize light spillover and glare to adjacent uses. The sports fields, pickleball courts, and parking
lots would be lit with pole-mounted light fixtures approximately 70 to 80 feet in height and directed
toward the area to be lit while also incorporating anti-glare features such as baffles, louvers, and
side shields to reduce light spillover. Pedestrian pathways would be lit with human-scale post-top
lighting fixtures approximately 2–3 feet in height and directed downward to the path. Site features
like benches or vertical walls would be accented with concealed lighting or wash lighting. The
pedestrian underpass at the Main Bundy Entry would be accented with uplighting.
Lighting would be designed in accordance with the SMMC. Energy efficient lighting, including
LED technology and sensible lighting controls would be used throughout the park. Light spillover
and pollution would also be mitigated through thoughtful fixture specification and best practices.
Best practices would include lighting controls that allow for full lighting output only during
operational and occupied times. Lighting would be designed so that it is not confused with runway
lighting for SMO. Occupancy sensors would be incorporated to dim or turn-off lighting at the
parking lots, athletic fields, and pickleball courts after operational hours. The proposed parking lot
would be located internal to the Project site, and vehicle headlights would be shielded from nearby
residences by park amenities and the proposed acoustical berm. Therefore, the Project would not
introduce a new source of substantial light or glare, such that views would be adversely impacted.
Therefore, impacts would be less than significant.
The Project site is presently improved with large paved surface areas and functionally designed
buildings in varying states of repair. The Project site is generally void of vegetation. The
introduction of an attractively designed park, complete with streetscape, greenspace, landscaping,
trees, and other improvements would improve visual character of the Project site and improve its
visual cohesion with the well-maintained landscaping of surrounding land uses. The Project would
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Final EIR – January 2018
have a beneficial impact on aesthetic resources in the Project vicinity and further analysis of this
issue is not required.
Agriculture and Forestry Resources
The Project would not have the potential for significant impacts associated with important
agricultural or forestry resources. The Project site and surrounding areas are entirely urbanized
and do not currently contain any developed agricultural or forestry resources. The Project would
not change any land use designations affecting such resources, and would not indirectly affect such
resources. Therefore, there is no impact to agriculture and forestry resources.
Biological Resources
The Project would not have the potential for significant impacts associated with biological
resources. The Project site is fully developed and located in an urbanized area in the City. No
special status/sensitive species occur on the Project site or surrounding area. Additionally, given
the urbanized nature of the Project site and considering that the Project site has already been
disturbed with small commercial buildings, paved surface areas, and aviation-related uses, the
likelihood of the presence of any sensitive or special status species is unlikely. Species expected
to occur onsite would be limited to terrestrial species (such as squirrels) and birds that are
commonly found in urban environments. No riparian habitat, other sensitive natural community,
or wildlife corridor/nursery site exists on the Project site or in the surrounding area. There are also
no wetlands on the Project site or in the surrounding area. The Project would not interfere with
any migratory route for terrestrial or avian species and would not conflict with a Habitat
Conservation Plan. The Project would remove approximately 30 ornamental trees during
renovation of an approximately 1.5-acre portion of the existing park. However, the existing on-
site ornamental landscaping is not protected by local policies or ordinance and the Project would
more than replace the number of trees removed. Therefore, the Project impact on biological
resources would be less than significant and further analysis of this issue is not required.
Cultural Resources
The Project would not significantly affect historic resources within the Project vicinity. Previous
surveys and record searches of the Project vicinity indicate that there are no historically significant
structures or landmarks within the Project vicinity (AECOM 2017). The only known historical
resource near the Project Site is the Santa Monica Airport Rotating Beacon Tower City of Santa
Monica designated the tower a City Landmark in 1988. Originally built in 1928, it was moved to
SMO in 1952. The rotating tower beacon is located north of Donald Douglas Loop South (between
the runway and Donald Douglas Loop south), and is not within the Project site boundaries.
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Final EIR – January 2018
The Project site consists of paved surfaced areas, and few buildings that are older than 50 years of
age. Records indicate aircraft support structures existed on the east paved surface area as early as
1953 (Appendix D.1). Small administrative office buildings and airplane hangars on the west
paved area were constructed in 1954 and the existing aircraft-related commercial building (now
occupied by Proteus Air Service) was in place since at least 1967 (Appendix D.1). Although onsite
structures are 50 years or greater in age, existing structures have not been determined to be
potentially eligible historic resources, as represented by previous surveys of the site. Therefore,
the Project would not have a substantial adverse effect on historic structures or landmarks in the
Project vicinity and there would be no impact on historic resources. Further analysis of this issue
is not required.
The Project would not significantly affect paleontological or archaeological resources within the
Project vicinity. In compliance with Assembly Bill (AB) 52 and Senate Bill (SB) 18, Native
American tribes identified by the Native American Heritage Commission (NAHC) as potentially
having input or concerns for construction activities on the Project site were contacted by letter on
March 3, 2017. No responses to these letters were received.
There is no evidence to suggest presence of archaeological resources. Review of the 1924-1925
USGS topographic map shows that much of the project site was occupied by relatively steep slopes
prior to its development with a golf course and then the existing airport related uses. Remnants of
these steep slopes remain along the steep cut slopes present on the sites Bundy Drive frontage. As
a result, the Project site is highly disturbed due to extensive grading required to support its past
development with the golf course as well as level, aviation-related and recreational land uses. No
archaeological or paleontological resources were identified as part of previous surveys and record
searches for the Project vicinity (Culbertson, Adams & Associates, Inc. 2002). Development under
the Project would occur in previously disturbed areas that have been subject to past extensive mass
grading. Given the urban, built environment of the Project site and the fact that excavation would
only occur to a depth of approximately 5 feet below ground surface, significant archaeological or
paleontological resources would not be encountered within the Project site as past grading has led
to deep disturbance of the historic soil profile. Therefore, impacts from the Project on
archeological and paleontological resources would be less than significant and further analysis of
this issue is not required.
Geology and Soils
The regional geologic setting of the Project site is situated in the central portion of the Santa
Monica Basin. The Santa Monica Basin is bounded by the Santa Monica Mountains to the north,
the Pacific Ocean to the west, the Ballona Escarpment and Baldwin Hills to the south, and the
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4-10 Airport Park Expansion Project
Final EIR – January 2018
Newport-Inglewood Fault Zone to the east (Culbertson, Adams & Associates, Inc. 2002). The
Project site and SMO Airport are located on an elevated marine terrace, which is a predominant
topographical feature of Santa Monica. The four main fault systems that are most likely to cause
potentially significant seismic damage to the Project site are the San Andreas Fault, Santa Monica-
Hollywood/Malibu Coast Fault, Newport-Inglewood Fault, and Palos Verdes Fault. No designated
Alquist-Priolo Fault Zones have been identified within the City of Santa Monica (CGS 1999).
Furthermore, the recently released preliminary Alquist-Priolo zone update map (July 2017) does
not indicate the Project site as being located across the Santa Monica Fault (CGS 2017).
Additionally, the City of Santa Monica has designated Fault Hazard Management Zones for the
Santa Monica Fault; the Project site is not located in any of these zones.
The Project site is presently improved with paved surface area, single-story structures, and
recreational uses. Below the Project site consists of approximately 10 to 30 feet of silty and
gravelly sand underlain by the San Pedro Formation, which contains layers of marine sand, silt,
and clay (Culbertson, Adams & Associates, Inc. 2002). Liquefaction is unlikely to occur on the
Project site due to the lack of the combination of saturated, cohesionless, and uniformly fine sand
(Culbertson, Adams & Associates, Inc. 2002). Subsidence is also unlikely to occur because the
City manages its groundwater use to prevent a substantial depletion of groundwater resources
which would potentially cause future subsidence on the Project site. Slope conditions on the
Project site are insignificant and the potential for slope failure does not appear to exist in the
immediate vicinity of the Project site (Culbertson, Adams & Associates, Inc. 2002).
The natural soil condition onsite consists primarily of silty sand, gravelly sand, and silty clay in
varying amounts; artificial soils (fill) onsite consist of primarily damp to moist, medium-dense to
dense concrete gravel mixed with fine to medium grained sand and silty sand. The soil type most
prevalent beneath the Project site is the Hanford soil series, which has low erosion hazard potential
and low expansion hazard potential (Culbertson, Adams & Associates, Inc. 2002).
Site grading and excavation would potentially result in short-term soil erosion impacts associated
with Project construction; however, temporary erosion control measures would be implemented
during the construction phase, as required by the City of Santa Monica grading codes. Specifically,
to reduce the potential for sediment and runoff leaving the Project site, Project construction would
occur in accordance with the requirements of the National Pollutant Discharge Elimination System
(NPDES) General Construction Permit (Order No. 99-08-DWQ) and the City of Santa Monica
Urban Runoff Pollution Ordinance (Chapter 7.10 of the Santa Monica Municipal Code[SMMC]).
In accordance with these regulations, best-management practices (BMPs) and pollutant control
measures would be employed during Project construction to minimize pollutants and reduce
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Final EIR – January 2018
sediment runoff, and ensure that Project construction complies with applicable water quality
standards.
Development of the Project site would result in intermediate alterations of the existing landform
conditions onsite; the existing concrete and asphalt surfaces would be removed and filled with
compacted gravel and soil for open space and park use. The Project would be designed in
compliance with the recommendations of a site-specific Geotechnical Report (as required by the
City during the building permit process) and applicable building codes and standards, including
the Santa Monica Building Code (which adopts the California Building Code [CBC] by reference
with local amendments), and the seismic safety design standards in the SMMC, which would
ensure that geologic and soils impacts are considered less than significant. Therefore, further
analysis of this issue is not required.
Hydrology & Water Quality
Construction of the Project would require earthwork activities including excavation of onsite soils
and site grading. During earthwork activities, exposed and stockpiled soils on the construction site
could be subject to minor erosion and conveyed via storm water runoff to municipal storm drains
and into the Pacific Ocean. However, Project construction would occur in accordance with the
requirements of the NPDES General Construction Permit (Order No. 99-08-DWQ) and the City
of Santa Monica Runoff Conservation and Sustainable Management Ordinance (Chapter 7.10 of
the Santa Monica Municipal Code). In accordance with the ordinance, BMPs and runoff control
measures would be employed during Project construction to minimize pollutants and reduce runoff
to levels that comply with applicable water quality standards. Compliance with existing regulatory
requirements would ensure pollutant levels in urban runoff during Project construction would be
fully addressed. Therefore, the Project would have no substantial construction impacts related to
violation of water quality standards or wastewater discharge requirements and impacts would be
less than significant.
With regard to Project operation, the Project would replace paved surface areas, which rapidly
convey stormwater runoff from the Project site, with recreational amenities, natural turf areas, and
landscaped areas, which would retain stormwater runoff for longer periods of time and have higher
rates of groundwater infiltration. Therefore, implementation of the Project would inherently reduce
the amount and rate of stormwater runoff from the Project site.
In addition, the City would implement good housekeeping practices to minimize polluted runoff
and prepare a Runoff Mitigation Plan in accordance with the City’s Runoff Conservation and
Sustainable Management Ordinance. The Runoff Mitigation Plan would require that the park store
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Final EIR – January 2018
and use (for non-potable purposes), infiltrate, or evapotranspire Project-generated runoff through
incorporation of Low Impact Development (LID) design elements and green infrastructure.
Existing City requirements and other 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. Project site drainage design and stormwater management
would be designed to incorporate LID principles as set forth by the City and the Los Angeles
County Water Quality Management Plan.
To meet these requirements, the Project would include biofiltration swales and/or detention basins
integrated with the landscaping, which would treat the “first flush” of a rain event (flow-through
system) and slow down the flowrates, reducing the volume of runoff. The Project BMPs would
serve as a form of pre-treatment to the overall watershed. The biofiltration systems would be
integrated and coordinated with the landscaping of the Project site and utilize storage chambers,
where applicable, to attenuate the peak flow rates that discharge into the existing storm drain
systems. Project site drainage design and stormwater management would reduce peak flowrates
and treat polluted runoff. Therefore, the Project would have no substantial operational impacts
related to violation of water quality standards and wastewater discharge requirements and impacts
would be less than significant.
The Project would not substantially deplete or interfere with groundwater quality or supply (see
also, Section 3.4 Hazards and Hazardous Materials). The City of Santa Monica overlies the Santa
Monica Groundwater Basin, and the Project site is located within the Coastal sub-basin.1 The City
of Santa Monica uses groundwater for municipal purposes. However, the Santa Monica
Groundwater Basin is not adjudicated and has a capacity of storing approximately 1.1 million acre-
feet of water (City of Santa Monica 2015a). Groundwater in the Santa Monica Basin and its sub-
basins contain various levels of contaminants from past urban and industrial development, such as
total dissolved solids (TDS), nitrate, volatile organic compounds (VOCs), and methyl tertiary butyl
ether (MTBE). However, past groundwater contamination has been remediated. In addition, the
Santa Monica Water Treatment Plant located at 1228 South Bundy Drive in the City of Los
Angeles treats water from all of the City’s three well fields to drinking water quality standards
prior to distributing it to residents. Further, while sea water intrusion into the Coastal Sub-basin
was of concern, although the City does not currently draw water from this subbasin. There are no
groundwater wells located within the Project vicinity. Water supply to the Project site would be
accommodated by the City’s municipal water distribution system. The City currently relies on
groundwater for a majority of its water supply and intends to obtain all of its water from a
1 Extensive faulting within the Santa Monica Groundwater Basin separates it into five smaller subdivisions: Arcadia,
Olympic, Coastal, Crestal, and Charnock.
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Final EIR – January 2018
combination of groundwater and recycled water by 2020 (City of Santa Monica 2015a). The City’s
2015 Urban Water Management Plan (UWMP) ensures that the existing groundwater supplies are
able to sustainably meet current City demand when supplemented with imported water from the
Metropolitan Water District (MWD). The Project’s estimated water demand of 23 acre-feet per
year (AFY) would require a negligible portion of available groundwater supplies (which have an
estimated safe yield of 12,500 AFY) and in relation to the City’s overall demand by 2030
(14,800 AFY). When compared to an average water demand of 13,567 AFY for the 2005–2010
period, the City’s water demand is anticipated to be 1,233 AFY, of which the Project constitutes
only 1.9 percent of the projected increase. The water demand of the Project would be associated
with the large, natural turf multi-purpose area, community gardens and some areas of landscaping,
which could be satisfied with existing groundwater supplies. The synthetic turf sports fields would
not require irrigation. The Project would convert large paved surface areas and aviation-related
buildings to open space and recreational uses, which would slightly improve or not change the
amount of groundwater infiltration that would occur at the Project site when compared to existing
conditions. Therefore, the Project would not substantially deplete groundwater supplies or
interfere with groundwater recharge and no impact would occur.
The Project would not substantially alter any drainage patterns in a manner that would result in
substantial on or offsite erosion, siltation, or flooding. The Project site is largely developed with
impervious surface areas with minimal amount of ornamental vegetation and the surrounding areas
are urbanized. Furthermore, there are no streams or rivers within the Project site or in the
surrounding area. Runoff from the Project site flows to the southwest and is captured in eight catch
basins located throughout the Project site. The catch basins flow to a 36-inch stormwater main
along Airport Avenue, which then flows west through a series of stormwater mains and ultimately
drains to the Penmar Water Quality Improvement Project (Penmar Project), located underneath
Penmar Recreation Center Park. Runoff is currently diverted to the sanitary sewer and treated at
the City of Los Angeles Hyperion Water Reclamation Plant. Phase II construction of the Penmar
Project is currently in progress and will eventually treat the captured runoff instead of diverting to
Hyperion Treatment Plant. Site-generated surface water runoff would continue to flow into nearby
municipal drains and/or catch basins. 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 all design plans to ensure that adequate drainage would be provided to
accommodate the Project’s stormwater flows. Therefore, the Project would not create or contribute
runoff water that would exceed the capacity of existing stormwater drainage systems and would
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4-14 Airport Park Expansion Project
Final EIR – January 2018
not degrade water quality (see also, below section on Utilities). Therefore, impacts related to
substantially altering existing drainage patterns or the rate of runoff would be less than significant.
The Project site and the surrounding vicinity is not located within a 100-year flood plain (FEMA
2008). Additionally, the Project does not involve residential development. Therefore, the Project
would not place housing within a 100-year flood plain and would not place any structures within
a 100-year flood hazard area, such that flood flows would be impeded. No dams, levees, or flood
control channels exist in the City of Santa Monica. Therefore, the Project would not expose people
or structures to a significant risk of loss, injury or death involving flooding as a result of the failure
of a levee or dam. The Project site is not located within an tsunami inundation zone or seiche
hazard zone (Cal EMA 2009). Mudflows (also called debris flows) result from the downslope
movement of soil and/or rock under the influence of gravity. Given the absence of any steep slopes
nearby, the Project site and the surrounding vicinity would not be at risk from inundation by
mudflow. Therefore, impacts would be less than significant.
Mineral Resources
The Project would not have the potential for significant impacts associated with important mineral
resources. The Project site and surrounding areas are entirely urbanized and do not currently
contain any developed mineral resources. The Project would not change any land use designations
affecting such resources, and would not indirectly affect such resources. Therefore, there is no
impact to mineral resources. Further analysis of this issue is not required.
Neighborhood Effects
The potential impacts resulting from construction and operation of the Project on adjacent
neighborhoods are evaluated in the above discussion of potential aesthetic impacts, and in Section
3.1, Air Quality, Section 3.6, Noise, and Section 3.7, Transportation and Traffic of this Draft EIR.
As concluded in Section 3.1, Air Quality, construction and operation of the Project would result in
a less than significant air quality impact to adjacent residences and no carbon monoxide (CO) “hot
spots” would be formed at any of the study intersections.
As concluded in Section 3.6, Noise¸ when conservatively compared against City of Los Angeles
thresholds, Project construction would result in a temporary, significant noise impact at the
residences across South Bundy Drive, which are located in the City of Los Angeles. When
compared to City of Santa Monica thresholds, Project construction would not exceed established
thresholds at these residences. No feasible mitigation is available to reduce construction noise
levels to below City of Los Angeles thresholds. However, construction-related significant noise
impacts would be episodic depending on equipment use, are temporary (i.e., a period of
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Airport Park Expansion Project 4-15
Final EIR – January 2018
approximately 14-15 months) and would cease once construction of the Project is completed.
Further, Project construction would be limited to daytime hours Monday through Saturday, when
ambient noise levels are highest, and prohibited on Sundays and holidays. As a result, Project
construction is not anticipated to result in sleep disturbance at the adjacent residences. As
discussed in Section 3.6, Noise, Project operation would generate nuisance noise at adjacent
residences during the park’s hours of operation (6:00 A.M. to 10:00 P.M.), of which cheering crowds
at sporting events would generate the highest levels of nuisance noise. Noise generated by cheering
crowds already occurs at the Project site, would be intermittent, and would not exceed thresholds
established by either the City of Santa Monica or the City of Los Angeles, even without accounting
for any reduction in noise transfer that would result from the acoustical berm proposed by the
Project.
As concluded in Section 3.7, Transportation and Traffic, Project operation would result in a
significant increase in vehicle trips (i.e., more than one vehicle trip) on two neighborhood street
segments, 23rd Street north of Dewey Street and Dewey Street west of 23rd Street. However, this
determination is based on the City’s goal of creating no net new trips on these streets during the
P.M. peak hour. While no feasible mitigation measures are available to reduce Project trips on these
streets to less than one vehicle, the increase in trips resulting from the Project represent less than
a one percent increase in vehicle trips when compared to existing conditions. The increase in trips
along these streets would not result in a perceptible change in roadway noise to adjacent residences.
As a result, impacts would be less than significant and no further evaluation of Neighborhood
Effects in an EIR is recommended.
Population and Housing
The Project would not have the potential for significant impacts associated with population and
housing (see also, Population and Housing Generation under Section 4.3 Growth Inducing
Impacts). The Project does not involve development of new housing opportunities. The Project
would generate primarily short-term employment opportunities during construction and would not
generate substantial long-term employment opportunities. Short-term construction employment
opportunities resulting from the Project would draw from the existing regional workforce and
would not significantly increase the population of the City. Further, while Park maintenance and
management could incrementally increase demand for City staff, it is anticipated that any changes
in City staff would be minor and that existing Park personnel could perform all or most required
activities. Therefore, there would be no direct or indirect increase in residential population that
could result in substantial population growth. Additionally, no existing housing or population
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4-16 Airport Park Expansion Project
Final EIR – January 2018
would be displaced. Therefore, potential impacts of the Project associated with population and
housing would be less than significant. Further analysis of this issue is not required.
Public Services
Fire Protection
The Santa Monica Fire Department (SMFD) provides fire protection services and emergency
medical (paramedic) services within the City. The City has four fire stations that provide
emergency response services to the Santa Monica community. Additionally, the SMFD strictly
enforces the City’s current Fire Code which provides strict requirements for fire suppression
systems, use of fire resistant building materials, and visible address signage (Santa Monica Fire
Department 2017). Santa Monica Fire Department Station No. 5 located approximately 1.2 miles
west of the Project site at 2450 Ashland Avenue is the first-response station for the Project site.
The current fire response time for SMFD is 5 minutes. The SMFD has approximately 122 total
personnel, of whom 108 are sworn firefighters (Amec Foster Wheeler 2016).
As discussed in Section 3.7 Transportation and Traffic, during Project construction activities,
emergency access to the Project site would be maintained for pedestrians and emergency vehicles
and the realigned Donald Douglas Loop would be designed to allow adequate emergency access.
Additionally, the Project would be designed in accordance with the applicable provisions of the
SMMC pertaining to fire protection. The Project’s recreational uses would result in a negligible
demand for fire protection services and expansion of existing SMFD facilities or personnel would
not be necessary to accommodate demand associated with the Project. The existing staff,
equipment, and facilities are sufficient to provide similar level of service after implementation of
the Project. Therefore, impacts to fire protection services would be less than significant.
Police Protection
The Santa Monica Police Department (SMPD) provides police protection services within the City.
SMPD headquarters are located approximately 3.6 miles west of the Project site at 333 Olympic
Drive. The SMPD has 197 sworn enforcement personnel and 255 non-sworn administrative and
support staff (SMPD 2016). The SMPD divides the City into four beats and operates these beats
on a 24-hour basis. The Project site is located within Beat 2. SMPD’s maximum allowable
response time to emergency calls is 5 minutes or less and there are 63 officers deployed across the
City at all times (Amec Foster Wheeler 2016). The Project’s recreational uses would result in a
negligible increase in demand on police protection services by SMPD, including services related
to airport security, and SMPD would not need to construct a new facility or alter an existing facility
to accommodate the Project. SMPD would monitor the need for police services and would request
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Airport Park Expansion Project 4-17
Final EIR – January 2018
appropriate service enhancements through the annual budgetary process if the need arises.
Therefore, impacts to police protection services would be less than significant.
Schools
The Santa Monica-Malibu Unified Scholl District (SMMUSD) provides education to the City and
Project site. The SSMUSD operates thirteen public (K-12) schools in Santa Monica, including
seven (K-5) elementary schools, two (6-8) middle schools, one (K-8) alternative school, two (9-
12) high schools, and one (6-12) middle and high school, as well as additional school facilities in
the City (SMMUSD 2017). There were approximately 10,027 students enrolled during the 2015-
2016 school year (SMMUSD 2016). The Project does not involve residential uses and would not
significantly change employment, and implementation of the Project would not result in a direct
or indirect population growth that would increase demand on SMMUSD schools. Therefore,
impacts to school facilities would be less than significant.
Other Public Facilities
The City of Santa Monica Public Works Department (PWD) provides park maintenance for the
City’s 27 parks and approximately 141 acres of park space, medians, City facilities, and the Civic
Center complex. Approximately 125.5 acres of park space is maintained as formal space and
recreational facilities for the City’s population. The City also provides additional public services,
such as the five Santa Monica Public Libraries and additional recreational facilities, such as plazas,
regional areas, and school facilities with joint-use agreements (City of Santa Monica 2017). As
discussed in Population and Housing, the increase of employees and services provided from
Project implementation would not generate a residential population that would substantially
increase the demand for libraries or other public facilities. As discussed in Recreation, the Project
would not introduce a new population that would increase additional demands on existing or
planned park facilities. The Project would result in a positive impact by providing additional open
space and recreational amenities within the City and for its residents. The provision of additional
recreational amenities under the Project may reduce the demand for use at other City parks.
Therefore, impacts to parks and other public facilities would result in a beneficial impact.
Potential impacts to fire protection, police protection, schools, parks, or other public facilities
would result in no impact, less than significant impact, or a beneficial impact. The Project would
not result in significant effects to public services and further analysis of this issue is not required.
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Recreation
The Project site is located in an urbanized area of the City of Santa Monica. The City has 27 parks
that range in size from 0.16 acres (Schader Park) to 26.41 acres (Palisades Park). The City also
provides 3 community gardens, 5 public grounds (e.g., Annenberg Beach House, Civic
Auditorium, Community Center, etc.) (Amec Foster Wheeler 2016). The City also provides and
maintains stretches of sandy beach, off-leash dog parks, bike and walking paths, lawn areas, and
other recreational opportunities for the City’s residents, employees, and visitors. Recreational
areas near the Project site include the currently developed portion of Airport Park (located directly
adjacent to the east and south of the Project site), Clover Park (approximately 1,800 feet
northwest), and the City of Los Angeles’ Venice Reservoir Site (approximately 1,200 feet
southeast), which is a neighborhood park featuring baseball and softball fields, open green space,
and a picnic area.
The Project includes expansion of the existing 8.3-acre Airport Park and development of new
recreational facilities, which would alleviate demand and impacts of overuse on existing parks in
the community. General park facilities and amenities proposed under the Project consist of
synthetic turf sports fields, community gardens, pickleball courts, a sports track, pedestrian
pathways, restroom facilities, and onsite parking. Streetscape and emergency access improvements
are also proposed under the Project which would enhance the experience and safety of pedestrians
in the park. In addition, by providing expanded recreational opportunities, the Project could reduce
the demand on other parks and recreation facilities. Therefore, the Project would have a beneficial
impact on recreational resources in the Project vicinity and further analysis of this issue is not
required.
Tribal Cultural Resources
The Project would not significantly affect tribal cultural resources within the Project vicinity. In
compliance with AB 52, Native American tribes identified by the NAHC as potentially having
input or concerns for construction activities on the Project site were contacted by letter on March 3,
2017. The City received no response to these consultation letters. No tribal cultural resources were
identified as part of previous surveys and record searches for the Project vicinity (Culbertson,
Adams & Associates, Inc. 2002). Further, as discussed above, development under the Project
would occur in areas subject to previous substantial grading, including major cut and fill of historic
slopes. Given the urban, built environment of the Project site, it is unlikely that significant tribal
cultural resources would be encountered within the Project site. Therefore, based on limited
potential for undiscovered tribal cultural resources to exist within the Project site, impacts from
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Final EIR – January 2018
the Project on tribal cultural resources are considered to be less than significant and further analysis
of this issue is not required.
Utilities and Service Systems/Energy Conservation
Energy and Power
Southern California Edison Company (SCE) provides electricity service to the City and Southern
California Gas Company (SoCal Gas) is the natural gas provider for the City. As of 2013, overall
electricity and natural gas consumption was 6.1 Gigajoules (GJ), 0.7 percent higher than 2012, but
still 10.4 percent lower than 1990, the highest year recorded for the City; an increase in natural gas
accounted for the change, rising 3 percent from 2012 while electricity usage dropped 1.5 percent.
The commercial sector dominated energy consumption contributing 58 percent of total energy
demands while the residential sector accounted for 42 percent. As of 2015, the City has
successfully reduced its annual community greenhouse gas emissions 20 percent below 1990
levels. This is the result of the City’s efforts through the 15x15 Climate Action Plan and other
community activities. External factors have also influenced the downward trend; the electricity
that is provided to the City comes from sources that are now 28 percent renewable (City of Santa
Monica 2016). The City’s Sustainable City Plan indicates that the City plans to reduce total energy
use by 10 percent and 50 percent of all electricity will come from renewable sources by 2020.
Commercial energy use has dropped significantly due to gains in energy efficiency (City of Santa
Monica 2014a). Energy consumption in new buildings is regulated by State Building Energy
Standards (Title 24) and the City’s Green Building Ordinance. Currently, energy services in the
Project vicinity are considered adequate; no deficiencies in service capacities have been identified
(Amec Foster Wheeler 2016).
There is an existing gas line south of Airport Avenue, however, the Project would not require the
use of natural gas. Hot water in the park/restroom building would be provided by an electric or
solar water heater system rather than from natural gas sources. An existing power line running
along Airport Avenue 300 feet west of Bundy Drive provides electrical charge of 120/240v single-
phase, three-wire, 4kV overhead lines; there is also a three-phase bank along the same line that
provides 240v three-phase, three-wire service (Culbertson, Adams & Associates, Inc. 2002).
Currently, the largest main switch that can be served from the existing single-phase system is 400
amps. An onsite transformer taking the form of a pad-mounted structure or a below-grade structure
would likely be required to meet the increased demand for electricity to power the Project’s variety
of lighting structures. The sports fields, pickleball courts, and parking lots would be lit with pole-
mounted light fixtures approximately 70 to 80 feet in height. Pedestrian pathways would be lit
with human-scale post-top lighting fixtures approximately 2–3 feet in height. Site features like
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Final EIR – January 2018
benches or vertical walls would be accented with concealed lighting or wash lighting. The
pedestrian underpass at the Main Bundy Entry would be accented with uplighting.
As discussed above, Project design features would be included to reduce the Project’s overall
energy demand when compared to standard construction practices. For instance, the Project
would, at a minimum, comply with the green building requirement requirements included in the
Cal Green Building codes and the City’s Green Building Standards. The sustainable design
features include energy-efficient lighting fixtures that meet or exceed the Code’s requirement, the
use of synthetic turf on the sports fields and drought-tolerant plant species in less active areas of
the park, and water-efficient equipment and plumbing infrastructure. Energy efficient lighting,
including LED technology and sensible lighting controls will be used throughout the park.
Occupancy sensors would be incorporated to dim or turn-off lighting at the parking lots, athletic
fields, and pickleball courts after operational hours. As the available electrical infrastructure is
adequate to serve the Project, impacts would be less than significant.
Water
The City of Santa Monica Water Resources Division is the agency that provides water service to
the City. The City distributes water to approximately 18,000 customers throughout a 250-mile
network of water lines ranging from 4 to 36 inches in diameter. Water for the City of Santa Monica
service area consists of local groundwater, imported water from the Metropolitan Water District
of Southern California (MWD), and urban treated runoff water from the Santa Monica Urban
Runoff Recycling Facility (SMURRF). The City’s primary sources of water supply include
groundwater drawn from the Santa Monica Groundwater Basin (SMGB) and regional water
supplies provided by the MWD. The City operates three groundwater well fields within the Santa
Monica Basin that lie within the Arcadia Sub-Basin, the Olympic Sub-Basin, and the Charnock
Sub-Basin. The MWD delivers water imported from the Colorado River and the State Water
Project to the City. The City of Santa Monica contracts with MWD to provide imported water at
two locations: Arcadia Water Treatment Plant and Charnock Wellfield and Pump Station site.
Historically, the City produced approximately 70 percent of the municipal water supplies from
groundwater resources; however, the City confirmed contamination (methyl tert-butyl ether) in
groundwater supplies from the Charnock Groundwater Sub-basin wells from 1996 to 2011 and
have relied more heavily upon imported water supplies from the Metropolitan Water District of
Southern California. Presently, contamination has been remediated and all 5 wells are operational.
During a normal water year, the 2015 UWMP estimated the total maximum projected water supply
capacity to be approximately 20,469 acre-feet per year (AFY) through 2040, consisting of 7,409
AFY of imported MWD water, 12,500 AFY of local groundwater from the SMGB, and 560 AFY
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Final EIR – January 2018
of urban treated runoff water (City of Santa Monica 2016). The available supply would be reduced
to 19,906 AFY during a “multiple dry year” scenario due to a reduced amount recycled dry water
urban runoff.
Additionally, when the State of California entered a fourth year of drought in 2015, urban water
reduction mandates were issued to conserve water resources throughout the state. Actions to
reduce water demand include the City’s Sustainable Water Master Plan, which outlines the City’s
plan to achieve water supply self-sufficiency (i.e., no reliance on imported water) by 2020 (City
of Santa Monica 2014b). The Sustainable Water Master Plan includes an evaluation of expanded
demand management measures and a variety of water supply alternatives including recycled water,
storm water collection and treatment, rainwater harvesting, gray-water applications, and other
water rights supply and exchange opportunities to align with the goal of water self-sufficiency.
This plan illustrates projected water supply and demand scenarios, and characterizes the
approximate magnitude of supply deficits or unpredictability that needs to be addressed to meet
the City’s self-sufficiency objectives by 2020 (City of Santa Monica 2014b). Additionally, in
January 2015, the City adopted the Water Shortage Response Plan to reduce water usage citywide
by 20 percent by December 31, 2016 through penalties for residents and businesses who fail to
reduce their water usage by 20 percent below their 2013 usage (City of Santa Monica 2015b).
According to the 2015 UWMP, the City had an average annual water demand of approximately
13,567 AFY between 2005–2010. Under the City’s LUCE, the land use changes within the City
are expected to create a water demand of 15,323 AFY by 2020 and 16,066 AFY by 2030 (City of
Santa Monica 2010). However, based on a recent study conducted by the City’s Department of
Public Works, a comparison of current water demands and the City’s LUCE projected demands
suggests that the LUCE projection may be too high (City of Santa Monica 2013). Whereas the
LUCE projected citywide water demands of approximately 15,300 AF in 2012, a detailed billing
data analysis shows actual demand in 2012 was approximately 13,872 AF; a difference of 1,800
AF. To plan for future supply needs, a comprehensive demand analysis was performed in 2013-
2014 by the City Water Resources Division in order to develop new demand projections that align
more closely with current demands. The analysis indicates that water demand is expected to be
approximately 14,100 AFY by 2020 and 14,800 AFY by 2030 (City of Santa Monica 2013,
2014b). When the projected water demand for 2030 is compared to the available water supply of
20,469 AFY during a normal year scenario and 19,906 AFY during multiple dry years, the City
would have an excess water supply of 5,669 AFY and 5,106 AFY, respectively.
The Project would receive its potable and irrigation water from the 12-inch diameter City main
located in Airport Avenue, likely through 4-inch diameter domestic water feeds at selected point
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Final EIR – January 2018
connections. A water meter would be provided for the City at the back of the curb along Airport
Avenue and a backflow preventer would be located in the landscaping. As previously mentioned,
the park would be designed to include sustainable design features that help reduce water demand,
such as drought-tolerant landscaping and water efficient-equipment and plumbing infrastructure.
The City’s LUCE EIR does not provide a water demand factor for parks and open space, and does
not identify parks and open space as a land use requiring substantial water demand. Based on the
water demand factor applied in the 2002 EIR, the portions of the expanded park requiring irrigation
(natural-turf multi-use area, landscaping, community gardens) would have an estimated water
demand of approximately 23 AFY.2 The proposed synthetic turf sports fields, roadways and
parking lot, and pickleball courts would not require water for irrigation. When combined with
minimal potable water use required the two, small concession/restroom buildings, the Project’s
water demand would be negligible in relation to the City’s projected water demand through 2030
(14,800 AFY) and excess available water supply during both a normal year (5,669 AFY) and
multiple dry years (5,106 AFY). When compared to an average water demand of 13,567 AFY for
the 2005–2010 period, the City’s projected water demand for 2030 of 14,800 AFY represents an
increase of approximately 1,233 AFY, of which the Project constitutes only 1.9 percent of the
projected increase. As a result, the Project water demand could be accommodated by the City’s
existing and future water supply and impacts to the City’s water supply would be less than
significant. Furthermore, the Project’s estimated water demand would not require the construction
of new water treatment facilities or expansion of existing facilities and impacts would be less than
significant.
Sewer
Wastewater is collected through the City of Santa Monica’s wastewater system, which is owned
by the City of Santa Monica and is managed, operated, and maintained by the Water Resources
Division of the City’s Environmental and Public Works Department. The City’s sewer collection
system consists of 2,875 active pipe segments with a total length of approximately 152 miles of
pipe ranging in size from 6 inches to 36 inches in diameter (Amec Foster Wheeler 2017). All
wastewater is treated at the Hyperion Treatment Plant (HTP), located approximately eight miles
southeast of the Project site, along the Santa Monica Bay coastline. The HTP operates in
accordance with water quality permits issued by the Los Angeles Regional Water Quality Control
2 The 2002 EIR assumed water use would be 82 gallons per day (gpd) per 1,000 square feet (ksf) based on the Southern
California Water Company water demand factor for general public park use. This water demand factor is conservative
is that it doesn’t consider reductions in water demand for drought-tolerant species and the use of drip-irrigation systems.
A total of 5.68 acres of the expanded park area would require irrigation, including 4.14 acres of landscaped area,
1.29 acres of natural turf multi-purpose area, and 0.25 acre of community gardens.
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Final EIR – January 2018
Board (LARWQCB). The LARWQCB in connection with implementation of the NPDES program
impose requirements on the treatment of wastewater and its discharge into local water bodies,
including Santa Monica Bay. Wastewater produced by the Project would meet these requirements
through treatment at the HTP. 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. Therefore, LARWQCB wastewater treatment requirements would not be exceeded and
the Project would not conflict with any existing wastewater management plans. Therefore, impacts
would be less than significant.
To ensure that wastewater flows would be adequately accommodated, the City reviews sewer lines
based on the depth of the Peak Wet Weather Flow (PWWF), projected for the design period, for
sewer lines. Per the City, sewers shall be sized such that the PWWF is no more than 75 percent of
the pipe diameter (d/D = 0.5 where d = depth of flow and D = pipe diameter). The City uses this
design screening criteria of d/D=0.75 for utilities planning purposes to assess whether future
upgrades are needed to their sewer system. This 0.75 d/D factor applies to all the sewer segments
that operate based on gravity flow. The City’s daily wastewater flow is metered and averages about
9 million gallons per day (GPD).
Santa Monica wastewater flows primarily by gravity in a southerly direction via the existing sewer
system to the City of Los Angeles sewer network near Dewey Street and is delivered to the HTP
via the Coastal Interceptor Sewer System (CISS). The CISS system is designed for 51.7 million
gallons per day (mgd) at its terminus at the southern City boundary. The HTP currently processes
an average of 340 mgd but has a dry weather capacity of 450 mgd and a wet weather capacity of
850 mgd (Amec Foster Wheeler 2016). As such, the City’s 9.23 mgd of wastewater flows
contributes approximately 2.7 percent of the daily flows received by the HTP (Amec Foster
Wheeler 2017). The majority of the water consumed on the Project site would be for irrigation
purposes and would not be discharged into the sewer system. Only the Project’s two restroom
concession building would discharge into the City sewer system. The Project’s two
concession/restroom buildings are anticipated to generate a minimal amount of wastewater, which
constitute a negligible fraction of the City’s contribution to the existing sewer system and HTP.
Given the large remaining capacity of the City’s wastewater treatment systems, the increase in
wastewater flows generated by the Project would not significantly contribute to the remaining
capacity of the HTP and City’s CISS.
Both concession/restroom buildings would likely require a 4-inch diameter sanitary sewer line to
discharge wastewater from the buildings into the City sewer line on Airport Avenue. There are 6-
inch laterals existing on-site which may also be utilized to convey these wastewater flows offsite.
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Final EIR – January 2018
Existing sewer lines on the Project site flow by gravity towards the west and south directions. The
marginal increase in wastewater would be within the City’s contractual entitlement for flows to
the HTP and the Project would not require or result in the need to construct new wastewater
treatment facilities or expand existing facilities. Adequate wastewater treatment capacity exists to
serve the Project and the Project would not require upgrades to the sewer lines serving the Project
site. As discussed above, the Project would not generate a substantial increase in wastewater and
would be adequately accommodated by the existing wastewater collection system. Therefore, the
Project would not require the construction of new wastewater treatment facilities or expansion of
existing facilities and impacts would be less than significant.
Solid Waste
The Resource Recovery and Recycling Division of the City’s Public Works Department provides
solid waste management and collection services to all Santa Monica residents and approximately
50 percent of commercial and industrial operations within Santa Monica. The City collects,
transfers, and disposes of trash; processes green waste and food scraps for compost; recycles
single-stream commingled recyclables; and provides a State authorized e-waste collection facility.
The City sorts and sends disposed items to reuse and recycling facilities instead of landfills
whenever possible, which is a solid waste management approach otherwise known as diversion.
Currently, 77 percent of solid waste generated in the City is diverted through waste prevention,
recycling, and composting; the remaining 23 percent is disposed in landfills or waste-to-energy
facilities (HDR 2013).
Municipal solid waste generated in the City is hauled through the Southern California Disposal
Transfer Station (1908 Frank Street) within the City and then transferred for disposal at several
landfills within the City or converted to energy resources at transformation (waste-to-energy)
facilities. Landfills and other solid waste facilities serving the City have a remaining capacity of
2,244 million tons and a maximum daily capacity of 24.5 million tons (Amec Foster Wheeler
2017). The majority of the City’s solid waste currently disposed of in landfills is sent to the
Sunshine Canyon City/County Landfill and Commerce Refuse-To-Energy Facility, which have
66 million tons and 400 million tons of remaining capacity, respectively (CalRecycle 2017). The
City currently generates an average of 110 tons per day, which is negligible relative to the
maximum daily capacity of the waste disposal facilities.
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
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Final EIR – January 2018
of C&D material from landfills. With approximately 522,270 sf (12 acres) of new recreational uses
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. Additionally,
the increase in solid waste generated from Project operation would be marginal when compared to
the remaining capacity and daily permitted intake of solid waste landfills serving the City. Given
the large remaining regional landfill capacity and projected increases in diversions rates, future
solid waste resulting from the Project would not impact the ability of these landfills to
accommodate solid waste generated in Santa Monica. Therefore, the Project would be served by a
landfill with sufficient capacity and impacts would be 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 WMP would be prepared prior to commencement
of construction work. Therefore, the Project would comply with federal, state, and local regulations
related to solid waste and impacts would be less than significant.
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5.0 ALTERNATIVES
5.1 INTRODUCTION
This section of the EIR evaluates alternatives to the proposed Airport Park Expansion Project
(Project) and analyzes the comparative environmental impacts associated with each alternative
consistent with the California Environmental Quality Act (CEQA).
The CEQA Guidelines state that an “EIR shall describe a range of reasonable alternatives to the
proposed project, or to the location of the project, which would feasibly attain most of the basic
objectives of the project but would avoid or substantially lessen any of the significant effects of the
project, and evaluate the comparative merits of the alternatives” (Section 15126.6).
The CEQA Guidelines state that “the range of alternatives required in an EIR is governed by a
rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the project. Of those alternatives, the EIR need to examine in detail
only the ones that the Lead Agency determines could feasibly attain most of the basic objectives
of the project (Section 15126.6(f)(1)).
Not every conceivable alternative must be addressed, nor do infeasible alternatives need to be
considered (CEQA Guidelines Section 15126.6(a)). In defining feasibility of alternatives, the
CEQA Guidelines state that “among the factors that may be taken into account when addressing
the feasibility of alternatives are site suitability, economic viability, availability of infrastructure,
general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and
whether the proponent can reasonably acquire, control or otherwise have access to the alternative
site” (Section 15126.6).
The alternatives selected for review must adequately represent the spectrum of environmental
concerns to permit a reasonable choice of alternatives. The CEQA Guidelines also requires the
analysis of a No Project alternative. The EIR must also provide the rationale for selecting or
defining the alternatives evaluated throughout the document, including identifying any alternatives
that were considered by the Lead Agency, but rejected as infeasible during the scoping process.
Based on the alternatives analyzed, the environmentally superior alternative is to be identified.
The EIR should include sufficient information about each alternative to allow meaningful
evaluation, analysis, and comparison with the Project. The alternatives analyzed in this EIR have
been prepared at a sufficient level of detail to permit their consideration for adoption by the City
of Santa Monica (City). When considered with the information contained in the body of this EIR,
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the analysis of these alternatives adequately characterizes the potential associated impacts on the
environment. However, depending upon the degree of design changes associated with any given
alternative, an additional administrative level of environmental review may be required to refine
mitigation measures and assess detailed changes in the Project description associated with the
adoption of one of these alternatives.
The alternatives analysis for this EIR is presented in four major parts. Section 5.2 below describes
the objectives of the Project. Section 5.3 summarizes the potentially significant and unavoidable
short- and long-term impacts of the Project based on the analyses presented in Chapter 3.0. Section
5.4 identifies alternatives considered but discarded from further evaluation. Section 5.5 describes
those alternatives selected for full evaluation, and discusses potential impacts of the alternatives.
The final section, Section 5.6 concludes with the selection of an environmentally superior
alternative based on consideration of the fewest significant impacts while meeting the greatest
number of Project objectives.
5.2 PROJECT OBJECTIVES
Section 15124(b) of the CEQA Guidelines requires a project description to contain a statement of
a project’s objectives and Section 15124(b) requires that the statement of objectives include the
underlying purpose of the project. The primary objectives of the Project are discussed in Section
2.0, Project Description, and summarized below:
1. Provide a Broad Range of Safe Park Uses: Enhance and expand the City of Santa Monica
open space system by providing a broad range of safe, high-quality recreational amenities for
residents of all ages and abilities, with an emphasis on maximizing the total square footage of
sports fields available at Airport Park.
2. Accommodate Future Expansion of Airport Park: Ensure that the design of Airport Park is
compatible with the goal of a much larger and more varied mix of active and natural park uses
anticipated following the closure of the airport, to facilitate further expansion of Airport Park
in the future.
3. Community Needs: Develop recreational uses that meet the highest priority needs of the
community.
4. Compatible Interface with Adjacent Uses: Design a park and recreation facility that is
sensitive to, and compatible with surrounding land use and the environment.
5. General Plan Open Space Element: Implement Policy 2.1 of the Open Space Element to
revise portions of public lands, including the “conversion of non-aviation lands at the
Municipal Airport including streetscape improvements to Airport Avenue, sports fields, picnic
areas, and an off-leash dog area.”
6. Streetscape Improvements: Provide sidewalk, street and streetscape improvements along the
relocated portion of Donald Douglas Loop South and portions of Bundy Drive north of the
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Final EIR – January 2018
existing dog park to the project’s northerly boundary to enhance aesthetics of the Airport,
including Airport Park and its surrounding land uses.
7. Minimize Noise Impacts: Buffer potential noise impacts associated with airport operations
on Airport Park, and potential noise impacts associated with Airport Park on the nearby
residential and commercial uses.
8. Minimize Traffic Impacts: Develop high-quality recreational facilities in walking distance to
residents and with convenient access to public transit options.
9. Architectural Design: Ensure high-quality architectural design that enhances the park’s
surroundings, including by incorporating attractive architectural features, landscaping, and
lighting.
10. Sustainability: Build new and modern energy-efficient amenities and water saving features
that are sustainable and meet the latest building and energy codes.
5.3 SUMMARY OF POTENTIALLY SIGNIFICANT AND UNAVOIDABLE PROJECT IMPACTS
Based on the analysis presented in this EIR, implementation of the Project would result in short-
term significant and unavoidable construction-related impacts to noise, and long term significant
and unavoidable impacts to transportation and traffic based on intersection level of service. Please
refer to Section 3.6, Noise, and Section 3.7, Transportation and Traffic, for the full analysis.
Noise
During Project construction, the use of heavy-duty construction equipment as part of the
demolition and grading phases would result in maximum unmitigated short-term noise levels that
could reach as high as 98 dBA at the existing Airport Park and 93 dBA at the exterior of nearby
residential uses east across South Bundy Drive. These noise levels were identified as significant
and unavoidable under the City of Los Angeles construction noise thresholds, but would be less
than significant under the City of Santa Monica’s thresholds as discussed below.
The Project would be required to implement MM NOI-1, which would limit the noisiest
construction activities to between the hours of 10:00 A.M. and 3:00 P.M. consistent with Section
4.12.110(d) of the City’s Noise Ordinance. Under MM NOI-1, the implementation of noise
attenuation measures may include the use of noise barriers (e.g., sound walls) or noise blankets.
Additionally, MM NOI-1 would require construction staging areas and earthmoving equipment to
be located as far away from noise and vibration-sensitive land uses as possible to reduce
construction-related noise levels. Further, MM NOI-1 would ensure that haul trucks associated
with construction activities are routed away from residences located along Dewey Street and
adjacent to South Bundy Drive to the maximum extent feasible. Lastly, Project construction would
be required to comply with Section 4.12.110(c) of the Noise Ordinance, which requires applicants
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Final EIR – January 2018
of construction projects located within 500 feet of any residential development, or other noise
sensitive land uses, to submit a list of equipment and construction activities prior to the issuance
of a building permit. This list must include (1) construction equipment to be used, such as pile
drivers, jackhammers, pavement breakers, or similar equipment; (2) construction activities such as
24-hour pumping, excavation or demolition; and (3) a list of measures that will be implemented to
minimize noise impacts on nearby residential uses. Therefore, under City of Santa Monica
thresholds, short-term construction noise impacts would be less than significant.
As a general rule, a sound wall is able to reduce noise by 5 dBA. The existing wall along the
residential neighborhood east of the site would reduce construction noise levels to residences
across South Bundy Drive (in the City of Los Angeles) to approximately 88 dBA. The City of Los
Angeles considers any construction activity that would exceed existing ambient noise levels by
5 dBA or more at a sensitive receptor to result in a significant noise impact. Thus, even with the
noise attenuation measures implemented under MM NOI-1, the residences across South Bundy
Drive could potentially experience short-term construction-related noise levels of 88 dBA, which
is greater than 5 dBA above ambient noise levels. The highest noise levels would occur during
construction along the Project site’s eastern boundary, primarily from construction of the proposed
acoustic berm/wall, which involves earthmoving equipment. Construction noise levels would
decrease rapidly as construction activities moves toward the center of the Project site. Nonetheless,
even with the implementation of identified mitigation measures, noise impacts to the residences
across South Bundy Drive are conservatively considered to be significant and unavoidable based
on the City of Los Angeles thresholds.
Transportation and Traffic
During operation of the Project, the proposed sport fields and recreational uses would generate up
to an estimated 35 net new A.M. peak hour trips (19 inbound/16 outbound) and 98 net new P.M.
peak hour trips (55 inbound/43 outbound) (Table 3.7-8). Based on the City’s significance
thresholds for intersection level of service, the Project would result in significant traffic impacts
at three intersections during the Approval Year (2017) scenario: 23rd Street & Dewey Street (P.M.
peak hour), 23rd Street & Walgrove Avenue (A.M. peak hour), and Bundy Drive & Ocean Park
Boulevard (P.M. peak hour). In addition, the Project would also result in cumulatively considerable
impacts at four intersections under the Future Year (2025) scenario, which includes the three
intersections listed above and the intersection at Centinela Avenue & Airport Avenue (P.M. peak
hour). Further, Project operations would increase vehicle trips (i.e., more than one vehicle trip) to
two street segments, 23rd Street north of Dewey Street and Dewey Street west of 23rd Street,
resulting in significant impacts at these locations. No significant impacts were identified at
5.0 ALTERNATIVES
Airport Park Expansion Project 5-5
Final EIR – January 2018
intersections within the City of Los Angeles based on that City’s adopted thresholds. Due to
physical constraints (e.g., no additional right-of-way available due to adjacent development), no
feasible mitigation measures are available to reduce impacts to study intersections and street
segments. Therefore, the Project would result in a significant and unavoidable impact to
transportation and traffic.
5.4 ALTERNATIVES CONSIDERED BUT DISCARDED
As discussed above, CEQA Section 15126.6(c) requires that an EIR disclose alternatives that were
considered and discarded and provide a brief explanation as to why such alternatives were not fully
considered in the EIR. Among the factors that may be used to eliminate alternatives from
consideration in an EIR are i) failure to meet most of the project objectives, (ii) infeasibility, or
(iii) inability to avoid significant impacts.
As required by the CEQA Guidelines, the selection of alternatives for the Project included a
screening process to determine which alternatives could reduce significant effects but also feasibly
meet most of the Project objectives. Because of the Project’s potential for significant impacts
related to transportation and traffic, this screening was particularly important for determining the
feasibility of alternatives. The following alternatives were considered but eliminated from further
analysis due to inconsistency with primary Project objectives, infeasibility, or inability to avoid
significant impacts.
Alternate Land Use Alternative
Under the Alternate Land Use Alternative, the proposed land use mix would shift from recreational
uses to commercial or light industrial uses. For the purposes of this alternative, potential land uses
for this alternative are anticipated to be a continuation of land uses already existing in the Project
vicinity. This alternative would consider the development of one- to two- story buildings for office
and light industrial uses, with an operational date similar to that of the Project (i.e., 2020). These
buildings may be laid out in a traditional commercial formation similar to the development north
of the Airport on Ocean Park Boulevard. While the broader Project vicinity is currently dominated
by residential uses, it is not anticipated that residential uses would be developed on the Project site
due to their incompatibility with existing airport operations until its closure in 2028.
The Alternate Land Use Alternative would not meet the Project’s underlying purpose or the
primary Project objectives. The “residual lands” south of the runaway have been envisioned for
park and recreational uses since the 1984 Settlement Agreement between the City and the Federal
Aviation Administration (FAA) (1984 Settlement Agreement). Additionally, with the February
5.0 ALTERNATIVES
5-6 Airport Park Expansion Project
Final EIR – January 2018
2017 Settlement Agreement/Consent Decree between the City and the FAA to cease operations at
Santa Monica Airport (SMO) by 2028, extensive park and recreational uses are anticipated to be
planned following closure of the SMO. Therefore, the development of commercial or light
industrial uses under this alternative is discarded because it would not meet the Project’s primary
objective of constructing a board range of high-quality recreational amenities. It also does not meet
the Project objective to implement Policy 2.1 of the City’s General Plan Element to revise portions
of public lands, including the “conversion of non-aviation lands at the Municipal Airport including
streetscape improvements to Airport Avenue, sports fields, picnic areas, and an off-leash dog
area.”
In addition, depending on the specific design and land use characteristics, it is unlikely that this
alternative would avoid or reduce the Project’s potentially significant impacts. Significant short-
term construction noise would also be experienced at nearby sensitive receptors. Additionally,
during operation, office and light industrial uses would result in greater trip generation as
compared to the Project and would result in associated significant traffic impacts. Therefore, this
alternative is discarded from further analysis.
Alternate Sites
Section 15126.6(f)(2) of the CEQA Guidelines state that two provisions are necessary for an
adequate alternative site analysis, feasibility and location. The EIR should consider alternate
project locations if a significant impact could be avoided or substantially lessened by moving the
Project to an alternate site. Accordingly, alternate sites were considered for the development of
approximately 12 acres of new park/open space uses with a similar mix of recreational amenities
as those proposed under the Project.
In the case of the Project, the Project site is specifically identified because it is adjacent to the
existing Airport Park and is part of the City’s long-standing objective to develop non-aviation
lands south of the SMO runway with parks and recreational facilities. The Project site is also
available, City-owned, and under the City’s control. Within SMO property, 19 potential sites were
previously considered for the location of the existing Airport Park, but were discarded by the 1997
Non-Aviation Land Use Feasibility Study, primarily due to FAA restrictions, land use
compatibility, jurisdictional zoning conflicts, and safety issues and concerns (City of Santa Monica
Parks and Recreation Master Plan 1997). Although SMO is now planned for closure in 2028, these
concerns remain issues today and until 2028 or beyond. At that time, a major land use planning
effort would be undertaken to determine the appropriate future uses within the SMO property.
However, these lands are not currently available and the uncertain timing if their availability would
5.0 ALTERNATIVES
Airport Park Expansion Project 5-7
Final EIR – January 2018
defer development of a Park for decade or more which would be inconsistent with primary Project
objectives.
The development of the recreational facilities proposed by the Project at an alternate site outside
of SMO property would require a suitably sized site that is controlled by the City or which could
be feasibly acquired. Furthermore, the alternate site must have suitable zoning and would have to
be located in an area that could feasibly accommodate a public park to serve City residents. Santa
Monica is a fully developed urban community with very limited vacant or underdeveloped land.
The City does not own or otherwise control a site outside of SMO property that is suitably sized
(approximately 12 acres) and within proximity of an existing park or recreational facility.
Acquisition of an alternative site outside of the SMO property would require City purchase of an
already developed site and displacement of existing uses. Therefore, suitable sites outside of the
SMO property are unavailable or infeasible for development of a park and this alternative is
discarded from further analysis.
Permanent Ice Rink Alternative
A Permanent Ice Rink Alternative was considered in response to expressed community interest in
developing a permanent ice rink with the other active recreational facilities (e.g., sports fields,
pickleball courts) when expanding Airport Park. Of the 689 responses received during a survey
taken as part of the community design engagement process—which occurred prior to the EIR
process in the summer of 2016—the overwhelming majority of respondents listed “sports fields”
as the activity they would like to see/do at Airport Park, where it scored 802 points when listed in
the top five amenities desired at the park. Subsequent to the community design engagement process
survey, 30 comments were e-mailed directly to the City for consideration during the September
27, 2016 City Council discussion regarding the expansion of Airport Park. Of those 30 e-mails, 20
also supported the development of additional athletic fields, which are proposed in the Project.
However, ten letters were also received indicating support for an ice rink as part of the Project.
Although the City operates a seasonal ice rink in the Downtown for approximately three months
each winter, these responses demonstrate a community interest in a permanent ice rink. The Culver
City Ice Rink, once located approximately 3.5 miles from the Project site closed on February 2,
2014, leaving west Los Angeles area without a permanent ice rink. However, development of a
permanent ice rink on the Project site would conflict with the overwhelming community desire for
new sports fields at Airport Park, which is the Project’s primary objective. Furthermore, the
development of a permanent ice rink at the Project site and outside of the Downtown would likely
result in low levels of visitation due to the site’s less centralized location. In this manner, a
permanent ice rink may be underutilized when compared with the sports fields identified by
5.0 ALTERNATIVES
5-8 Airport Park Expansion Project
Final EIR – January 2018
community feedback and reflected in the high utilization of the existing sports field at Airport
Park.
In addition, a Permanent Ice Rink Alternative would entail substantial construction and operational
activities (e.g., high energy demand, high trip generation during peak traffic hours) that would not
materially reduce, but may increase, environmental impacts. Therefore, the Permanent Ice Rink
Alternative was considered but discarded as an alternative because it would not be consistent with
the Project objective to develop recreational uses that would serve the highest priority needs of the
community. Additionally, this alternative is discarded because there would be no reduction in the
Project’s adverse environmental impacts.
5.5 ALTERNATIVES ANALYSIS
This section discusses alternatives to the Project, including the No Project Alternative in
compliance with CEQA Guidelines Section 15126.6(e). Each of these considers the ability of a
particular alternative to substantially reduce or eliminate the Project’s significant environmental
impacts while still meeting basic Project objectives. Potential impacts of these alternatives are
compared to the thresholds of significance used in Section 3.0 of the EIR, which are posed as
separate questions herein. These alternatives include:
• Alternative 1 – No Project/No Build Alternative;
• Alternative 2 – No Project/Reasonable Foreseeable Development Alternative;
• Alternative 3 – Airport Park Expansion without Fields Alternative;
• Alternative 4 – Reduced Project Alternative (East Paved Surface Area Only); and
• Alternative 5 – Community Recreation Center Alternative.
5.5.1 Alternative 1 – No Project/No Build
Per CEQA Guidelines Section 15126.6(e)(2), the No Project Alternative analysis shall discuss the
existing conditions at the time the Notice of Preparation (NOP) is published (March 8, 2017), as
well as what would be reasonably expected to occur in the foreseeable future if the Project were
not approved, based on current plans and consistent with available infrastructure and community
services. The environmental impacts of the No Project Alternative shall be compared to those of
the Project.
The CEQA Guidelines continue that “in certain instances, the no project alternative means ‘no
build’ wherein the existing environmental setting is maintained. However, where failure to proceed
with the project will not result in preservation of existing environmental conditions, the analysis
5.0 ALTERNATIVES
Airport Park Expansion Project 5-9
Final EIR – January 2018
should identify the practical result of the project's non-approval and not create and analyze a set
of artificial assumptions that would be required to preserve the existing physical environment.”
The No Project/No Build Alternative (Alternative 1) includes a discussion and analysis of the
existing baseline conditions at the time the Notice of Preparation was published. The No
Project/Reasonable Foreseeable Alternative (Alternative 2) includes a discussion and analysis of
what would be reasonably expected to occur in the foreseeable future if the Project were not
approved, and the west/east paved surface areas were redeveloped with non-recreational uses.
For the purposes of the EIR, Alternative 1 assumes that the existing Airport Park and Project site
would remain as-is under existing conditions until SMO ceases operation in 2028, after which the
regulation of land uses on SMO property would be returned to the City and no longer subject to
the existing agreements between the City and the FAA. Under this Alternative, no additional
recreational amenities would be developed on this 12-acre site and no portion of the existing park
would be reconfigured. For the purposes of this analysis, the No Project/No Build Alternative
assumes that existing commercial and aviation-related uses would remain until the closure of SMO
in 2028. Specifically, the west paved surface area would continue to be used for aviation (e.g.,
airplane hangars, tie downs) and commercial uses (e.g., flight school, event staging for the Barker
Hangar) and the east paved surface area would remain as a vacant paved surface area, with public
access for unprogrammed recreational use, including roller-blading and bicycle training for
families. The existing Airport Park would remain in its current condition as an 8.3-acre park with
a dog park, children’s playground, a synthetic turf sports field with lights, a picnic area, a 0.6-mile
walking loop, 118 parking spaces and bike racks.
However, Alternative 1 assumes that following closure of the airport in 2028, the 12-acre west and
east paved surface areas would not be developed for recreation uses. Rather, the aviation uses
within the buildings on the west paved surface area would be vacated and instead, storage and
maintenance uses for the City would reoccupy the buildings. The east paved surface area would
remain vacant, and could potentially be utilized for other civic uses compatible with an open paved
area, such as a farmer’s market on a weekend day.
It should be noted that as part of cessation of airport operations, the SMO property will be subject
to a major land use planning effort to determine the appropriate future uses on the site. However,
at this time and for the purposes of the EIR, it is assumed that no new development would occur
and the existing buildings on the west paved surface area would be re-occupied with storage and
maintenance-related uses for the City under the No Project/No Build Alternative. These land uses
are permitted under the Institutional/Public Lands designation by the LUCE and as such, are
5.0 ALTERNATIVES
5-10 Airport Park Expansion Project
Final EIR – January 2018
considered under Alternative 1. Areas designated as Institutional/Public Lands are intended to
retain their strong variety of government, educational, cultural, and other facilities that meet the
needs of the community..
Environmental Impacts
Retention of the existing buildings on the west and east paved surface areas would not result in
changes to visual character, generate new shadows, or increase lighting levels. The visual character
of the site would remain as it appears today. Continued use of the existing buildings and paved
surface areas would mean that no construction effects would occur. With the aviation-uses on the
west paved surface area being replaced by storage and maintenance uses, it is anticipated that there
would be a decrease in air quality and greenhouse gas emissions. Similarly, noise from vehicle
trips would be decreased as compared to the Project.
Additionally, hazardous materials and geological conditions would remain as in existing
conditions. With regard to land use and planning, Alternative 1 would not create land use
compatibility issues. However, this alternative not be consistent with LUCE goals and policies to
improve recreation and open space within the City. Further, Alternative 1 would not generate
population growth or an increase in demand for public services or utilities.
5.5.2 Alternative 2 – No Project/Reasonable Foreseeable Development (Non-Recreational
Use)
CEQA Section 15126.6 states that “in certain instances, the no project alternative means ‘no build’
wherein the existing environmental setting is maintained. However, where failure to proceed with
the project will not result in preservation of existing environmental conditions, the analysis should
identify the practical result of the project's non-approval and not create and analyze a set of
artificial assumptions that would be required to preserve the existing physical environment.”
As previously discussed, following the closure of SMO by 2028, the SMO property will be subject
to a major land use planning effort to determine the appropriate future uses on the site. Therefore,
it is unlikely that the 12-acre west and east paved surface areas would remain as is (with no new
development). The existing Airport Park would continue to remain in its current configuration.
The Project site is designated Institutional/Public Lands, which permits uses such as public/semi-
public uses (e.g., community recreational, child care, colleges, trade schools), farmers markets,
parking, and transportation, community, and utilities uses as shown in Table 5-1. Based on the
City’s long-standing policies to develop recreational uses on non-aviation land, it is anticipated
5.0 ALTERNATIVES
Airport Park Expansion Project 5-11
Final EIR – January 2018
Table 5-1. Permitted Uses Under Institutional/Public Lands Land Use Designation
Use Classification Permitted Uses
Residential Uses Emergency Shelters, Large Family Day Care, Small Family
Day Care
Public and Semi-Public Uses Adult Day Care, Cemetery, Child Care and Early Education
Facilities, Colleges and Trade Schools, Community
Assembly, Community Gardens, Cultural Facilities, Public
Park and Recreation Facilities, Public Safety Facilities,
Schools, Social Service Centers
Commercial Uses Farmers Markets, Public or Private Parking
Transportation, Communication, and Utilities Uses Citywide Bikeshare Facility, Communication Facilities
(Equipment within Buildings), Major Utilities, and Minor
Utilities
Source: SMMC Table 9.15.020: Land Use Regulations–Public and Semi-Public Districts (City of Santa Monica 2016)
that the west and east paved surface areas would most likely be developed with public park and
recreation facilities. However, the development of additional park and open space uses are not
considered under Alternative 2 - No Project/Reasonable Foreseeable Development (Non-
Recreational Use) since the environmental impacts of developing the Project site with an active
park use are the subject of this EIR. Furthermore, the development of the Project site with passive
open space uses is the subject of Alternative 3 (Airport Park Expansion without Fields) below.
In addition, Alternative 5 (Community Recreation Center Alternative) considers the development
of a community recreation center on the west paved surface area, and so the development of a
community assembly building or social services center is also not considered under the No
Project/Reasonable Foreseeable Development Alternative. Additionally, due to the retention of the
existing Airport Park and proximity of single-family residential neighborhoods to the Project site,
some of the land uses permitted under the Institutional/Public Lands land use designation would
likely be incompatible for development on the Project site, such as emergency shelters,
communications facilities, and major and minor utilities. Therefore, the development of these uses
is also not considered under Alternative 2.
Because of the Project site’s proximity to both the Santa Monica College (SMC) Bundy Campus
and the privately operated cultural and arts uses along Airport Avenue (e.g., Barker Hangar), it is
assumed for the purposes of this alternative that the west and east paved surface areas would be
developed with the following land uses permitted under the Institutional/Public Lands land use
designation: colleges and trade schools and cultural/arts facilities. In this manner, Alternative 2
envisions two types of development occurring on the west and east paved surface areas. This
alternative assumes that following the closure of SMO in 2028, the west paved surface area would
5.0 ALTERNATIVES
5-12 Airport Park Expansion Project
Final EIR – January 2018
be developed with a new educational building for the SMC Bundy Campus and the east paved
surface area would be developed with additional public or privately operated cultural/arts uses.
The west paved surface area provides a logical location for the SMC Bundy Campus to expand its
facilities and provide additional educational uses because it is within convenient walking distance
to the Bundy Campus and located along Big Blue Bus Line 44 (the SMC Intercampus Shuttle
route). For the purposes of Alternative 2 and based on review of existing development at the SMC
Bundy Campus, it is assumed that the educational uses would include approximately 165,000
square feet (sf) of educational floor area in a two-story building with classrooms and outdoor areas
(see Table 5-2). Additionally, development of this alternative would include approximately 1 acre
of landscaping, and approximately 3 acres of surface parking, including installation of additional
bicycles facilities similar to those of the existing SMC Bundy Campus. A two-story building is
envisioned on the site because it is considered to be most compatible with the existing one- and
two-story residential and commercial buildings in the Project vicinity. By assuming that the new
SMC building would be a maximum of two-stories in height and designed with ample landscaping
and adequate parking, the building proposed under this alternative would be compatible with
surrounding land uses, and would not physically divide an existing neighborhood.
Table 5-2. Assumed Development of the West and East Paved Surface Areas Under
Alternative 2 Following Closure of SMO in 2028
Potential Future Land Use Estimated Size
Existing Airport Park
Park area to be retained 8.3 acres
West Paved Surface Area
Two-story campus building 165,000 sf
East Paved Surface Area
Two, one-story buildings for cultural and arts uses (e.g. art studios, event
venues, film/music production, creative design spaces)
100,000 sf
The east paved surface area similarly provides a logical location for development of publicly or
privately operated cultural and arts uses. The southeast portion of SMO property has organically
transitioned into a cultural node for the City, with cultural/arts uses present in the immediate
Project vicinity including the Barker Hanger, Museum of Flying, Santa Monica Arts Studios,
Ruskin Theatre Group, Creative Spaces, individual arts studios, and the monthly Santa Monica
Antiques Mart. LUCE Policy CE3.3 seeks to “Retain and enhance current concentrations of arts
uses at the Pier, Bergamot Station, the Santa Monica Airport, 18th Street Arts Center and the Civic
Center.” Consistent with existing land uses and the LUCE policy to retain and enhance these uses,
5.0 ALTERNATIVES
Airport Park Expansion Project 5-13
Final EIR – January 2018
it is assumed for this alternative that the east paved surface area would be developed as two, one-
story buildings accommodating approximately 100,000 sf of cultural/arts uses, such as a museum,
art galleries, and event venues. These uses would be supported by the development of
approximately one acre of landscaping and art installations, with underground parking, as well as
the installation of additional bicycle storage/racks.
Alternative 2 is conceptual for the purposes of the EIR. The exact layout and structural
configuration of the proposed development is not determined; however, Figure 5-1 provides a
conceptual diagram of what could potentially occur under this alternative.
Unlike the Project, this alternative would result in no new development in the short-term and,
therefore, would result in no environmental impacts until development occurs subsequent to 2028
when SMO ceases operation. Development that would occur in the long-term under Alternative 2
could result in lesser impacts in some environmental resources areas and greater impacts in other
environmental resource areas evaluated in this EIR in relation to the Project. Some potential
impacts, such as traffic and circulation, could be influenced by the other improvements that would
follow the closure of SMO in 2028. For example, potential development of new surface streets to
access the Project site through SMO property may alleviate impacts in some areas while
exacerbating impacts in others. Further, increases in intensity of use would likely occur, with
potentially greater average and peak populations using the site than those occurring at active playfields
during peak sporting events.
Air Quality
Would the project conflict with or obstruct implementation of the applicable air quality plan?
Although this alternative would generate short-term employment opportunities during
construction and long-term employment opportunities during operation, the new educational and
cultural/arts buildings would serve the existing and anticipated future population and would not
directly contribute to population growth in excess of the 2016 Air Quality Management Plan
(AQMP)’s population forecast. In addition, since Alternative 2 would not cause or contribute to
new air quality violations as shown in the tables below, this alternative would not conflict with the
2016 AQMP, and this impact would be less than significant.
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5.0 ALTERNATIVES
Airport Park Expansion Project 5-15
Final EIR – January 2018
Would the project violate any air quality standard or contribute substantially to an existing or
projected air quality violation?
Expansion of the SMC Bundy Campus and development of cultural/arts uses under this alternative
would result in increased air quality impacts, as compared to the Project. Emissions of criteria air
pollutants would occur due to construction and operation of the proposed uses under Alternative 2.
Air quality emissions were estimated for both construction and operation of this alternative using
the California Emissions Estimator Model (CalEEMod) Version 2016.3.1, and compared to the
thresholds of significance for SCAQMD (see Appendix C, Table 5-3, and Table 5-4).
Table 5-3. Maximum Estimated Daily Construction Emissions for Alternative 2
compared to SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds3
Construction Emissions1,2 Exceeds Threshold? 2029 2030
NOx 100 32.35 14.67 No
VOC 75 3.10 57.73 No
PM10 150 22.97 3.53 No
PM2.5 55 4.97 1.07 No
SOx 150 0.11 0.07 No
CO 550 28.29 22.82 No
Notes: Bold text indicates the highest potential daily emission level from onsite and offsite sources over the assumed construction
period (January 2029 – December 2030).
1 Refer to Appendix C for CalEEMod output sheets.
2 Construction emissions were estimated assuming that construction equipment would meet Tier 4 engine standards, based on the
estimated construction start date of 2029.
3 Source: SCAQMD 2015.
Table 5-4. Maximum Estimated Operational Emissions for Alternative 2 compared to
SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds2
Operational Emissions1 Exceeds
Threshold Area Energy Mobile Overall
NOx 55 0.00 1.49 37.90 39.39 No
VOC 55 10.78 0.16 7.09 18.04 No
PM10 150 0.00 0.11 43.53 43.64 No
PM2.5 55 0.00 0.11 11.80 11.91 No
SOx 150 0.00 0.01 0.43 0.44 No
CO 550 0.03 1.25 88.44 89.72 No
1 Refer to Appendix C for CalEEMod output sheets.
2 Source: SCAQMD 2015.
5.0 ALTERNATIVES
5-16 Airport Park Expansion Project
Final EIR – January 2018
Construction Emissions
Construction-related air pollutant emissions were estimated for construction of Alternative 2 using
CalEEMod and compared to the thresholds of significance for SCAQMD (Appendix C).
Development of the west and east paved surface areas with an expansion of the SMC Bundy
Campus and cultural/arts uses would result in similar or incrementally greater short-term
construction-related air quality impacts as the Project. While the construction of buildings would
result in greater use of construction equipment and architectural coatings (e.g., paints) as well as a
substantially longer construction period, it is the excavation and grading phases of construction
which generate the highest emission of construction-related air pollutants. Because Alternative 2
assumes surface parking, the excavation and grading is anticipated to be similar to the Project.
However, the estimated construction emissions for the Project assumed that construction would
occur using equipment meeting Tier 3 Emissions Standards for Off-Road Compression-Ignition
Engines. Tier 3 standards apply to construction equipment that is 2006 or newer. Tier 4 standards,
which are more stringent, apply to construction equipment that is 2012 or newer. By the time the
west and east paved surface areas are developed (earliest 2029), it is likely that all construction
equipment would meet Tier 4 standards, and construction emissions may actually be less than what
occurs under the Project, even though building construction would be greater under Alternative 2.
As mentioned above and as modeled using CalEEMod software, despite the increase in building
and construction activities under Alternative 2 compared to the Project, peak daily construction-
related emissions for criteria air pollutants under this alternative would generally be less than the
Project. This is due to the fact that CalEEMod assumes emissions from construction equipment
become cleaner in future years as engines become progressively more efficient and older
equipment and vehicles are phased out of existing construction equipment fleets. Therefore, since
construction is assumed to begin in 2029 under this alternative, as compared with 2019 under the
Project, CalEEMod used newer and cleaner emissions data for Alternative 2 than for the Project.
As with the Project, this alternative’s construction emissions of carbon monoxide (CO), volatile
organic compounds (VOCs), nitrogen oxides (NOx), particulate matter (PM10 and PM2.5), and
sulfur dioxide (SOx) would be below SCAQMD construction emissions thresholds and impacts
would be less than significant (see Table 5-3 and Table 5-4).
Operational Emissions
As with construction, operational emissions for Alternative 2 may be less than estimated under the
Project even with the development of higher intensity uses because vehicle emissions standards,
fuel economy, and fleet mix will be more energy efficient (e.g., greater percentage of electric
5.0 ALTERNATIVES
Airport Park Expansion Project 5-17
Final EIR – January 2018
vehicles) and building energy conservation standards can be expected to be stricter in 2029 than
current regulations. However, to allow for direct comparison, operational emissions were modeled
using the same operations assumptions (i.e., mobile emissions) used to estimate the Project’s
operational emissions. Operational air pollutant emissions and impacts to regional air quality
would increase under this alternative compared to the Project largely due to the increase in vehicle
trips that would be generated by use of the new campus buildings and cultural/arts facilities.
However, as shown in Table 5-4, operational emissions generated by Alternative 2 (including
vehicle trips, energy use, and landscaping/building maintenance) would be below the SCAQMD
operational regional significance thresholds for CO, NOx, PM10, PM2.5, SOx and VOC; therefore,
operational emission impacts would be less than significant. Further, closure of SMO and the
City’s ability to reuse SMO property after 2028 provides opportunities to implement infrastructure
improvements that reduce vehicle miles traveled and associated emissions. Infrastructure
improvements may include the installation of new north-south transportation connections that
would traverse the SMO property allowing for north-south movement for all modes of
transportation, and may also include additional direct bus routes and bike paths from other portions
of the City. These infrastructural improvements may further reduce emissions from operations of
development of this alternative.
As discussed in Section 3.1, Air Quality, the Project would contribute to cumulative traffic in the
area and would incrementally increase CO levels generated from congested intersections. This
alternative, which would develop proposed college and cultural/arts uses, would result in 388 A.M.
peak hour and 289 P.M. peak hour trips, the addition of which would still not exceed 44,000
vehicles during the peak hour at any intersection. Therefore, CO hotspot impacts would be similar
to the Project, and this impact would be less than significant.
Would the project expose sensitive receptors to substantial pollutant concentrations?
Similar to the Project, this alternative would not generate substantial quantities of toxic air
contaminants (TACs) and would not pose a risk to sensitive receptors in the vicinity or place
sensitive receptors within buffer zones of significant TAC emitters. Since this alternative would
become operational after cessation of operations at SMO, aviation-related TAC emissions from
SMO operations in the vicinity would cease. As with the Project, this alternative’s construction
emissions would be below SCAQMD’s Localized Significant Thresholds (LSTs), as shown in
Table 5-5. Therefore, impacts to sensitive receptors would be less than significant.
5.0 ALTERNATIVES
5-18 Airport Park Expansion Project
Final EIR – January 2018
Table 5-5. Maximum Estimated Daily Construction Emissions for Alternative 2
compared to Localized Significance Thresholds (pounds/day)
Air Pollutant LST Thresholds Onsite Construction Emissions Exceeds
Threshold? 2029 2030
CO 1,531 36.72 17.87 No
NOx 221 29.98 14.23 No
PM10 13 9.53 0.90 No
PM2.5 6 2.89 0.90 No
Notes: Refer to Appendix C for CalEEMod output sheets.
Would the project create objectionable odors affecting a substantial number of people?
This alternative would include academic and cultural/arts land uses and as such, these uses would
not result in objectionable odor impacts, similar to the Project, and this impact would be less than
significant.
Construction Effects
Would construction of the project result in considerable construction-period impacts due to the
scope, or location of construction activities?
The range of construction-related impacts under Alternative 2 would be expected to be greater
than the Project, as the construction of buildings on the west and east paved surface areas would
likely require a longer construction period.
With regard to aesthetics, visual effects associated with construction activities would include
construction fencing, staging areas for grading, and presence of construction equipment. These
impacts would be similar to the Project and impacts would be less than significant.
As shown in Table 5-3, when construction-related air quality emissions are estimated using the
same assumptions as the Project, short-term construction-related emissions would be greater than
under the Project, but would also be less than significant.
Regarding hazards and hazardous materials, the development of the west and east paved surface
areas would continue to have the potential to encounter lead-based paint (LBP), asbestos-containing
materials (ACMs), and identified soil contaminants (e.g., arsenic) during the demolition, excavation,
and grading phases. The potential to encounter these hazardous materials would not be any greater
than under the Project, and the implementation of MMs HAZ-1 and MM HAZ-2 would continue to
be required. These measures require a comprehensive survey for LBP and ACMs prior to the start
of demolition, and appropriate remediation of these materials if discovered. The measures further
5.0 ALTERNATIVES
Airport Park Expansion Project 5-19
Final EIR – January 2018
require a Soils Management Plan to be implemented during excavation and/or grading in areas of
known soil contamination, which includes the screening of materials to confirm any presence of soil
contamination and outlines procedures for the proper handling of contaminated materials if
discovered. With the implementation of identified mitigation measures, construction impacts would
be similar to the Project and reduced to less than significant level.
With regard to construction-related noise, Alternative 2 would develop the west and east paved
surface areas with more intense uses than the Project, requiring a potentially longer construction
schedule. However, this alternative would not likely entail the construction of the acoustic berm
along South Bundy Drive and, as such, noise associated with the construction of this berm for off-
site sensitive receptors would not occur. Therefore, construction activities at the eastern site
perimeter, across from the residences on South Bundy Drive, would likely be reduced when
compared to the Project. In addition, all construction would be required to adhere to Section
4.12.110(d) of the City’s Noise Ordinance. MM NOI-1 would require that the noisiest activities
be limited to between the hours of 10:00 A.M. and 3:00 P.M., consistent with Section 4.12.110(d)
of the City’s Noise Ordinance. Under mitigation measure MM NOI-1, the implementation of noise
attenuation measures may include the use of noise barriers (e.g., sound walls) or noise blankets. In
addition, mitigation measure MM NOI-1 would further reduce noise impacts as it would ensure
that construction haul trucks are routed away from residential streets. Therefore, short-term
construction noise impacts would be similar to the Project and less than significant under City of
Santa Monica thresholds. However, the City of Los Angeles considers any construction activity
that would exceed existing ambient noise levels by 5 dBA or more at a sensitive receptor to result
in a significant noise impact. Although construction noise impacts to the residences east of the
Project site across South Bundy Drive would likely be less than under the Project, they are still
likely to exceed ambient noise levels by more than 5 dBA and even with the implementation of
MM NOI-1, impacts would remain significant and unavoidable.
With regard to construction-related traffic/transportation impacts, the size and scope of
construction for this alternative would be greater than the Project due to development of multiple
one- to two-story buildings for additional campus facilities and new cultural/arts facilities. As
compared to the Project, this alternative would result in a longer construction schedule, a longer
period of temporary congestion from construction work vehicles and heavy truck traffic, and likely
more construction vehicle trips to and from the Project site. Similar to the Project, Alternative 2
would require implementation of MM T-1 to reduce construction-related impacts. MM T-1 would
require the preparation of a Construction Impact Mitigation Plan, which would include provisional
measures to address construction traffic routing and control, vehicular and pedestrian safety,
5.0 ALTERNATIVES
5-20 Airport Park Expansion Project
Final EIR – January 2018
pedestrian/bicycle access and parking, street closures, and construction parking. Therefore,
construction-related traffic impacts would be greater than the Project and would be significant and
unavoidable, even after implementation of mitigation measure MM T-1.
Greenhouse Gas Emissions
Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
Greenhouse gas (GHG) emissions were estimated for both construction and operation of this
alternative using CalEEMod (see Appendix C, Table 5-6, and Table 5-7). Alternative 2 would
generate greater GHG emissions than the Project during both construction and operation due to
the construction of additional buildings and the increase in energy use for building operations and
the significant increase in the total number of daily trips generated by the proposed SMC and
cultural/arts buildings. GHG emissions generated from construction of this alternative are
estimated to be 1,487 metric tons of CO2 equivalent (MT CO2e).
Table 5-6. GHG Emissions from Construction of Alternative 2 (MT/yr)
Construction Phase GHGs (MT CO2e)
Demolition 120
Grading 81
Building Construction 1,191
Paving 82
Architectural Coating 13
Total (Construction) 1,487
Amortized over 30 years 50
Note: All values rounded to the closest whole number.
Source: Annual Emissions Calculations in MT/Year for Alternative 2 - CalEEMod – Appendix C.
Table 5-7. Combined Annual GHG Emissions for Alternative 2 (MT/yr)
Annual Emissions by Category GHGs (MT CO2e)
Area 0
Energy 1,336
Mobile 6,128
Waste 395
Water 226
Total (Operational) 8,085
Construction (amortized) 50
Total (Combined) 8,135
Note: All values rounded to the closest whole number.
Source: Annual Emissions Calculations in MT/Year for Alternative 2 - CalEEMod – Appendix C.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-21
Final EIR – January 2018
As discussed above, operational emissions may be less than estimated under the Project even with
the development of higher intensity uses because vehicle emissions standards and building energy
conservation standards can be expected to be stricter in 2029 than current regulations. Further,
with the closure of SMO and the City’s ability to reuse the SMO property, greenhouse gas
reduction opportunities may arise due to pedestrian/bicycle improvements that could effectively
reduce vehicle trips made to the Project site. However, to provide a conservative analysis,
operational GHG emissions were modeled using current emissions factors. GHG emissions were
estimated for both construction and operation of Alternative 2 using CalEEMod (Appendix C).
As Alternative 2 would ultimately result in more intensive development than the Project, this
alternative would generate greater operational GHG emissions due to the increase in energy use
for building operations and increase in trip generation. Operational GHG emissions under this
alternative are estimated at 8,085 MT CO2e/ year. When the amortized construction GHG
emissions are considered, the combined annual GHG emissions for the construction and operation
of this alternative, which consists of institutional and commercial uses, are estimated to be 8,135
MT CO2e/year, which would exceed SCAQMD’s Option 2 single numerical screening threshold
of 3,000 MT CO2e/year. Given this value exceeds the SCAQMD Tier 3 threshold, Alternative 2
GHG emissions are compared the SCAQMD Tier 4 threshold of 4.8 MT CO2e/year per service
population for project-level analyses. As provided in Table 5-8, it is conservatively assumed that
this alternative would generate a minimum service population of 2,268 persons associated with the
educational uses. With this assumption, Alternative 2 GHG emissions per service population
would be 3.6 MT CO2e/year per service population, which would be less than the SCAQMD Tier
4 threshold. Therefore, although GHG emissions under Alternative 2 would be greater than the
Project, impacts would still be less than significant.
Table 5-8. Alternative 2 Annual GHG Emissions Compared to SCAQMD Tier 4
Threshold
Annual Emissions by Category GHGs (MT CO2e)
Total Emissions (Combined) 8,135
Alternative 2 Service Population1 2,268
GHG Emissions per capita service population 3.6
Note: All values rounded to the closest whole number.
1 Project Service Population has been based on Institute of Traffic Engineers (ITE) Trip Generation Rates from the 8th Edition
ITE Trip Generation Report for the Junior/Community College ITE Code (540). While Alternative 2 would involve the
construction of 100,00 sf of cultural and art uses, this analysis conservatively assumes these uses would have a service population
of 0.
5.0 ALTERNATIVES
5-22 Airport Park Expansion Project
Final EIR – January 2018
Would the project be inconsistent with any applicable plan, policy, or regulation of an agency that
has been adopted for the purpose of reducing GHG emissions?
Although Alternative 2 would result in education and cultural/arts uses rather than the Project’s
proposed recreational uses, this alternative would be consistent with the City’s plans and policies
to reduce GHG reductions. Consistent with SCAG’s RTP/SCS alignment of transportation, land
use, and housing strategies, the Project Site is an infill location and would provide
recreational/open space uses in walking distance to existing residential and commercial uses,
which would result in reduced VMT.
The development of new educational uses and cultural/arts uses under Alternative 2 would help
fulfill LUCE policies to create complete neighborhoods. Furthermore, it is anticipated that the new
buildings would be designed in accordance with sustainability and green building standards
established by the City and the State. Therefore, similar to the Project, this alternative would be
consistent with the City’s plans, regulations, and policies to reduce GHG reductions. Impacts
would be similar to the Project and less than significant.
Hazards and Hazardous Materials
Would the project create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials?
As with the recreational amenities proposed under the Project, the educational, cultural, and arts
uses proposed under Alternative 2 would require the use of commercially available cleaners,
fertilizers, pesticides, and herbicides. While the use of some hazardous materials would be less
(e.g., fertilizers, herbicides) and others would be greater (e.g., cleaning products), all hazardous
materials would be handled, stored, and transported in accordance with applicable federal, state,
and regulations, as well as manufacturers’ recommendations, impacts would be similar to the
Project and less than significant.
Would the project 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?
As discussed above, Alternative 2 would require demolition of existing structures and site
preparation activities, including excavation, similar to the Project. Potential hazardous materials
impacts could occur due to risks of exposure to or release of hazardous materials, including
potential LBPs and ACMs that could be encountered during demolition of the existing buildings,
5.0 ALTERNATIVES
Airport Park Expansion Project 5-23
Final EIR – January 2018
in addition to potential subsurface soil contamination that could be encountered during site grading
activities. Overall, impacts with regard to hazardous materials under this alternative would be
similar to those described under the Project. Alternative 2 would be required to implement
mitigation measures MM HAZ-1 and MM HAZ-2 to mitigate any presence and use of hazardous
materials in a similar manner as the Project. With implementation of mitigation measures, impacts
related to the accidental release of hazardous materials into the environment would be less than
significant.
For a project located within an airport land use plan or, where such a plan has not been adopted,
within 2 miles of a public airport or public use airport, would the project result in a safety hazard
for people residing or working in the Project site?
Following the closure of SMO in 2028, no portion of the Project site would be located within an
airport influence area (AIA) and risk of airport safety hazards for students, visitors, and employees
at the Project site would be eliminated. The closest airport to the Project site would be Los Angeles
International Airport (LAX), located approximately 4.5 miles southwest of the Project site.
Therefore, by the time the proposed uses are occupied, there would be no impact with regard to
airport hazards. Until such time that operations cease at SMO, the potential risk of airport hazards
would remain the same as it is under existing conditions. Because no portion of the existing Airport
Park and Project site is located within a designated runway protection zone (RPZ) and the number
of employees and visitors to the Project site would not increase over existing conditions, impacts
would be less than under the Project and less than significant.
Land Use and Planning
Would the project conflict with any applicable land use plan, policy, or regulation of an agency
with jurisdiction over the project (including, but not limited to the general plan, specific plan, local
coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an
environmental effect?
Regarding land use and planning, Alternative 2 would not result in development on the Project site
until the City attains the ability to reuse SMO property following closure of the airport in 2028.
The educational and cultural/arts uses proposed under Alternative 2 would become part of a
comprehensive land use planning and zoning effort for the entire SMO property. Future land use
planning would likely either be accomplished though the preparation of a Specific Plan for the
SMO property, or through the City’s next revision to the General Plan LUCE. In addition to
establishing land use designations for the entire SMO property, the City would zone the SMO
property in accordance to the future Specific Plan and/or next updated LUCE. Because the
5.0 ALTERNATIVES
5-24 Airport Park Expansion Project
Final EIR – January 2018
proposed educational and cultural/arts buildings under Alternative 2 would be included in the
comprehensive planning effort for the SMO property, there would be an opportunity to ensure that
the design of the proposed buildings and surrounding uses would be compatible with existing and
planned uses, as well as with any suitability objectives established in the land use planning efforts.
Any future comprehensive land use planning or zoning effort would be subject to environmental
review under CEQA to address environmental impacts associated with land use and the compatibility
with adjacent uses. That said, the development of recreational amenities under the Project is being
proposed to fulfill the City’s long-standing objective established as early as the 1984 Settlement
Agreement to develop recreational uses on non-aviation lands south of the runway. As a result, both
the Project and Alternative 2 would be consistent with land use plans for the Project site, and impacts
would be similar and less than significant.
The proposed educational and cultural/arts uses of this alternative would be consistent with
surrounding land uses and the existing land use patterns in the vicinity. SMO forms a notable
barrier to north-south circulation through the City with physically separated land uses on either
side of the airport. As such, the existing transportation network has been designed to
circumnavigate SMO. As this alternative would not involve changes to this land use patter, this
alternative would not exacerbate any physical barrier caused by SMO. Therefore, similar to the
Project, this alternative would not physically divide an established community and further analysis
of this issue is not required. Further, as part of the comprehensive planning of SMO property, the
new buildings under this alternative may ultimately be designed and oriented in a manner to help re-
establish north-south multi-modal connections through the existing SMO property.
Similar to the Project, the proposed buildings under Alternative 2 would be designed to be
consistent with the overall LUCE vision to incorporate pedestrian-scale development and
encourage local-serving uses. By expanding the SMC Bundy Campus on the north side of Airport
Avenue, Alternative 2 would place the SMC Bundy Campus facilities within close walking
distance of each other and along the Big Blue Bus Line 44 (SMC Connector Shuttle). In
combination with the Airport Avenue Improvement Project, development of this alternative would
contribute to implementing LUCE goals to enhance pedestrian-oriented spaces, arts and amenities,
and pedestrian-bicycle networks within the City. However, Alternative 2 would not be consistent
with LUCE goals and policies to improve recreation and open space within the City. In relation to
the goals and policies of the current LUCE, the development of cultural/arts uses on the east paved
surface area, within walking distance of the similar cultural/arts uses currently located in the
Project vicinity along Airport Avenue, would be consistent with LUCE Policy CE3.3, which seeks
to “Retain and enhance current concentrations of arts uses at the Pier, Bergamot Station, the Santa
5.0 ALTERNATIVES
Airport Park Expansion Project 5-25
Final EIR – January 2018
Monica Airport, 18th Street Arts Center and the Civic Center.” Therefore, similar to the Project,
impacts related to consistency with applicable land use plans, policies, and regulations would be
less than significant.
Noise
Would the project result in exposure of persons to or generation of noise levels in excess of
standards established in the local general plan or noise ordinance, or applicable standards of
other agencies?
Would the proposed project would result in a substantial temporary or periodic increase in
ambient noise levels in the project vicinity above levels existing without the project?
Would the project result in a substantial permanent increase in ambient noise levels in the project
vicinity above existing levels without the project?
Construction Noise
As discussed above, Alternative 2 would develop the west and east paved surface areas with more
intense land uses than the Project, potentially requiring a longer construction schedule. However,
this alternative would not require the construction of the acoustic berm, and therefore, construction
activities at the eastern site perimeter across from the residences on South Bundy Drive would
likely be reduced when compared to the Project. Development under Alternative 2 would result in
a longer duration and extent of construction activities compared to the Project. With the prolonged
construction schedule anticipated under this alternative, temporary noise levels would be greater
than those described under the Project. However, similar to the Project, all construction would be
required to adhere to Section 4.12.110(d) of the City’s Noise Ordinance. MM NOI-1 would require
that the noisiest activities be limited to between the hours of 10:00 A.M. and 3:00 P.M., consistent
with Section 4.12.110(d) of the City’s Noise Ordinance. Implementation of noise attenuation
measures for MM NOI-1 may include the use of noise barriers (e.g., sound walls) or noise blankets.
Additionally, MM NOI-1 would further reduce these construction-related noise impacts as it would
ensure that haul trucks associated with construction activities are routed away from residential
streets. Therefore, short-term construction noise impacts would be similar to the Project and less
than significant under City of Santa Monica thresholds. However, the City of Los Angeles
considers any construction activity that would exceed existing ambient noise levels by 5 dBA or
more at a sensitive receptor to result in a significant noise impact. Although construction noise at
the residences east of the Project site across South Bundy Drive would likely be less than under
5.0 ALTERNATIVES
5-26 Airport Park Expansion Project
Final EIR – January 2018
the Project, they are still likely to exceed ambient noise levels by more than 5 dBA. Therefore,
even with the implementation of MM NOI-1, impacts would remain significant and unavoidable.
Operational Noise
Under Alternative 2, additional operational noise may be generated as a result of an increase in
trip generation when compared to the Project. Noise levels that would be generated by a 1,160
percent increase in daily trip generation would result in a commensurate addition to the noise level
increases generated by the Project. Ambient roadway noise increases from Alternative 2 trip
generation would be similarly commensurate (e.g., more than 1 dB). Therefore, noise impacts on
existing sensitive receptors from vehicle trips generated by this alternative would be slightly
greater than the Project, but would also be less than significant.
Stationary noise sources may be decreased as compared to the Project due to the development of
buildings that would contain operational noise indoors. Although proposed development under
this alternative would result in a higher intensity of uses, the educational and cultural/arts uses
would be limited to indoors, which would generate less noise on surrounding sensitive receptors
than the Project’s noise levels from the outdoor recreational amenities (i.e., sports fields).
Development of indoor uses would eliminate the crowd cheering noises generated at the Project’s
two proposed sports fields. However, the Project locates the proposed parking lot on the western
portion of the Project site, while Alternative 2 would also be located on the east paved surface
area, in closer proximity to the residences across South Bundy Drive from the Project site.
However, it is not anticipated that parking lot noise would exceed ambient noise levels generated
by traffic on South Bundy Drive. All new stationary noise sources, such as heating, ventilation,
and air condition (HVAC) systems would be located, installed, and shielded in accordance with
SMMC requirements. Operational noise impacts on existing sensitive receptors from the Project
site would be reduced as compared to the Project, and would be less than significant.
Would the project result in exposure of persons to or generation of excessive ground-borne
vibration or ground-borne noise levels?
Construction of Alternative 2 would generate ground-borne vibration from various types of
construction equipment such as drillers, loaders, jack hammers, and bulldozers. Periods of high
vibration levels would occur primarily during demolition, excavation, and construction of the
sound berm and site foundation. However, vibration levels at nearby sensitive receptors would be
well below the threshold of 0.1 in/sec at all adjacent uses. Therefore, similar to the Project, ground-
borne vibration impacts would be less than significant.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-27
Final EIR – January 2018
For a project located within an airport land use plan or, where such a plan has not been adopted
within two miles of a public airport or public use airport, would the project expose people residing
or working in the project area to excessive noise levels?
Because development of Alternative 2 would occur following the closure of SMO, no land uses
would be placed within a noise contour for an operational airport. Alternative 2 would not increase
the number of visitors to the Project site until after the closure of SMO. Therefore, impacts
associated with exposing people to airport noise would be less than under the Project and less than
significant.
Transportation and Traffic
Would the project conflict with an applicable plan, ordinance or policy establishing measures of
effectiveness for the performance of the circulation system, taking into account all modes of
transportation including mass transit and non-motorized travel and relevant components of the
circulation system, including but not limited to intersections, streets, highways and freeways?
Would the project result in a decrease in LOS of affected intersections according to established
thresholds?
Would the project increase traffic demand on the CMP facility by 2 percent (V/C greater than
0.02) causing it to operate at LOS F (V/C > 1.00) of if the facility is already at LOS F, would the
project traffic cause an incremental change in the V/C ratio of 0.02 or greater?
Compared to the Project, this alternative would result in a longer construction schedule, a longer
period of temporary congestion from construction work vehicles and heavy truck traffic, and likely
more construction vehicle trips to and from the Project site. This alternative would generate short-
term construction related traffic that would be greater than under the Project. As the scope and
extent of construction would be increased under this alternative, the duration of construction traffic
trips would also be increased. Similar to the Project, Alternative 2 would require implementation
of MM T-1 to reduce construction-related impacts. MM T-1 would require the preparation of a
Construction Impact Mitigation Plan, which would include provisional measures to address
construction traffic routing and control, vehicular and pedestrian safety, pedestrian/bicycle access
and parking, street closures, and construction parking. Therefore, construction-related traffic
impacts would be greater than the Project due to the greater duration of construction, but would
continue to be significant and unavoidable after implementation of mitigation measure MM T-1.
In terms of operational traffic impacts, under Alternative 2, there would be no new development
occurring on the Project site until SMO ceases operation in 2028. Therefore, there would be no
5.0 ALTERNATIVES
5-28 Airport Park Expansion Project
Final EIR – January 2018
significant impacts to traffic and transportation through the horizon year (2025), as there would be
no change in trips relative to existing conditions on the Project site.
However, based on the number of additional trips that could be generated by the new educational
uses and cultural/arts uses, additional intersection impacts would likely occur under this
alternative. Development of higher intensity uses on the Project site would generate additional
vehicle trips when compared to the Project, and as such, traffic impacts would be greater. The
Transportation Impact Analysis prepared for this EIR found that based on trip generation rates
specific to the SMC Bundy Campus, the additional campus building use would be estimated to
generate 3,846 daily trips, including 388 trips in the A.M. peak hour (326 inbound and 62 outbound)
and 289 trips in the P.M. peak hour (133 inbound and 156 outbound).1 The specific mix of uses
and programming to be developed within the cultural/arts space would be estimated to generate
2,792 daily trips, including 221 trips in the A.M. peak hour (197 inbound and 24 outbound) and
285 trips in the P.M. peak hour (88 inbound and 197 outbound). Based on these assumed uses,
vehicle generation of Alternative 2 is estimated to be estimated to be greater than the Project. The
trip generation estimates provided are intended only to provide a frame of reference, given that
this alternative could not begin development sooner than 2029. However, this substantial increase
in vehicle trip generation would likely lead to greater intersection and street segment impacts and
vehicle miles traveled. Intersections anticipated to operate poorly under future conditions,
assuming no changes to the street network as a result of the airport closure, could potentially be
impacted under Alternative 2, such as Walgrove & Rose, Centinela & Ocean Park, Bundy & Ocean
Park, Bundy & National, Centinela & Airport, and Centinela & Palms. However, as noted above,
forecasting specific impacts would be speculative due to potential changes in the roadway network
and bike, transit operations, and the potential changes in the mix and intensity of land uses
surrounding the Project site. For these reasons, it is also not possible to identify mitigation
measures that may or may not be available to reduce impacts at intersections or street segments
due to physical constraints. Therefore, operational impacts would potentially be significant and
unavoidable.
1 Long-term trip generation estimates based on a potential development scenario that includes 165,000 square feet of community
college use can be estimated using trip generation rates specific to Santa Monica College. The rates, drawn from the Draft EIR
for the SMC Career and Educational Facilities Master Plan (2010) Update (Christopher A. Joseph & Associates, April 21,
2010), are as follows:
• Daily Trip Rate: 23.31 trips/1,000 GSF of building area; 50% inbound/50% outbound
• A.M. Peak Hour Trip Rate: 2.35 trips/1,000 GSF of building area: 84% inbound/16% outbound
• P.M. Peak Hour Trip Rate: 1.75 trips/1,000 GSF of building area: 46% inbound/54% outbound
5.0 ALTERNATIVES
Airport Park Expansion Project 5-29
Final EIR – January 2018
5.5.3 Alternative 3 – Airport Park Expansion without Fields
Similar to the Project, Alternative 3 (Airport Park Expansion without Fields Alternative) would
expand the existing Airport Park by developing 12 acres of new park facilities and recreational
amenities on non-aviation lands adjacent to the existing Airport Park. However, the 12 acres of
new park area would be developed with more passive recreational amenities rather than the active
recreational amenities proposed under the Project. Specifically, this alternative would not include
the Project’s two Federation International de Football Association (FIFA) regulation-sized sports
fields, pickleball courts, concrete bleachers, and park fitness equipment. Rather, this alternative
would instead be developed with passive
recreational amenities, such as walking
paths and open space.
During the initial community engagement
process for the Airport Park expansion
design, —which occurred prior to the
EIR process in the summer of 2016—
there was interest expressed in developing
the expanded park with more passive
recreational uses. As described in the
discussion of the Permanent Ice Rink
alternative (Section 5.4, Alternatives
Considered but Discarded) above, the
overwhelming majority of respondents
listed “sports fields” as the activity they
would like to see/do at Airport Park.
However, of the top ten listed uses, passive uses such as gardens/landscape, wildlife habitat,
promenades, community gardens, and social areas were also listed as features that respondents would
like to see at the expanded Airport Park. In response to this feedback, Alternative 3 would emphasize
the open space aspects of Airport Park that some community members have expressed an interest in.
Specifically, this alternative would provide park features such as a second natural turf multi-purpose
area, shaded seating areas with tables and chess area, winding walking paths, a water feature, unique
architectural and cultural focal points (e.g., aviation-themed art installation), an additional 60–
80 community garden plots, and an area that would planted with natural habitat area and traversed by
winding walking paths (see Table 5-9).
Tongva Park is an example Santa Monica park that features
passive recreational amenities such as natural turf multi-purpose
areas, winding pathways through natural habitat, water features,
and unique focal cultural/art installations.
5.0 ALTERNATIVES
5-30 Airport Park Expansion Project
Final EIR – January 2018
Table 5-9. Alternative 3 Passive Recreational Uses to Replace Project Features
Alternate Land Use Area Increase over Project
Multi-Purpose Natural Turf Area 2.21 acres +0.92 acre
Community Gardens 120-160 plots / 0.5 acre +60-80 plots/+0.25 acre
Natural Habitat 1 acre +1 acre
Shaded Seating Areas 0.5 acre +0.5 acre
Water Feature 0.25 acre +0.25 acre
Unique Architectural and Cultural
Focal Point
0.25 acre +0.25 acre
The park layout of this alternative would be similar to that of the Project; however, proposed sports
fields and densely clustered amenities proposed under the Project would be replaced with turf,
gardens, and habitat areas, walking paths, or seating areas that would provide for passive
recreational use. Two new restrooms would continue to be provided, as would the acoustical berm
to attenuate park noise at adjacent residences and from aircraft noise on park visitors. The
acoustical berm would continue to provide an airport overlook and a 24-foot-wide path that forms
the Main Bundy Entry to the park, creating a defined park entrance complete with monument signs.
Alternative 3 is conceptual for the purposes of the EIR. The exact layout and structural
configuration of the proposed development is not determined; however, Figure 5-2 provides a
conceptual diagram of what could potentially occur under this alternative.
As compared to the Project, this alternative would result in similar or reduced impacts in relation
to the anticipated intensity of use and density of proposed amenities. With low intensity recreational
uses and without development of new sports fields, peak visitation to the park would likely be reduced
as compared to the Project’s active sports fields during peak sporting events such as tournaments.
By providing a mix of passive recreational opportunities, Alternative 3 would continue to enhance
pedestrian-oriented spaces, the overall amount of green space in the City, and pedestrian-bicycle
networks within the City.
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5.0 ALTERNATIVES
5-32 Airport Park Expansion Project
Final EIR – January 2018
Air Quality
Would the project conflict with or obstruct implementation of the applicable air quality plan?
Similar to the Project, this alternative would not conflict with the 2016 AQMP as this alternative
would not contribute to population growth in excess of the AQMP’s population forecast, and
would not cause or contribute to new air quality violations as shown in the tables below. Therefore,
this impact would be less than significant.
Would the project violate any air quality standard or contribute substantially to an existing or
projected air quality violation?
Air quality emissions were estimated for both construction and operation of this alternative using
CalEEMod and compared to the SCAQMD thresholds of significance (Appendix C, see also
Table 5-10 and Table 5-11).
Table 5-10. Maximum Estimated Daily Construction Emissions for Alternative 3
compared to SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds3
Construction Emissions1,2 Exceeds Threshold? 2018 2019
NOx 100 63.84 11.35 No
VOC 75 3.68 6.70 No
PM10 150 11.46 0.78 No
PM2.5 55 4.21 0.66 No
SOx 150 0.14 0.02 No
CO 550 74.33 17.97 No
Notes: Bold text indicates the highest potential daily emission level from onsite and offsite sources over the assumed construction
period (early 2018 – early 2019).
1 Refer to Appendix C for CalEEMod output sheets.
2 While Section 2.0, Project Description, describes a 2019-2020 construction schedule, the air pollutant modeling prepared using
CalEEMod software was run assuming a reasonable worst-case scenario for construction emissions in the event Project
construction should begin sooner than initially expected in 2018.
3 Source: SCAQMD 2015.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-33
Final EIR – January 2018
Table 5-11. Maximum Estimated Operational Emissions for Alternative 3 compared to
SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds2
Operational Emissions1 Exceeds
Threshold Area Energy Mobile Overall
NOx 55 0.00 0.00 2.60 2.60 No
VOC 55 3.69 0.00 0.52 4.22 No
PM10 150 0.00 0.00 1.69 1.69 No
PM2.5 55 0.00 0.00 0.47 0.47 No
SOx 150 0.00 0.00 0.02 0.02 No
CO 550 0.00 0.00 6.46 6.46 No
1 Refer to Appendix C for CalEEMod output sheets.
2 Source: SCAQMD 2015.
As discussed in Section 3.1, Air Quality, the Project would contribute to cumulative traffic in the
Project vicinity and would incrementally increase CO levels in the vicinity of local intersections.
However, none of the intersections in the study area would approach the volume of vehicles
required to result in a CO hotspot and Project impacts would be less than significant. However, as
trip generation would be reduced under this alternative, the increase of CO emissions associated
with this alternative would be less than under the Project and would also not cause an exceedance
of state or federal CO standards. Therefore, CO hotspot impacts would be less than significant.
Construction Emissions
Under Alternative 3, the footprint of new proposed park and recreational amenities would be
similar in size to the Project (i.e., 12 acres of new development). The substitution of two sports
fields and three pickleball courts for passive recreational amenities would have no appreciable
change on the construction schedule, excavation and grading, and type of construction required to
expand the park. Thus, the duration and extent of construction activities, such as demolition,
grading, park construction, and paving would be similar to the Project. As a result, associated
construction emissions would be similar. The majority of construction-related emissions would
occur during the demolition, grading, and construction phases for the park. As the scope of these
activities would be similar to the Project, this alternative’s construction emissions of CO, VOC,
NOx, PM10, PM2.5 and SOx would also be below SCAQMD construction emissions thresholds and
impacts would be less than significant (see Table 5-10).
Operational Emissions
As shown in Table 5-11, operational emissions generated by Alternative 3 (including vehicle trips
and the use of landscaping maintenance equipment) would be below the SCAQMD operational
5.0 ALTERNATIVES
5-34 Airport Park Expansion Project
Final EIR – January 2018
regional significance thresholds for all air pollutants. Due to the reduced intensity of recreational
uses and elimination of the two sports fields under this alternative, the number of daily vehicle
trips to the Project site would be reduced as compared to the Project. Specifically, Alternative 3
would generate approximately 53 percent fewer daily net new trips than the Project, and associated
traffic-generated air pollutants (mobile source) would be commensurately reduced (see
Table 5-11). Therefore, this alternative’s operational emissions would be less than significant.
Would the project expose sensitive receptors to substantial pollutant concentrations?
Similar to the Project, this alternative would expand Airport Park by approximately 12 acres. Park
uses would not generate substantial amounts of TACs and would not pose a risk to sensitive receptors
in the Project vicinity. Similarly, the Project site is well outside the recommended buffer zone of
potential TAC emitters as defined by SCAQMD and California ARB. Because Alternative 3 would
develop 12 acres of additional parkland, this alternative would also not generate substantial TACs
and would not place sensitive receptors within buffer zones of potential TAC emitters. As concluded
in the HRA, SMO would not result in a significant acute or non-acute carcinogenic health risk effect
on visitors or employees at the Project site (see Appendix B). Upon cessation of operations at SMO,
the emission of aviation-related TACs from SMO operations in the Project vicinity would cease.
This alternative’s construction emissions would be below SCAQMD’s LSTs, as shown in
Table 5-12, and impacts to sensitive receptors would be less than significant.
Table 5-12. Maximum Estimated Daily Construction Emissions for Alternative 3
compared to Localized Significance Thresholds (pounds/day)
Air Pollutant LST Thresholds Construction Emissions1 Exceeds
Threshold? 2018 2019
CO 1,531 72.81 14.30 No
NOx 221 60.93 11.30 No
PM10 13 11.22 0.61 No
PM2.5 6 4.10 0.61 No
Notes: Refer to Appendix C for CalEEMod output sheets.
1 While Section 2.0, Project Description, describes a 2019-2020 construction schedule, the air pollutant modeling prepared using
CalEEMod software was run assuming a reasonable worst-case scenario for construction emissions in the event Project
construction should begin sooner than initially expected.
Would the project create objectionable odors affecting a substantial number of people?
This alternative would include similar recreational uses as the Project and, as such, would not
result in objectionable odor impacts. Therefore, impacts related to odors would be less than
significant.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-35
Final EIR – January 2018
Construction Effects
Would construction of the project result in considerable construction-period impacts due to the
scope, or location of construction activities?
The construction of recreational park and open space uses on a similar footprint as the Project
would result in similar range of construction-related impacts under Alternative 3, including those
related to aesthetics, air quality, hazards and hazardous materials, noise, and transportation and
traffic.
With regard to air quality, the similar size of recreational facilities proposed under this alternative
would require a similar construction schedule and fleet of construction equipment to develop the
recreational amenities. As shown in Table 5-12, when construction-related air quality emissions
are estimated using the same assumptions as the Project, short-term construction-related regional
and localized emissions of criteria pollutants would be similar to those generated during
construction of the Project, and would be less than significant.
With regard to hazards and hazardous materials, the development of the west and east paved
surface areas would have the potential to encounter LBP, ACMs, and soil contaminants during the
demolition, excavation, and grading phases. The potential to encounter these hazardous materials
would be similar to the Project, and the implementation of MMs HAZ-1 and MM HAZ-2 would
also be required. These measures require a comprehensive survey for LBP and ACMs prior to the
start of demolition, and appropriate remediation of these materials if discovered. The measures
further require a Soils Management Plan to be implemented during excavation and/or grading in
areas of known soil contamination, which includes the screening of materials to confirm any
presence of soil contamination and outlines procedures for the proper handling of contaminated
materials if discovered. With the implementation of identified mitigation measures, construction
impacts would be reduced to less than significant levels, similar to the Project.
With regard to construction-related noise, Alternative 3 would develop new recreational uses on a
similar footprint as the Project and would require a construction schedule and fleet of construction
equipment that would be similar to the Project. As with the Project, all construction would be
required to adhere to Section 4.12.110(d) of the City’s Noise Ordinance. MM NOI-1 would require
that the noisiest activities be limited to between the hours of 10:00 A.M. and 3:00 P.M., consistent
with Section 4.12.110(d) of the City’s Noise Ordinance. Under MM NOI-1, the implementation
of noise attenuation measures may include the use of noise barriers (e.g., sound walls) or noise
blankets. In addition, MM NOI-1 would further reduce noise impacts as it would ensure that haul
trucks associated with construction activities are routed away from residential streets. Therefore,
5.0 ALTERNATIVES
5-36 Airport Park Expansion Project
Final EIR – January 2018
short-term construction noise impacts would be similar to the Project and less than significant
under City of Santa Monica thresholds. However, the City of Los Angeles considers any
construction activity that would exceed existing ambient noise levels by 5 dBA or more at a
sensitive receptor to result in a significant noise impact. Because the development of the Project
site is similar to the Project, including the installation of an acoustic berm on the eastern site
perimeter, construction noise levels at the residences across South Bundy Drive are expected to be
similar to the Project and would exceed ambient noise levels by more than 5 dBA. Even with the
implementation of MM NOI-1, impacts would be significant and unavoidable when compared to
City of Los Angeles thresholds.
Because this alternative would require a similar construction schedule, fleet of construction
equipment, and export of soil materials from the Project site, construction impacts would be similar
to the Project. As with the Project, the demolition and relocation of Donald Douglas Loop South
under Alternative 3 would occur in a manner to provide continued access to airport uses north of
Airport Park. The construction haul route would be approved by the City to ensure that residential
streets would be avoided. Further, as with the Project, Alternative 3 would require implementation
of MM T-1, requiring the preparation of a Construction Impact Mitigation Plan. Therefore, the
construction impacts of Alternative 3 would be similar to the Project and reduced to less than
significant with the implementation of identified mitigation measures.
Greenhouse Gas Emissions
Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
GHG emissions were estimated for both construction and operation of this alternative using
CalEEMod (see Appendix C, Table 5-13, and Table 5-14). As the duration and extent of
construction activities under Alternative 3 would be similar to the Project, GHG emissions from
construction would be similar when compared to the Project and are estimated to be 1,475 MT
CO2e. GHG emissions from trip generation and energy use under Alternative 3 would be less than
under the Project.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-37
Final EIR – January 2018
Table 5-13. GHG Emissions from Construction of Alternative 3 (MT/yr)
Construction Phase GHGs (MT CO2e)
Demolition 113
Grading 134
Park Construction 1,199
Paving 27
Architectural Coating 2
Total (Construction) 1,475
Amortized over 30 years 49
Note: All values rounded to the closest whole number.
Source: Annual Emissions Calculations in MT/Year for Alternative 3 - CalEEMod – Appendix C.
Table 5-14. Combined Annual GHG Emissions for Alternative 3 (MT/yr)
Annual Emissions by Category GHGs (MT CO2e)
Area 0
Energy 51
Mobile 350
Waste 0
Water 40
Total (Operational) 441
Construction (amortized) 49
Total (Combined) 490
Note: All values rounded to the closest whole number.
Source: Annual Emissions Calculations in MT/Year for Alternative 3 - CalEEMod – Appendix C.
With regard to operational impacts of Alternative 3, the elimination of the two sports fields would
incrementally reduce daily, A.M. peak hour, and P.M. peak hour vehicle trips generated at the
Project site when compared to the Project. Therefore, although the park’s recreational uses
themselves would result in a similar level of construction-related GHG emissions, the reduction
of vehicle trip generation under this alternative would result in less overall operational GHG
emissions when compared to the Project. Operational GHG emissions under this alternative are
estimated at 441 MT CO2e/year. When the Project’s amortized construction GHG emissions are
considered, the combined annual GHG emissions for the construction and operation of the Project
are estimated to be 490 MT CO2e/year, which is well below the SCAQMD Tier 3 screening
threshold of 3,000 MT CO2e. Therefore, GHG emissions under Alternative 3 would be less than
the Project, and impacts would be less than significant.
5.0 ALTERNATIVES
5-38 Airport Park Expansion Project
Final EIR – January 2018
Would the project be inconsistent with any applicable plan, policy, or regulation of an agency that
has been adopted for the purpose of reducing GHG emissions?
Alternative 3 would be consistent with the City’s plans and policies to reduce GHG reductions as
discussed in Impact GHG-2. Consistent with SCAG’s RTP/SCS alignment of transportation, land
use, and housing strategies, the Project Site is an infill location and would provide
recreational/open space uses in walking distance to existing residential and commercial uses,
which would result in reduced VMT.
Expansion of Airport Park under Alternative 3 would help fulfill LUCE Goal LU4, which calls for
the creation of complete sustainable neighborhoods that exemplify sustainable living practices to
reduce GHGs by providing uses such as open spaces and green connections that meet the daily
needs of residents and reduce vehicle trips and GHG emissions.
Similar to the Project, the new park space would also be designed to comply with green design
requirements, which would help fulfill LUCE Goal LU16, related to ensuring that new projects
are sustainable and environmentally sound. Therefore, this alternative would be consistent with
the City’s plans, regulations, and policies to reduce GHG reductions. Impacts would be similar to
the Project and less than significant.
Hazards and Hazardous Materials
Would the project create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials?
Similar to the Project, operation of Alternative 3 would entail routine cleaning and maintenance
activities using commercially available hazardous materials, such as cleaning fluids, detergents,
and pesticides/herbicides, etc. However, use of such materials would likely be in limited (i.e., not
commercially reportable) quantities and would be handled in compliance with federal, state, and
local regulations pertaining to their transport, use, and disposal, such as those established by the
U.S. EPA, CalEPA, OSHA, Cal OSHA, and the DTSC. Implementation of standard good
housekeeping measures, BMPs, site maintenance and security precautions, as well as compliance
with standards and regulations would ensure that the potential impacts related to the routine
transport, use, or disposal of hazardous materials would be similar to the Project and less than
significant.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-39
Final EIR – January 2018
Would the project 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?
Would the project would emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within one-quarter mile of an existing or proposed school?
As discussed above, Alternative 3 would require the demolition of existing structures and site
preparation activities, including excavation, similar to the Project. Accordingly, this alternative
would result in similar risks of exposure to hazardous materials, including potential LBP and
ACMs that could be released during demolition of the existing buildings and potential subsurface
soil contamination that could be encountered during site grading activities. Impacts with regard to
hazardous materials under this alternative would be similar to those described under the Project.
Alternative 3 would be required to implement mitigation measures MM HAZ-1 and MM HAZ-2
to mitigate any presence and use of hazardous materials. With implementation of mitigation
measures, impacts related to the accidental release of hazardous materials into the environment
would be less than significant.
For a project located within an airport land use plan or, where such a plan has not been adopted,
within 2 miles of a public airport or public use airport, would the project result in a safety hazard
for people residing or working in the Project site?
Similar to the Project, development under this alternative would be located within the SMO AIA.
However, no portion of the existing Airport Park and Project site is located within a designated
runway protection zone (RPZ). Similar to the Project, Alternative 3 would not place structures, or
recreational amenities within this RPZ. This alternative is also subject to policies regarding airport
safety and development restrictions in RPZs. Alternative 3 would not increase the number of
structures within the flight path or RPZs. In addition, this alternative would require a FAA Part 77
Clearance Permit to be submitted and approved by the FAA to ensure airport land use
compatibility; to avoid new development that may cause airspace obstructions; and to reduce
safety risks associated with airport hazards and accidents. Since this alternative would reduce the
number of visitors to the Project site due to the reduction in proposed new sports fields, impacts
would be less than the Project and less than significant.
5.0 ALTERNATIVES
5-40 Airport Park Expansion Project
Final EIR – January 2018
Would the project impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan?
Similar to the Project, Alternative 3 would realign Donald Douglas South Loop which would be
designed in accordance with City standards to provide adequate emergency access. The realigned
Donald Douglas Loop South would have a minimum width of 24 feet at its intersection with
Donald Douglas Loop and a minimum design turning radius of 27 feet to accommodate the City’s
fleet of emergency vehicles. Therefore, operational impacts with adopted emergency response or
emergency evacuation plans would be similar to the Project and less than significant.
Land Use and Planning
Would the project conflict with any applicable land use plan, policy, or regulation of an agency
with jurisdiction over the Project (including, but not limited to the general plan, specific plan,
local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an
environmental effect?
Regarding land use and planning, Alternative 3 would develop the Project site with recreational
park and open space uses, and as such, would fulfil the City’s long-standing objective established
as early as the 1984 Settlement Agreement to develop recreational uses on non-aviation lands south
of the runway. The passive recreational elements proposed under Alternative 3 are consistent with
other LUCE land use policies, including increasing the amount of green space in the City providing
greater access to recreational facilities, and encouraging local-serving uses. Similar to the Project,
Alternative 3 would be consistent with the overall LUCE vision to expand the amount, quality,
diversity and interconnectivity of parks, open spaces and recreational facilities throughout the City.
Therefore, impacts related to consistency with applicable land use plans, policies, and regulations
would be similar to the Project and less than significant.
The proposed uses under this alternative would be consistent with surrounding land uses and the
existing land use patterns in the vicinity. SMO forms a physical barrier to north-south circulation
through the City with physically separated land uses on either side of the airport. As such, the
existing transportation network has been designed to circumnavigate SMO and this alternative
would not exacerbate any physical barrier caused by SMO. Therefore, this alternative would not
physically divide an established community and further analysis of this issue is not required.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-41
Final EIR – January 2018
Noise
Would the project result in exposure of persons to or generation of noise levels in excess of
standards established in the local general plan or noise ordinance, or applicable standards of
other agencies?
Would the project would result in a substantial temporary or periodic increase in ambient noise
levels in the project vicinity above levels existing without the project?
Would the project result in a substantial permanent increase in ambient noise levels in the project
vicinity above existing levels without the project?
Construction Noise
As discussed above, under Alternative 3, the overall footprint of new recreational uses would be
similar to the Project and, as such, would result in similar duration and extent of construction
activities as the Project, including excavation and grading. As discussed above and in Section 3.6,
Noise, impacts to residential sensitive receptors across South Bundy Drive associated with
construction noise would be potentially significant. As a result, construction noise impacts under
Alternative 3 would similarly be temporarily adverse. With implementation of MM NOI-1,
construction noise impacts would be reduced to less than significant under City of Santa Monica
thresholds. However, similar to the Project, implementation of MM NOI-1 would not guarantee
reductions in construction noise at residences across South Bundy Drive to below adopted
construction noise thresholds for the City of Los Angeles. Therefore, similar to the Project, when
considering City of Los Angeles noise thresholds, impacts would be significant and unavoidable.
Operational Noise
Although the existing sports field at Airport Park would remain, because no additional sports fields
would be developed under Alternative 3, noise from cheering crowds during games and
tournaments and public address system use would be less than under the Project. The passive
recreational uses under Alternative 3 would have a reduced potential to generate large cheering
crowds when compared to sports fields. Although the Project would not result in significant
operational noise impacts, the long-term operational noise levels under this alternative would be
reduced as compared to the Project, particularly for residences east of the Project site due to the
development of less intense uses and an associated reduction in vehicle trip generation (see Table
5-28) Alternative 3 would generate less vehicle trips since no new sports fields would be
developed. Ambient roadway noise increases from Alternative 3 trip generation would be
incremental (e.g., less than 1 dB) and less than the Project. Therefore, noise impacts from park
5.0 ALTERNATIVES
5-42 Airport Park Expansion Project
Final EIR – January 2018
operations and vehicle trips generated by this alternative would be less than under the Project and
less than significant.
Would the project result in exposure of persons to or generation of excessive ground-borne
vibration or ground-borne noise levels?
Similar to the Project, construction of Alternative 3 would generate ground-borne vibration from
various types of construction equipment such as drillers, loaders, jack hammers, and bulldozers.
Periods of high vibration levels would occur primarily during demolition, excavation, and
construction of the sound berm and site foundation. However, vibration levels at nearby sensitive
receptors would be well below the threshold of 0.1 in/sec at all adjacent uses. Therefore, similar
to the Project, ground-borne vibration impacts would be less than significant.
For a project located within an airport land use plan or, where such a plan has not been adopted
within two miles of a public airport or public use airport, would the project expose people residing
or working in the project area to excessive noise levels?
Similar to the Project, Alternative 3 would locate recreational amenities outside of the 65 dB
CNEL noise contour for the airport, minimizing exposure of park visitors to excessive airport noise
levels generated by SMO. Further, similar to the Project, this alternative would involve the
construction of an acoustical sound berm to screen park facilities from both airport and roadway
noise, which would further reduce noise levels from airport operations at the Project site when
compared to existing conditions, in addition to screening sensitive uses to the east from exposure
to noise generated by park operations. Therefore, operational noise impacts of this alternative
would be less than under the Project and less than significant.
Transportation and Traffic
Would the project conflict with an applicable plan, ordinance or policy establishing measures of
effectiveness for the performance of the circulation system, taking into account all modes of
transportation including mass transit and non-motorized travel and relevant components of the
circulation system, including but not limited to intersections, streets, highways and freeways?
Would the project result in a decrease in LOS of affected intersections according to established
thresholds?
Would the project increase traffic demand on the CMP facility by 2 percent (V/C greater than
0.02) causing it to operate at LOS F (V/C > 1.00) of if the facility is already at LOS F, would the
project traffic cause an incremental change in the V/C ratio of 0.02 or greater?
5.0 ALTERNATIVES
Airport Park Expansion Project 5-43
Final EIR – January 2018
Similar to the Project, Alternative 3 would generate short-term construction-related traffic. As the
scope and extent of construction activities would be similar to the Project under this alternative,
construction traffic trips and the impacts to traffic flow, emergency vehicle access, and access to
existing uses would also be similar. This alternative would require similar construction schedule,
fleet of construction equipment, and export of soil materials from the Project site. As with the
Project, the demolition and relocation of Donald Douglas Loop South under Alternative 3 would
occur in a manner to provide continued access to airport uses north of Airport Park. The
construction haul route would be approved by the City to ensure that residential streets would be
avoided. Further, as with the Project, Alternative 3 would require implementation of MM T-1,
requiring the preparation of a Construction Impact Mitigation Plan. Therefore, the construction-
related traffic impacts of Alternative 3 would be similar to the Project and reduced to less than
significant with implementation of the identified mitigation measure.
Operational transportation and circulation impacts under Alternative 3 would be less than under
the Project since the two sports fields proposed under the Project would not be developed. As
compared to the high-trip generating sports fields, the passive recreational uses proposed under
this alternative would have a lower daily, A.M. peak hour, and P.M. peak hour vehicle trip
generation. The Transportation Impact Analysis prepared for this EIR found that Alternative 3
would generate a net increase of 35 A.M. peak hour trips, 39 P.M. peak hour trips, and 278 total
daily trips (Appendix F). Compared to the Project, Alternative 3 would result in the same amount
of A.M. peak hour trips and 59 fewer P.M. peak hour trips, and 89 fewer 249 fewer total daily trips.
Overall, total daily trip generation under this alternative would be reduced approximately 47
percent from the Project.
As this alternative would generate fewer trips relative to the Project, impacts on intersections
within the local street network would be reduced. During the Approval Year (2017) scenario, the
significant intersection impact at 23rd Street & Walgrove Avenue would remain because this
alternative would not change A.M. peak hour conditions, as compared to the Project. The
significant impacts to neighborhood traffic would also remain, as the allowable increase, based on
existing ADT, is 1 trip. This alternative’s reduced trip generation in the P.M. peak hour would
likely eliminate significant impact at the intersection of 23rd Street & Dewey Street and may
eliminate significant impact at the intersection of Bundy Drive & Airport Avenue. The severity of
the impact at Bundy Drive & Ocean Park Boulevard would be reduced by this alternative, but the
intersection would remain significantly and unavoidably impacted. During the Future Year (2025)
scenario, this alternative would most likely impact the same four intersections as the Project (also
for the same peak hours); however, the impact would be lessened under this alternative. Street
5.0 ALTERNATIVES
5-44 Airport Park Expansion Project
Final EIR – January 2018
segment impacts would remain unchanged; however, this is due to the City of Santa Monica’s
criteria considering a single additional trip on local-classified streets as an impact. Therefore,
intersection traffic impacts would be reduced, and would likely result in fewer significantly
impacted intersections identified for the Project. Feasible mitigation is not available to address
these impacts, as discussed in Section 3.7, Transportation and Traffic. Therefore, impacts would
continue to be significant and unavoidable.
5.5.4 Alternative 4 – Reduced Project Alternative (East Paved Surface Area Only)
Under Alternative 4 (the Reduced Project Alternative – East Paved Surface Area Only), only the
east paved surface area would be developed with recreational uses. For the purposes of the EIR,
Alternative 4 assumes that the existing uses on the west paved surface area would remain as is
under existing conditions until SMO ceases operations in 2028 per the 2017 consent decree
between the City and FAA. The west paved surface area would remain as is with existing airplane
hangars, tie-downs, small commercial buildings, and the flight school. There is potential that
existing land uses on the west paved surface area may be converted into another permitted land
use prior to the airport’s closure in 2028, however, for the purposes of this analysis, Alternative 4
assumes that existing commercial and aviation-related uses would remain until 2028.
Under this alternative, for the near-term, Donald Douglas Loop South would not be reconfigured
and only one new sports field would be developed. The existing 58-space north parking lot
adjacent to the existing sports field would remain in place and the three pickleball courts proposed
under the Project would not be developed. The proposed looped path would be shorter than what
is proposed under the Project. The drop-off area and west restroom would also not be developed.
As compared to the Project, the total area of new recreational amenities to be developed under
Alternative 4 would be reduced by approximately 6 acres, or 50 percent. Because the Project’s
proposed 120-space parking lot would also not be developed, Alternative 4 would result in 62
fewer parking spaces than the Project. Alternative 4 also represents an approximately 77 percent
reduction in open space/landscaped area as compared to the Project.
Under this alternative, the park’s architectural design theme and landscape palette under this
alternative would be similar to the Project. The park layout of this alternative would be
considerably reduced as compared to the Project with development of only one new sports field
and densely clustered amenities that would provide space for both active and passive recreational
uses. The acoustic berm at the Project site’s eastern perimeter would continue to be developed
under this alternative, as would the 24-foot-wide path through the berm to form the Main Bundy
Entryway. This alternative is conceptual for the purposes of the EIR; the exact layout and structural
5.0 ALTERNATIVES
Airport Park Expansion Project 5-45
Final EIR – January 2018
configuration of the proposed development is not determined; however, Figure 5-3 provides a
conceptual diagram of what could potentially occur under Alternative 4 with only development of
the east paved surface area only.
In the long-term, after the closure of SMO in 2028, the west paved surface area could be developed
into a park with recreational amenities, similar to the Project, or other uses as part of a
comprehensive land use planning effort following the closure of SMO in 2028. For the purposes
of this EIR, the analysis evaluates only the short-term impacts of retaining the west paved surface
area because any future uses are too speculative to evaluate with certainty at this time. However,
if the west paved surface area were developed with park uses as envisioned by the Project,
environmental impacts would largely be identical to those occurring from the development of the
Project.
With reduction of the amount of proposed new recreational amenities by approximately
50 percent, including reducing the number of new sports fields (from two to one), visitation to
Airport Park would be less than the Project, which would have active sports parks with multiple
playfields during peak sporting events.
By providing a mix of active and passive recreational opportunities, Alternative 4 would continue
to enhance pedestrian-oriented spaces and the overall amount of green space in the City.
Air Quality
Would the project conflict with or obstruct implementation of the applicable air quality plan?
Similar to the Project, this alternative would not conflict with the 2016 AQMP as this alternative
would not contribute to population growth in excess of the AQMP’s population forecast and would
not cause or contribute to new air quality violations as shown in the tables below. Therefore, this
impact would be less than significant.
Would the project violate any air quality standard or contribute substantially to an existing or
projected air quality violation?
Air quality emissions were estimated for both construction and operation of this alternative using
CalEEMod, and compared to the SCAQMD thresholds of significance (Appendix C, see also Table
5-15 and Table 5-16).
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5.0 ALTERNATIVES
Airport Park Expansion Project 5-47
Final EIR – January 2018
Table 5-15. Maximum Estimated Daily Construction Emissions for Alternative 4
compared to SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds3
Construction Emissions1,2 Exceeds Threshold? 2018
NOx 100 31.90 No
VOC 75 1.69 No
PM10 150 9.52 No
PM2.5 55 2.36 No
SOx 150 0.07 No
CO 550 37.41 No
Notes: Bold text indicates the highest potential daily emission level from onsite and offsite sources over the assumed construction
period (January 2018 – July 2019).
1 Refer to Appendix C for CalEEMod output sheets.
2 While Section 2.0, Project Description, describes a 2019-2020 construction schedule, the air pollutant modeling prepared using
CalEEMod software was run assuming a reasonable worst-case scenario for construction emissions in the event Project
construction should begin sooner than initially expected.
3 Source: SCAQMD 2015.
Table 5-16. Maximum Estimated Operational Emissions for Alternative 4 compared to
SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds2
Operational Emissions1 Exceeds
Threshold Area Energy Mobile Overall
NOx 55 0.00 0.00 2.90 2.90 No
VOC 55 0.02 0.00 0.58 0.60 No
PM10 150 0.00 0.00 1.88 1.88 No
PM2.5 55 0.00 0.00 0.52 0.52 No
SOx 150 0.00 0.00 0.02 0.02 No
CO 550 0.00 0.00 7.21 7.21 No
1 Refer to Appendix C for CalEEMod output sheets.
2 Source: SCAQMD 2015.
Construction Emissions
Alternative 4 would reduce the total amount of new recreational area as compared to the Project,
decreasing the duration and extent of construction activities such as demolition and construction.
As the scope of these activities would be reduced from the Project, construction emissions of CO,
VOCs, NOx, PM10 and PM2.5, and SOx would be reduced, and, therefore, emissions from this
alternative’s construction activities would be below SCAQMD construction emissions thresholds.
This alternative would reduce construction-related air quality impacts from the Project, and
impacts would remain less than significant (see Table 5-15).
5.0 ALTERNATIVES
5-48 Airport Park Expansion Project
Final EIR – January 2018
Operational Emissions
As shown in Table 5-16, operational emissions generated by Alternative 4 (including vehicle trips,
energy use, and landscaping maintenance) would be below the SCAQMD operational regional
significance thresholds for all air pollutants. Due to the reduction in new recreational uses proposed
under this alternative, long-term operational air pollutant emissions and impacts to regional air
quality would be slightly reduced when compared to the Project. Further, this alternative would
generate approximately 59 percent fewer traffic trips and associated mobile source emissions
compared to the Project. Therefore, traffic-generated (mobile) air pollutant emissions would be
reduced by a commensurate amount when compared to the Project and would be less than
significant.
As discussed in Section 3.1, Air Quality, the Project would contribute to cumulative traffic in the
area and would incrementally increase CO levels at nearby intersections, but would not exceed
CO thresholds. As trip generation would be reduced under this alternative as compared to the
Project, the increase of CO emissions associated with this alternative would not cause an
exceedance of the state or federal CO standards and CO hotspot impacts would be less than
significant.
Would the project expose sensitive receptors to substantial pollutant concentrations?
As with the Project, this alternative would not generate substantial TACs and would not pose a
risk to sensitive receptors in the vicinity. As concluded in the HRA, SMO would not result in a
significant acute or non-acute carcinogenic health risk effect on visitors at the Project site (see
Appendix B). Upon cessation of operations at SMO, the emission of aviation-related TACs from
SMO operations in the Project vicinity would cease. This alternative’s construction emissions
would be below SCAQMD’s LSTs, as shown in Table 5-17, and impacts to sensitive receptors
would be less than significant.
Table 5-17. Maximum Estimated Daily Construction Emissions for Alternative 4
compared to Localized Significance Thresholds (pounds/day)
Air Pollutant LST Thresholds Construction Emissions1 Exceeds
Threshold? 2018
CO 1,531 36.40 No
NOx 221 33.86 No
PM10 13 9.20 No
PM2.5 6 2.26 No
Notes: Refer to Appendix C for CalEEMod output sheets.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-49
Final EIR – January 2018
1 While Section 2.0, Project Description, describes a 2019-2020 construction schedule, the air pollutant modeling prepared using
CalEEMod software was run assuming a reasonable worst-case scenario for construction emissions in the event Project
construction should begin sooner than initially expected.
Would the project create objectionable odors affecting a substantial number of people?
This alternative would include a similar mix of recreational uses as the Project and, as such, would
not result in objectionable odor impacts, similar to the Project. Therefore, impacts related to odors
would be less than significant.
Construction Effects
Would construction of the project result in considerable construction-period impacts due to the
scope, or location of construction activities?
Under Alternative 4, the decrease in new park space and recreational uses would result in less
construction-related impacts than the Project, including those related to air quality, hazards and
hazardous materials, noise, and transportation and traffic.
With regard to air quality, the reduced size of park space and recreational uses proposed under this
alternative would require a reduced construction schedule and smaller fleet of construction
equipment to develop the recreational amenities. As shown in Table 5-17, when construction-
related air quality emissions are estimated for this alternative, short-term construction-related
regional and localized emissions of criteria pollutants would be less than those generated during
construction of the Project, and would be less than significant.
Regarding hazards and hazardous materials, because Alternative 4 would not require demolition
of the existing structures on the west paved surface area, the potential to encounter LBP and ACMs
during construction would not occur. Therefore, the implementation of MM HAZ-1 requiring a
survey for these materials in existing structures would no longer be required. Development of the
east paved surface area would still have the potential to encounter identified soil contaminants
during the demolition, excavation, and grading phases. The potential to encounter these soil
contaminants would not be any greater than under the Project, and the implementation of MM
HAZ-2 would continue to be required. This mitigation measure requires the implementation of a
Soils Management Plan during excavation and/or grading in areas of known soil contamination,
which includes the screening of materials to confirm any presence of soil contamination and
outlines procedures for the proper handling of contaminated materials if discovered. Because the
demolition of structures potentially containing LBP and ACMs would not occur on the west paved
surface area under Alternative 4, construction impacts would be less than under the Project and
reduced to a less than significant level with the implementation of MM HAZ-1 and MM HAZ-2.
5.0 ALTERNATIVES
5-50 Airport Park Expansion Project
Final EIR – January 2018
With regard to construction-related noise, since Alternative 4 would reduce the development of
new recreational amenities by roughly 6 acres when compared to the Project, the alternative would
require a reduced construction schedule and smaller fleet of construction equipment when
compared to the Project. As with the Project, all construction would continue to be required to
adhere to Section 4.12.110(d) of the City’s Noise Ordinance. MM NOI-1 would require that the
noisiest activities be limited to between the hours of 10:00 A.M. and 3:00 P.M., consistent with
Section 4.12.110(d) of the City’s Noise Ordinance. Under MM NOI-1, the implementation of noise
attenuation measures may include the use of noise barriers (e.g., sound walls) or noise blankets. In
addition, MM NOI-1 would further reduce these impacts as it would ensure that haul trucks
associated with construction activities are routed away from residential streets. Therefore, short-
term construction noise impacts would be similar to the Project and less than significant under the
City of Santa Monica thresholds. However, the City of Los Angeles considers any construction
activity that would exceed existing ambient noise levels by 5 dBA or more at a sensitive receptor
to result in a significant noise impact. Because the greatest impact to nearby sensitive receptors
would occur from construction activities on the east paved surface area, including the installation
of an acoustic berm on the eastern site perimeter, the elimination of the west paved surface area
from development under Alternative 4 would not result in a reduction in construction noise levels
at the residences across South Bundy Drive. Therefore, construction-related noise impacts would
be expected to be similar to the Project and construction noise levels would exceed ambient noise
levels by more than 5 dBA. Even with the implementation of MM NOI-1, impacts would remain
significant and unavoidable when compared to City of Los Angeles thresholds.
Because Alternative 4 does not propose the realignment of Donald Douglas Loop South, any
construction-related access impacts associated with this realignment would not occur.
Construction-related impacts along Airport Avenue adjacent to the west parcel would also be
reduced. Although Alternative 4 would reduce the amount of excavation and grading, the export
of soil and potential temporary construction-related impacts along South Bundy Drive (e.g.,
temporary lane restrictions during construction of the east paved surface area) would still occur.
Therefore, as with the Project, Alternative 4 would require implementation of MM T-1, requiring
the preparation of a Construction Impact Mitigation Plan. Therefore, the construction impacts of
Alternative 4 would be less than under the Project and reduced to less than significant with the
implementation of identified mitigation measures.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-51
Final EIR – January 2018
Greenhouse Gas Emissions
Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
GHG emissions were estimated for both construction and operation of this alternative using
CalEEMod (see Appendix C, Table 5-18, and Table 5-19). The majority of construction-related
GHG emissions would occur during demolition, grading, and construction activities. As the
duration and extent of these activities under Alternative 4 would be less than the Project, total
GHG emissions from construction would be less than the Project and are estimated to be 332 MT
CO2e.
Table 5-18. GHG Emissions from Construction of Alternative 4 (MT/yr)
Construction Phase GHGs (MT CO2e)
Demolition 32
Grading 32
Construction 260
Paving 7
Architectural Coating 1
Total (Construction) 332
Amortized over 30 years 11
Note: All values rounded to the closest whole number.
Source: Annual Emissions Calculations in MT/Year for Alternative 3 - CalEEMod – Appendix C.
Table 5-19. Combined Annual GHG Emissions for Alternative 4 (MT/yr)
Annual Emissions by Category GHGs (MT CO2e)
Area 0
Energy 0
Mobile 390
Waste 0
Water 31
Total (Operational) 421
Construction (amortized) 11
Total (Combined) 432
Note: All values rounded to the closest whole number.
Source: Annual Emissions Calculations in MT/Year for Alternative 4 - CalEEMod – Appendix C.
As the number of parking spaces and amount of recreational uses would be reduced when
compared to the Project, this alternative would generate less operational GHG emissions due to
5.0 ALTERNATIVES
5-52 Airport Park Expansion Project
Final EIR – January 2018
the reduction in energy use for building operations and reduction in vehicle trip generation.
Operational GHG emissions under this alternative are estimated at 421 MT CO2e/year. When the
Project’s amortized construction impacts are considered, the combined annual GHG emissions for
the construction and operation of the Project are estimated to be 432 MT CO2e/year, which would
be below the SCAQMD Tier 3 screening threshold of 3,000 MT CO2e. Therefore, GHG emissions
under Alternative 4 would be less than the Project, and impacts would be less than significant.
Would the project be inconsistent with any applicable plan, policy, or regulation of an agency that
has been adopted for the purpose of reducing GHG emissions?
Similar to the Project, this alternative would be consistent with the City’s plans and policies to
reduce GHG reductions as discussed in Impact GHG-2. Consistent with SCAG’s RTP/SCS
alignment of transportation, land use, and housing strategies, the Project Site is an infill location
and would provide recreational/open space uses in walking distance to existing residential and
commercial uses, which would result in reduced VMT.
Expansion of Airport Park under Alternative 4, even with the reduction in park space, would be
consistent with LUCE Goal LU4, which calls for the creation of complete sustainable
neighborhoods that exemplify sustainable living practices in order to reduce GHGs by providing
uses such as open spaces and green connections that meet the daily needs of residents and reduce
vehicle trips and GHG emissions.
Similar to the Project, the new park space would also be designed to comply with green design
requirements, which would help fulfill LUCE Goal LU16, related to ensuring that new projects
are sustainable and environmentally sound. Therefore, this alternative would be consistent with
the City’s plans, regulations, and policies to reduce GHG reductions. Impacts would be similar to
the Project and less than significant.
Hazards and Hazardous Materials
Would the project create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials?
Similar to the Project, operation of Alternative 4 would entail routine cleaning and maintenance
activities using commercially available hazardous materials, such as cleaning fluids, detergents,
and pesticides/herbicides, etc. However, use of such materials would likely be in limited (i.e., not
commercially reportable) quantities and would be handled in compliance with federal, state, and
local regulations pertaining to their transport, use, and disposal, such as those established by the
U.S. EPA, CalEPA, OSHA, Cal OSHA, and the DTSC. Implementation of standard good
5.0 ALTERNATIVES
Airport Park Expansion Project 5-53
Final EIR – January 2018
housekeeping measures, BMPs, site maintenance and security precautions, as well as compliance
with standards and regulations would ensure that the potential impacts related to the routine
transport, use, or disposal of hazardous materials would be similar to the Project and less than
significant.
Would the project 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?
Would the project would emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within one-quarter mile of an existing or proposed school?
Alternative 4 would require site preparation activities, including excavation and grading similar to
the Project. However, this alternative would not require the demolition of structures on the west
paved surface area that were identified as potentially containing LBP and ACMs, therefore,
Alternative 4 would result in less risks of exposure to hazardous materials, including ACMs and
LBP that could be released during demolition of the existing buildings. Alternative 4 would be
required to mitigate any presence of identified soil contaminants on the east paved surface area in
a similar manner with implementation of MM HAZ-2. With implementation of this mitigation
measure, impacts related to the accidental release of hazardous materials into the environment
would be considered less than significant with mitigation.
For a project located within an airport land use plan or, where such a plan has not been adopted,
within 2 miles of a public airport or public use airport, would the project result in a safety hazard
for people residing or working in the Project site?
Similar to the Project, development under this alternative would be located within the SMO AIA.
However, no portion of the existing Airport Park and Project site is located within a designated
runway protection zone (RPZ). Similar to the Project, Alternative 4 would not place structures, or
recreational amenities within this RPZ. This alternative is also subject to policies regarding airport
safety and development restrictions in RPZs. Alternative 4 would not increase the number of
structures within the flight path or RPZs. In addition, this alternative would require a FAA Part 77
Clearance Permit to be submitted and approved by the FAA to ensure airport land use
compatibility; to avoid new development that may cause airspace obstructions; and to reduce
safety risks associated with airport hazards and accidents. Since this alternative would reduce the
number of visitors to the Project site due to the reduction in recreational uses, this impact would
be less than the Project and would be less than significant.
5.0 ALTERNATIVES
5-54 Airport Park Expansion Project
Final EIR – January 2018
Would the project impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan?
Similar to the Project, Alternative 4 would not realign Donald Douglas South Loop. As such, no
changes to emergency access would occur. Emergency vehicles would continue to access the
Project site as they do under existing conditions. Therefore, operational impacts with adopted
emergency response or emergency evacuation plans would be similar to the Project and less than
significant.
Land Use and Planning
Would the project conflict with any applicable land use plan, policy, or regulation of an agency
with jurisdiction over the Project (including, but not limited to the general plan, specific plan,
local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an
environmental effect?
Alternative 4 would develop active and passive recreational amenities that would be consistent
with applicable land use plans, policies, and regulations, similar to the Project. Because both the
Project and Alternative 4 would develop the Project site with parkland and recreational amenities,
both would fulfil the City’s long-standing objective to develop recreational uses on non-aviation
lands south of the runway. However, Alternative 4 would be less consistent with this objective
than the Project because aviation uses would remain on the west paved surface area. When
combined with the Airport Avenue Improvement Project, this alternative would be consistent with
LUCE objectives of increasing the amount of green space in the City, providing greater access to
recreational facilities, and encouraging local-serving uses. Although this alternative would not
achieve LUCE objectives to the same extent as the Project, impacts related to consistency with
applicable land use plans, policies, and regulations would be less than significant.
The proposed uses developed under this alternative would be consistent with surrounding land
uses and the existing land use patterns in the vicinity. SMO forms a physical barrier to north-south
circulation through the City, and physically separates land uses on either side of the airport. As
such, the existing transportation network has been designed to circumnavigate SMO and this
alternative would not exacerbate any physical barrier caused by SMO. Therefore, this alternative
would not physically divide an established community and further analysis of this issue is not
required.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-55
Final EIR – January 2018
Noise
Would the project result in exposure of persons to or generation of noise levels in excess of
standards established in the local general plan or noise ordinance, or applicable standards of
other agencies?
Would the proposed project would result in a substantial temporary or periodic increase in
ambient noise levels in the project vicinity above levels existing without the project?
Would the project result in a substantial permanent increase in ambient noise levels in the project
vicinity above existing levels without the project?
Construction Noise
Because Alternative 4 would reduce the development of new recreational amenities by roughly 6
acres when compared to the Project, this alternative would require a reduced construction schedule
and smaller fleet of construction equipment when compared to the Project. As with the Project, all
construction would continue to be required to adhere to Section 4.12.110(d) of the City’s Noise
Ordinance. MM NOI-1 would require that the noisiest activities be limited to between the hours
of 10:00 A.M. and 3:00 P.M., consistent with Section 4.12.110(d) of the City’s Noise Ordinance.
Under MM NOI-1, the implementation of noise attenuation measures may include the use of noise
barriers (e.g., sound walls) or noise blankets. In addition, MM NOI-1 would further reduce these
impacts as it would ensure that haul trucks associated with construction activities are routed away
from residential streets. Therefore, under City of Santa Monica thresholds, short-term construction
noise impacts would be similar to the Project and less than significant. However, the City of Los
Angeles considers any construction activity that would exceed existing ambient noise levels by 5
dBA or more at a sensitive receptor to result in a significant noise impact. Because the greatest
impact to nearby sensitive receptors would occur from construction activities on the east paved
surface area, including the installation of an acoustic berm on the eastern site perimeter, the
elimination of the west paved surface area from development under Alternative 3 would not result
in a reduction in construction noise levels at the residences across South Bundy Drive, Therefore,
construction-related noise impacts would be expected to be similar to the Project and exceed
ambient noise levels by more than 5 dBA, and even with the implementation of MM NOI-1.
Therefore, impacts would remain significant and unavoidable when compared to City of Los
Angeles thresholds.
5.0 ALTERNATIVES
5-56 Airport Park Expansion Project
Final EIR – January 2018
Operational Noise
Long-term operational noise levels under this alternative would be incrementally reduced as
compared to the Project, due to the decrease in developed park area (which would decrease park
intensity of use and associated vehicle trip generation). Alternative 4 would generate less vehicle
trips because one less sports fields would be developed, resulting in less intensity of park use
compared to the Project. Ambient roadway noise increases from Alternative 4 trip generation
would be incremental (e.g., less than 1 dB) and less than the Project. Therefore, noise impacts from
vehicle trips generated by this alternative would be less than the Project.
Under Alternative 4, overall park noise generated by visitors would also be reduced when
compared to the Project due to the decrease in crowds and sports events on the site. However,
because the primary cause of potential noise impacts from park visitors on sensitive receptors was
the effect of crowd cheering at the east sports field on the residences across South Bundy Drive,
the impacts on these sensitive receptors would not be reduced by eliminating park development
on the west paved surface area. As with the Project, maximum intermittent noise levels perceptible
at the residences located approximately 180 feet to the north and across South Bundy Drive from
events at the proposed east sports fields would not be expected to exceed a maximum of 58 dBA
- which is within the acceptable noise levels for residential uses within both the City of Santa
Monica and City of Los Angeles. However, when considering the reduction in vehicle noise from
the Project, overall noise impacts from Alternative 4 on nearby sensitive residences would be less
than under the Project and less than significant.
Additionally, similar to the Project, Alternative 4 would be designed to locate park facilities and
amenities where people would recreate outside of the 65 dB CNEL noise contour for the airport,
minimizing exposure of visitors and park goers to excessive airport noise levels generated by
SMO. Further, similar to the Project, this alternative would involve the construction of an
acoustical sound berm to screen park facilities from both airport and roadway noise, which would
further reduce noise levels from airport operations at the site when compared to existing
conditions, in addition to screening sensitive uses to the north from exposure to noise generated
by park operations. Therefore, operational noise impacts of this alternative would be slightly less
than the Project and would be less than significant.
Would the project result in exposure of persons to or generation of excessive ground-borne
vibration or ground-borne noise levels?
Construction of Alternative 4 would generate ground-borne vibration from various types of
construction equipment such as drillers, loaders, jack hammers, and bulldozers. Periods of high
5.0 ALTERNATIVES
Airport Park Expansion Project 5-57
Final EIR – January 2018
vibration levels would occur primarily during demolition, excavation, and construction of the
sound berm and site foundation. However, vibration levels at nearby sensitive receptors would be
well below the threshold of 0.1 in/sec at all adjacent uses. Therefore, similar to the Project, ground-
borne vibration impacts would be less than significant.
Transportation and Traffic
Would the project conflict with an applicable plan, ordinance or policy establishing measures of
effectiveness for the performance of the circulation system, taking into account all modes of
transportation including mass transit and non-motorized travel and relevant components of the
circulation system, including but not limited to intersections, streets, highways and freeways?
Would the project result in a decrease in LOS of affected intersections according to established
thresholds?
Would the project increase traffic demand on the CMP facility by 2 percent (V/C greater than
0.02) causing it to operate at LOS F (V/C > 1.00) of if the facility is already at LOS F, would the
project traffic cause an incremental change in the V/C ratio of 0.02 or greater?
Similar to the Project, Alternative 4 would generate short-term construction related traffic. As the
scope and extent of construction would be reduced under this alternative, the duration of
construction traffic trips would also be slightly reduced. Similar to the Project, construction-related
traffic impacts would be reduced to less than significant after implementation of mitigation
measure MM T-1.
Operational transportation and circulation impacts under Alternative 4 would be reduced as
compared to the Project due to the reduction in recreational uses and associated vehicle trip
generation. The Transportation Study prepared for this EIR found that Alternative 4 would
generate a net increase of 18 A.M. peak hour trips, 88 P.M. peak hour trips, and 310 total daily trips
Alternative 4 would result in 17 fewer A.M. peak hour, 10 fewer P.M. peak hour trips, and 217
fewer total daily trips. Overall, trip generation under this alternative would be reduced
approximately 47percent from the Project. Further, Alternative 4 would not relocate Donald
Douglas Loop South, and so impacts at this intersection would remain less than significant, as
under existing conditions.
As this alternative would generate fewer trips relative to the Project, impacts on intersections
within the local street network would be reduced. During the Approval Year (2017) scenario, the
same 3 study intersections that would be impacted by the Project would also be impacted under
this alternative. Because the estimated trip generation of this alternative is less than the Project in
5.0 ALTERNATIVES
5-58 Airport Park Expansion Project
Final EIR – January 2018
the A.M. peak hour, it would likely eliminate the significant impact at 23rd Street & Walgrove
Avenue. Although the trip generation for this alternative is less than the Project in the P.M. peak
hour, the difference is less. Consequently, the severity of the impacts at 23rd Street & Dewey Street,
Bundy Drive & Ocean Park Boulevard, and Bundy Drive & Airport Avenue may be reduced under
this alternative, but the intersections would remain significantly and unavoidably impacted. The
significant impacts to neighborhood street segments would also occur, as the City’s significance
threshold is 1 trip based on existing ADT. During the Future Year (2025) scenario, this alternative
would likely impact the same four intersections as the Project (also for the same peak hours).
Therefore, traffic impacts would be reduced and would result in a reduced number of significantly
impacted intersections identified for the Project. Feasible mitigation is not available to address
these impacts, as discussed in Section 3.7. Therefore, impacts would continue to be significant and
unavoidable.
5.5.5 Alternative 5 – Community Recreation Center Alternative
Similar to the Project, Alternative 5 (Community Recreation Center Alternative) would expand
Airport Park by developing approximately 12 acres of new park facilities and recreational
amenities on non-aviation lands adjacent to the existing Airport Park. However, under Alternative
3, a two-story Community Recreation Center (CRC) providing 25,000 sf of floor area would be
built in place of the Project’s west sports field proposed on the west paved surface area. The CRC
would provide a range of features requested during the community design process. Indoor
recreational amenities provided by the CRC could include a multi-purpose room/gym, basketball
courts, swimming pool, fitness room, rock climbing wall, and/or racquetball courts. It is
anticipated that the multi-purpose room/gym could accommodate performances through the use of
a permanent or portable stage. The CRC would also potentially include less active areas, such as
community meeting rooms, an activity room (e.g., pool tables, table tennis tables, arcade games),
locker rooms with shower facilities, and a kitchen or snack bar. In addition, an outdoor shaded
seating area with tables would be developed along the southern edge of the building. With
exception of the proposed sports field that would be replaced by the CRC, the remainder of the
Project site would be developed as proposed under the Project.
Other park facilities would be designated to accommodate active and passive recreational uses and
pedestrian amenities (interconnected, looping pathways), similar to the Project. Local examples of
the types of recreational facilities anticipated in the CRC include Memorial Park; the Santa Monica
Swim Center, which is an aquatics center offering two open-air pools for recreational and lap
swimming, lessons and classes; and Rustic Canyon Recreation Center. Virginia Avenue Park is
another local example of a higher intensity mixed-use park, as it contains a teen center, park center,
5.0 ALTERNATIVES
Airport Park Expansion Project 5-59
Final EIR – January 2018
library, sports fields, walking paths, a weekly farmers market, and a full schedule of free programs
for community members of all ages.
The park layout of Alternative 5 would be similar to that of the Project, with exception of the CRC
building, which would replace the west sports field proposed under the Project. The remainder of
the park layout and new landscaping of this alternative would be similar to that of the Project. This
alternative is conceptual for the purposes of the EIR. The exact layout and structural configuration
of the proposed development is not determined; however, Figure 5-4 provides a conceptual
diagram of what could potentially occur under Alternative 5.
By providing a mix of indoor and outdoor, active and passive recreational opportunities,
Alternative 5 would continue to increase the overall amount of green space in the City, although
to a lesser extent than the Project.
Air Quality
Would the project conflict with or obstruct implementation of the applicable air quality plan?
Similar to the Project, this alternative would not conflict with the 2016 AQMP as this alternative
would not contribute to population growth in excess of the AQMP’s population forecast, and
would not cause or contribute to new air quality violations as shown in the tables below. Therefore,
this impact would be less than significant.
Would the project violate any air quality standard or contribute substantially to an existing or
projected air quality violation?
Air quality emissions were estimated for both construction and operation of this alternative using
CalEEMod, and compared to the thresholds of significance for SCAQMD (Appendix C, see also
Table 5-20 and Table 5-21).
Construction Emissions
Construction-related emissions for most criteria air pollutants under this alternative would be
similar to the Project, as the area to be demolished and graded is similar. Construction-related
emissions under Alternative 5 would be slightly greater than under the Project because the
construction of the CRC building would require more construction activity than a sports field.
Under this alternative, VOC emissions would be substantially greater than the Project due to the
architectural coating phase for the proposed CRC building. However, as with the Project,
construction emissions for CO, VOC, NOx, PM10, PM2.5 and SOx would be below SCAQMD
construction thresholds and impacts would be less than significant (see Table 5-20).
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5.0 ALTERNATIVES
Airport Park Expansion Project 5-61
Final EIR – January 2018
Table 5-20. Maximum Estimated Daily Construction Emissions for Alternative 5
compared to SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds3
Construction Emissions1,2 Exceeds Threshold? 2018 2019
NOx 100 62.32 11.35 No
VOC 75 3.76 29.89 No
PM10 150 11.54 0.78 No
PM2.5 55 4.18 0.66 No
SOx 150 0.13 0.02 No
CO 550 74.05 17.97 No
Notes: Bold text indicates the highest potential daily emission level from onsite and offsite sources over the assumed construction
period (early 2018 – early 2019).
1 Refer to Appendix C for CalEEMod output sheets.
2 While Section 2.0, Project Description, describes a 2019-2020 construction schedule, the air pollutant modeling prepared using
CalEEMod software was run assuming a reasonable worst-case scenario for construction emissions in the event Project
construction should begin sooner than initially expected.
3 Source: SCAQMD 2015.
Operational Emissions
Table 5-21. Maximum Estimated Operational Emissions for Alternative 5 compared to
SCAQMD Regional Thresholds of Significance (pounds/day)
Air Pollutant SCAQMD
Thresholds2
Operational Emissions1 Exceeds
Threshold Area Energy Mobile Overall
NOx 55 0.00 0.12 12.50 12.62 No
VOC 55 4.22 0.01 2.59 6.83 No
PM10 150 0.00 0.01 7.50 7.51 No
PM2.5 55 0.00 0.01 2.07 2.08 No
SOx 150 0.00 0.00 0.10 0.10 No
CO 550 0.00 0.10 29.65 29.75 No
1 Refer to Appendix C for CalEEMod output sheets.
2 Source: SCAQMD 2015.
Operational air pollutant emissions and impacts to regional air quality would increase under this
alternative largely due to the increase in vehicle trips that would be generated by use of the CRC
and other new recreational uses, as compared to the Project. As shown in Table 5-21, operational
emissions generated by Alternative 5 (including vehicle trips, energy use, and
landscaping/building maintenance) would be below the SCAQMD operational regional
significance thresholds for CO, NOx, PM10, PM2.5, SOx, and VOC; therefore, operational emission
impacts would be less than significant.
5.0 ALTERNATIVES
5-62 Airport Park Expansion Project
Final EIR – January 2018
As discussed in Section 3.1, Air Quality, the Project would contribute to cumulative traffic in the
area and would incrementally increase CO levels generated from congested intersections.
Although this alternative would affect peak traffic volumes at intersections in the Project vicinity
more so than the Project, the TIA estimated 74 A.M. peak hour and 164 P.M. peak hour trips would
be introduced, the addition of which would still not exceed 44,000 vehicles during the peak hour
at any intersection. Therefore, CO hotspot impacts would be similar to the Project, and this impact
would be less than significant.
Would the project expose sensitive receptors to substantial pollutant concentrations?
Similar to the Project, this alternative would not generate substantial quantities of TACs and would
not pose a risk to sensitive receptors in the vicinity. As concluded in the HRA prepared for the
Project, SMO would not result in a significant acute or non-acute carcinogenic health risk effect
on visitors or employees at the Project site (see Appendix B). Further, development of the CRC
building would provide more indoor recreational uses, the use of building filtration system meeting
Minimum Efficiency Reporting Value (MERV) standards could be incorporated into the
building’s HVAC system design to further lessen the impacts of park employees and visitors from
health risks associated with TACs from aircraft operations SMO. Upon cessation of operations at
SMO, the emission of aviation-related TACs from SMO operations in the Project vicinity would
cease. As with the Project, this alternative’s construction emissions would be below SCAQMD’s
Localized Significant Thresholds (LSTs), as shown in Table 5-22. Therefore, impacts to sensitive
receptors would be less than significant.
Table 5-22. Maximum Estimated Daily Construction Emissions for Alternative 5
compared to Localized Significance Thresholds (pounds/day)
Air Pollutant LST Thresholds Construction Emissions1 Exceeds
Threshold? 2018 2019
CO 1,531 72.81 17.30 No
NOx 221 60.93 11.30 No
PM10 13 11.22 0.61 No
PM2.5 6 4.10 0.61 No
Notes: Refer to Appendix C for CalEEMod output sheets.
1 While Section 2.0, Project Description, describes a 2019-2020 construction schedule, the air pollutant modeling prepared using
CalEEMod software was run assuming a reasonable worst-case scenario for construction emissions in the event Project
construction should begin sooner than initially expected.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-63
Final EIR – January 2018
Would the project create objectionable odors affecting a substantial number of people?
This alternative would include recreational uses and as such, would not result in objectionable
odor impacts, similar to the Project. Therefore, impacts related to odors would be less than
significant.
Construction Effects
Would construction of the proposed project result in considerable construction-period impacts
due to the scope, or location of construction activities?
Under Alternative 5, the decrease in new recreational park and open space uses would result in
less construction-related impacts than the Project, including those related to air quality, hazards
and hazardous materials, noise, and transportation and traffic.
With regard to air quality, the reduced size of recreational facilities proposed under this alternative
would require a reduced construction schedule and smaller fleet of construction equipment to
develop the recreational amenities. As shown in Table 5-20, when construction-related air quality
emissions are estimated for this alternative, short-term construction-related regional and localized
emissions of criteria pollutants would be less than those generated during construction of the
Project, and would be less than significant.
Regarding hazards and hazardous materials, because Alternative 5 would not require demolition
of the existing structures on the west paved surface area, the potential to encounter LBP and ACMs
during construction would not occur. Therefore, the implementation of MM HAZ-1 requiring a
survey for these materials in existing structures would no longer be required. Development of the
east paved surface area would still have the potential to encounter identified soil contaminants
during the demolition, excavation, and grading phases. The potential to encounter these soil
contaminants would not be any greater than under the Project, and the implementation of MM
HAZ-2 would continue to be required. This mitigation measure requires the implementation of a
Soils Management Plan during excavation and/or grading in areas of known soil contamination,
which includes the screening of materials to confirm any presence of soil contamination and
outlines procedures for the proper handling of contaminated materials if discovered. Because the
demolition of structures potentially containing LBP and ACMs would not occur on the west paved
surface area under Alternative 5, construction impacts would be less than under the Project and
reduced to a less than significant level with the implementation of MM HAZ-1 and MM HAZ-2.
5.0 ALTERNATIVES
5-64 Airport Park Expansion Project
Final EIR – January 2018
With regard to construction-related noise, since Alternative 5 would result in the development of
new recreational amenities similar to the Project, the alternative would require a similar
construction schedule and similar fleet of construction equipment when compared to the Project.
As with the Project, all construction would continue to be required to adhere to Section 4.12.110(d)
of the City’s Noise Ordinance. MM NOI-1 would require that the noisiest activities be limited to
between the hours of 10:00 A.M. and 3:00 P.M., consistent with Section 4.12.110(d) of the City’s
Noise Ordinance. Under MM NOI-1, the implementation of noise attenuation measures may
include the use of noise barriers (e.g., sound walls) or noise blankets. In addition, MM NOI-1
would further reduce these impacts as it would ensure that haul trucks associated with construction
activities are routed away from residential streets. Therefore, short-term construction noise impacts
would be similar to the Project and less than significant under the City of Santa Monica thresholds.
However, the City of Los Angeles considers any construction activity that would exceed existing
ambient noise levels by 5 dBA or more at a sensitive receptor to result in a significant noise impact.
Because the greatest impact to nearby sensitive receptors would occur from construction activities
on the east paved surface area, including the installation of an acoustic berm on the eastern site
perimeter, the elimination of the west paved surface area from development under Alternative 5
would not result in a reduction in construction noise levels at the residences across South Bundy
Drive. Therefore, construction-related noise impacts would be expected to be similar to the Project
and construction noise levels would exceed ambient noise levels by more than 5 dBA. Even with
the implementation of MM NOI-1, impacts would remain significant and unavoidable when
compared to City of Los Angeles thresholds.
Because this alternative would require a similar construction schedule, fleet of construction
equipment, and export of soil materials from the Project site, construction impacts would be similar
to the Project. As with the Project, the demolition and relocation of Donald Douglas Loop South
under Alternative 5 would occur in a manner to provide continued access to airport uses north of
Airport Park. The construction haul route would be approved by the City to ensure that residential
streets would be avoided. Further, as with the Project, Alternative 5 would require implementation
of MM T-1, requiring the preparation of a Construction Impact Mitigation Plan. Therefore, the
construction impacts of Alternative 5 would be similar to the Project and reduced to less than
significant with the implementation of identified mitigation measures.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-65
Final EIR – January 2018
Greenhouse Gas Emissions
Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
GHG emissions were estimated for both construction and operation of this alternative using
CalEEMod (see Appendix C, Table 5-23, and Table 5-24). Alternative 5 would generate greater
GHG emissions than the Project during both construction and operation, due to the construction
of additional buildings and the increase in energy use for building operations and substantial
increase in the total number of daily trips generated by the proposed CRC building. Temporary
generation of GHG emissions from construction of this alternative are estimated to be 1,496 MT
CO2e. Operational GHG emissions under this alternative are estimated at 1,861 MT CO2e/ year.
When the Project’s amortized construction impacts are considered, the combined annual GHG
emissions for the construction and operation of the Project are estimated to be 1,911 MT
CO2e/year, which would be below the SCAQMD Tier 3 screening threshold of 3,000 MT CO2e.
Therefore, although GHG emissions under Alternative 5 would be greater than the Project, impacts
would still be less than significant.
Table 5-23. GHG Emissions from Construction of Alternative 5 (MT/yr)
Construction Phase GHGs (MT CO2e)
Demolition 117
Grading 130
Park Construction 1,220
Paving 27
Architectural Coating 2
Total (Construction) 1,496
Amortized over 30 years 50
Note: All values rounded to the closest whole number.
Source: Annual Emissions Calculations in MT/Year for Alternative 5 - CalEEMod – Appendix C.
Table 5-24. Combined Annual GHG Emissions for Alternative 5 (MT/yr)
Annual Emissions by Category GHGs (MT CO2e)
Area 0
Energy 166
Mobile 1,575
Waste 72
Water 48
Total (Operational) 1,861
Construction (amortized) 50
Total (Combined) 1,911
Note: All values rounded to the closest whole number.
Source: Annual Emissions Calculations in MT/Year for Alternative 4 - CalEEMod – Appendix C.
5.0 ALTERNATIVES
5-66 Airport Park Expansion Project
Final EIR – January 2018
Would the project be inconsistent with any applicable plan, policy, or regulation of an agency that
has been adopted for the purpose of reducing GHG emissions?
Alternative 5 would be consistent with the City’s plans and policies to reduce GHG reductions as
discussed in Impact GHG-2. Consistent with SCAG’s RTP/SCS alignment of transportation, land
use, and housing strategies, the Project site is an infill location and would provide
recreational/open space uses in walking distance to existing residential and commercial uses,
which would result in reduced VMT.
Expansion of Airport Park and development of the CRC under Alternative 5 would help fulfill
LUCE Goal LU4, which calls for the creation of complete sustainable neighborhoods that
exemplify sustainable living practices in order to reduce GHGs by providing uses such as open
spaces and green connections that meet the daily needs of residents and reduce vehicle trips and
GHG emissions.
Similar to the Project, the new park space and CRC building would also be designed to comply
with green design requirements, which would help fulfill LUCE Goal LU16, related to ensuring
that new projects are sustainable and environmentally sound. Therefore, this alternative would be
consistent with the City’s plans, regulations, and policies to reduce GHG reductions. Impacts
would be similar to the Project and less than significant.
Hazardous and Hazardous Materials
Would the project create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials?
Similar to the Project, operation of Alternative 5 would entail routine cleaning and maintenance
activities using commercially available hazardous materials, such as cleaning fluids, detergents,
and pesticides/herbicides, etc. However, use of such materials would likely be in limited (i.e., not
commercially reportable) quantities and would be handled in compliance with federal, state, and
local regulations pertaining to their transport, use, and disposal, such as those established by the
U.S. EPA, CalEPA, OSHA, Cal OSHA, and the DTSC. Implementation of standard good
housekeeping measures, BMPs, site maintenance and security precautions, as well as compliance
with standards and regulations would ensure that the potential impacts related to the routine
transport, use, or disposal of hazardous materials would be similar to the Project and less than
significant.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-67
Final EIR – January 2018
Would the project 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?
Would the project would emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within one-quarter mile of an existing or proposed school?
With regard to hazards and hazardous materials, the development of the west and east paved
surface areas would continue to have the potential to encounter LBP, ACMs, and identified soil
contaminants during the demolition, excavation, and grading phases. The potential to encounter
these hazardous materials would not be any greater than under the Project, and the implementation
of MM HAZ-1 and MM HAZ-2 would also be required. These measures require a comprehensive
survey for LBP and ACMs prior to the start of demolition, and appropriate remediation of these
materials, if discovered. The measures further require a Soils Management Plan to be implemented
during excavation and/or grading in areas of known soil contamination, which includes screening
of materials to confirm any presence of soil contamination and outlines procedures for the proper
handling of contaminated materials if discovered. With implementation of identified mitigation
measures, construction impacts would be similar to under the Project and would be reduced to less
than significant.
For a project located within an airport land use plan or, where such a plan has not been adopted,
within 2 miles of a public airport or public use airport, would the project result in a safety hazard
for people residing or working in the Project site?
Similar to the Project, development under this alternative would be located within the SMO AIA.
However, no portion of the existing Airport Park and Project site is located within a designated
runway protection zone (RPZ). Similar to the Project, Alternative 5 would not place structures, or
recreational amenities within this RPZ. This alternative is also subject to policies regarding airport
safety and development restrictions in RPZs. Alternative 5 would not increase the number of
structures within the flight path or RPZs. In addition, this alternative would require a FAA Part 77
Clearance Permit to be submitted and approved by the FAA to ensure airport land use
compatibility; to avoid new development that may cause airspace obstructions; and to reduce
safety risks associated with airport hazards and accidents. Therefore, similar to the Project, this
impact would be less than significant.
5.0 ALTERNATIVES
5-68 Airport Park Expansion Project
Final EIR – January 2018
Would the project impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan?
Similar to the Project, Alternative 5 would realign Donald Douglas South Loop, which would be
designed in accordance with City standards to provide adequate emergency access. The realigned
Donald Douglas Loop South would have a minimum width of 24 feet at its intersection with
Donald Douglas Loop and a minimum design turning radius of 27 feet to accommodate the City’s
fleet of emergency vehicles. Therefore, operational impacts with adopted emergency response or
emergency evacuation plans would be similar to the Project and less than significant.
Land Use and Planning
Would the project conflict with any applicable land use plan, policy, or regulation of an agency
with jurisdiction over the Project (including, but not limited to the general plan, specific plan,
local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an
environmental effect?
Similar to the Project, Alternative 5 would be consistent with the City’s long-standing objective to
develop recreational uses on non-aviation lands south of the runway. Alternative 5 would be also
consistent with the overall LUCE vision to enhance recreational opportunities within the City.
Development of this alternative would contribute to implementing LUCE goals to increase the
amount of green space in the City providing greater access to recreational facilities, and in
combination with the Airport Avenue Improvement Project, create expanded bicycle and
pedestrian networks throughout the City, and encourage local-serving uses. Further, similar to the
Project, Alternative 5 would be consistent with the LUCE vision to expand the amount, quality,
diversity and interconnectivity of parks, open spaces and recreational facilities throughout the City.
As with the Project, Alternative 5 would provide enhanced recreational opportunities within access
to existing transit lines. Therefore, similar to the Project, land use impacts resulting from
Alternative 5 would remain less than significant.
The proposed uses developed under this alternative would be consistent with surrounding land
uses and the existing land use patterns in the vicinity. SMO forms a notable barrier to north-south
circulation through the City, and physically separates land uses on either side of the airport. As
such, the existing transportation network has been designed to circumnavigate SMO and this
alternative would not exacerbate any physical barrier caused by SMO. Therefore, this alternative
would not physically divide an established community and further analysis of this issue is not
required.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-69
Final EIR – January 2018
Noise
Would the project result in exposure of persons to or generation of noise levels in excess of
standards established in the local general plan or noise ordinance, or applicable standards of
other agencies?
Would the proposed project would result in a substantial temporary or periodic increase in
ambient noise levels in the project vicinity above levels existing without the project?
Would the project result in a substantial permanent increase in ambient noise levels in the project
vicinity above existing levels without the project?
Construction Noise
As discussed above, construction of the CRC building on the west paved surface area and the new
park space on the remainder of the Project site would result in a slightly longer duration and extent
of construction activities as compared to the Project. Construction noise and vibration would be
generated from demolition, excavation, construction activities, and truck haul trips. As discussed
in Section 3.6, Noise, construction noise impacts to residential sensitive receptors would be
temporarily adverse. However, the temporary adverse impacts occur at the residences located east
of the Project site would not be increased by the construction of the CRC, which would occur on
the west paved surface area. As a result, although noise impacts under Alternative 5 would be
greater than those described under the Project, the alternative would not increase the significant
and unavoidable impacts resulting from the Project. Similar to the Project, with implementation of
MM NOI-1, construction noise impacts would be reduced to less than significant under City of
Santa Monica thresholds, though construction noise would be slightly greater than under the
Project. Additionally, implementation of MM NOI-1 is not expected to guarantee reductions in
construction noise at residences across South Bundy Drive to below adopted construction noise
thresholds for the City of Los Angeles. Therefore, similar to the Project, when considering City of
Los Angeles noise thresholds, impacts would conservatively be considered to remain significant
and unavoidable.
Operational Noise
Under Alternative 5, additional operational noise may be generated through an increase in trip
generation due to the increase in intensity of use from development of the CRC building. However,
noise levels that would be generated by an increase in trip generation would be a nominal addition
to the incremental noise level increases generated by the Project. Ambient roadway noise increases
from Alternative 5 trip generation would be incremental (e.g., less than 1 dB). Therefore, noise
5.0 ALTERNATIVES
5-70 Airport Park Expansion Project
Final EIR – January 2018
impacts on existing sensitive receptors from vehicle trips generated by this alternative would
remain less than significant, though slightly greater than the Project.
Stationary noise sources may be increased as compared to the Project due to the development of
an indoor recreational facility, which would include the use of HVAC equipment and other
stationary noise sources. All new stationary noise sources, such as heating, ventilation, and air
condition (HVAC) systems would be located, installed, and shielded in accordance with SMMC
requirements. Although development of the CRC would result in higher intensity of park uses, it
would place many recreational amenities indoors, which would generate fewer sources of crowd
noise than the sports fields proposed under the Project. However, because the primary cause of
potential noise impacts from park visitors on sensitive receptors would be the effect of crowd
cheering at the east sports field on the residences across South Bundy Drive, the impacts on these
sensitive receptors would not be reduced by developing a CRC in place of the west sports field.
As with the Project, maximum intermittent noise levels perceptible at the residences located
approximately 180 feet to the north and across South Bundy Drive from events at the proposed
east sports field would not be expected to exceed a maximum of 58 dBA, which is within the
acceptable noise levels for residential uses within both the City of Santa Monica and City of Los
Angeles. Operational noise impacts on existing sensitive receptors from new stationary noise
sources would be reduced as compared to the Project, and would be less than significant.
Additionally, similar to the Project, Alternative 5 would locate park facilities and amenities outside
of the 65 dB CNEL noise contour for the airport, minimizing exposure of visitors and park goers
to excessive airport noise levels generated by SMO. Construction of the CRC building would
provide park visitors with an indoor space to recreate, which would further reduce potential
exposure to noise generated by SMO. This alternative would also involve the construction of an
acoustical sound berm to screen park facilities from both airport and roadway noise, which would
further reduce noise levels from airport operations at the site when compared to existing
conditions, similar to the Project. Therefore, as compared to the Project, this alternative would
reduce impacts and operational noise impacts would remain less than significant.
Would the project result in exposure of persons to or generation of excessive ground-borne
vibration or ground-borne noise levels?
Construction of Alternative 5 would generate ground-borne vibration from various types of
construction equipment such as drillers, loaders, jack hammers, and bulldozers. Periods of high
vibration levels would occur primarily during demolition, excavation, and construction of the
sound berm and site foundation. However, vibration levels at nearby sensitive receptors would be
5.0 ALTERNATIVES
Airport Park Expansion Project 5-71
Final EIR – January 2018
well below the threshold of 0.1 in/sec at all adjacent uses. Therefore, similar to the Project, ground-
borne vibration impacts would be less than significant.
Transportation and Traffic
Would the project conflict with an applicable plan, ordinance or policy establishing measures of
effectiveness for the performance of the circulation system, taking into account all modes of
transportation including mass transit and non-motorized travel and relevant components of the
circulation system, including but not limited to intersections, streets, highways and freeways?
Would the project result in a decrease in LOS of affected intersections according to established
thresholds?
Would the project increase traffic demand on the CMP facility by 2 percent (V/C greater than
0.02) causing it to operate at LOS F (V/C > 1.00) of if the facility is already at LOS F, would the
project traffic cause an incremental change in the V/C ratio of 0.02 or greater?
In addition to the impacts described in Section 3.7, Transportation and Traffic, Alternative 5 would
increase Project-generated traffic impacts and congestion at project study intersections. Similar to
the Project, Alternative 5 would create traffic impacts through generation of short-term
construction related traffic. As the scope and extent of construction would be increased under this
alternative, the duration of construction traffic trips would also be increased. Therefore,
construction-related traffic impacts would be greater than the Project and would remain significant
and unavoidable, even after implementation of mitigation measure MM T-1.
Operational transportation and circulation impacts under Alternative 5 would be increased from
the Project due to the increase in intensity of use of the recreational development, and associated
vehicle trip generation. Development of higher intensity park and CRC uses would generate
additional vehicle trips when compared to the Project, and traffic impacts would be greater. This
alternative would result in higher traffic volumes during peak use periods and may require more
parking than the Project. The Transportation Impact Analysis prepared for this EIR found that the
trip generation for Alternative 5 would be 113 percent more than that of the Project in the A.M.
peak hour and up to 68 percent more in the P.M. peak hour (Appendix F). This alternative would
generate 74 A.M. peak hour trips, 164 P.M. peak hour trips, and 1,474 total daily trips. As compared
to the Project, Alternative 5 would generate a net increase of 39 A.M. peak hour trips, 66 P.M. peak
hour trips, and 947 total daily trips. Compared to the Project, trip generation under this alternative
would be increased 180 percent from the Project.
5.0 ALTERNATIVES
5-72 Airport Park Expansion Project
Final EIR – January 2018
Based on the number of additional trips generated by the CRC building and projected traffic
conditions during the Approval Year (2017) and Future Year (2025) scenarios, additional
significant intersection impacts would occur. All the significant intersection impacts under
Approval Year and Future Year would remain. The neighborhood traffic significant impacts would
also occur based on the City’s 1 trip threshold. It is also anticipated that this alternative would
result in further significant impacts at analyzed intersections. In particular, the intersection of
Bundy Drive & Ocean Park Boulevard may be further impacted in the A.M. peak hour under both
Approval Year and Future Year conditions.
Feasible mitigation is not available to address these impacts, as discussed in Section 3.7. Therefore,
impacts would continue to be significant and unavoidable.
5.6 IDENTIFICATION OF ENVIRONMENTALLY SUPERIOR ALTERNATIVE
Section 15126.6(e)(2) of the State CEQA Guidelines indicates that an analysis of alternatives shall
identify an environmentally superior alternative among the alternatives evaluated in the EIR. In
general, the environmentally superior alternative as defined by CEQA should minimize adverse
impacts to the Project site and its surrounding environment. Table 5-25 summarizes the
environmental advantages and disadvantages associated with the Project and the analyzed
alternatives. In evaluating alternatives, different weights may be assigned to the relative
importance of specific environmental impacts. For example, in comparing alternatives for the
Project, “more weight” was given to significant short-term noise and long-term traffic effects than
to other resource area impacts, primarily considering the importance of these issue areas to result
in significant and unavoidable impacts (e.g., short-term construction noise on sensitive receptors,
increased traffic congestion at study intersections and neighborhood street segments).
Of the alternatives considered, Alternative 3, the "Airport Park Expansion without Fields
Alternative” reduces Project impacts the most; although significant and unavoidable short-term
noise impacts and long-term traffic impacts would remain, the long-term traffic impacts would be
measurably reduced. Because Alternative 3 would reduce long-term traffic impacts the most, this
alternative is considered to be the environmentally superior alternative over other alternatives that
may have fewer impacts in other areas, as shown in Table 5-25. However, by providing no new
sports fields, Alternative 3 would not meet the Project’s primary objective—as well as the desires
of the community and the City—to develop the Airport Park Expansion Park Project in a manner
than maximizes the number of new sports fields at Airport Park.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-73
Final EIR – January 2018
Table 5-25. Impact Comparison of Alternatives to the Proposed Project
Issue Area Project
Comparison to Project
Alternative 1 Alternative 2 Alternative
3
Alternative
4
Alternative
5
Air Quality Less Than Significant Less Greater Less Less Greater
Construction
Effects
Significant and
Unavoidable Less Greater Similar Less Greater
Greenhouse
Gas
Emissions
Less Than Significant
Less Greater Less Less Greater
Hazards and
Hazardous
Materials
Less Than Significant
with Mitigation Less Similar Similar Less Similar
Land Use and
Planning
Less Than Significant Less Similar Similar Less Similar
Noise Significant and
Unavoidable Less Greater Less Similar Less
Transportation
/ Traffic
Significant and
Unavoidable Less Greater Less Less Greater
Project
Objectives
Met?
Yes No No No Partially Partially
5.0 ALTERNATIVES
5-74 Airport Park Expansion Project
Final EIR – January 2018
Table 5-26. Maximum Daily Construction Emissions for Alternatives (lbs/day)
Emission Source CO
(lbs/day)
VOCs
(lbs/day)
NOx
(lbs/day)
PM10
(lbs/day)
PM2.5
(lbs/day)
SOx
(lbs/day)
Thresholds of Significance1 550 75 100 150 55 150
Localized Significance Thresholds2 6 -- 221 13 6 --
PROPOSED PROJECT
Total 74.33 6.70 63.84 7.10 4.21 0.14
Above Thresholds? No No No No No No
ALTERNATIVE 2: NO PROJECT/REASONABLE FORESEEABLE ALTERNATIVE
Total 38.68 57.65 34.18 11.36 3.10 0.12
Above Thresholds? No No No No No No
ALTERNATIVE 3: AIRPORT PARK EXPANSION WITHOUT FIELDS
Total 74.33 6.70 63.84 11.46 4.21 0.14
Above Thresholds? No No No No No No
ALTERNATIVE 4: REDUCED PROJECT – EAST PARCEL ONLY
Total 37.41 1.69 31.90 9.52 2.36 0.07
Above Thresholds? No No No No No No
ALTERNATIVE 5: COMMUNITY RECREATION CENTER
Total 74.05 29.89 62.32 11.54 4.18 0.13
Above Thresholds? No No No No No No
1 Source: SCAQMD Air Quality Significance Thresholds 2015.
2 Localized significance threshold for a 1.55-acre site in SRA-2 within 25 meter distance from sensitive receptors.
3 Represents localized emission values at the site of the offsite affordable housing development(s).
Note: Values for maximum daily emissions represent peak values during the 2019 construction period. However, as discussed
above Alternative 2 refers to reasonable foreseeable development that would not occur until 2029, after the airport’s closure in
2028. Refer to Appendix C for CalEEMod output sheets.
5.0 ALTERNATIVES
Airport Park Expansion Project 5-75
Final EIR – January 2018
Table 5-27. Maximum Operational Emissions from Alternatives (lbs/day)
Emission Source CO
(lbs/day)
VOCs
(lbs/day)
NOx
(lbs/day)
PM10
(lbs/day)
PM2.5
(lbs/day)
SOx
(lbs/day)
Thresholds1 550 55 55 150 55 150
PROPOSED PROJECT
Total 12.26 4.68 4.94 3.21 0.89 0.04
Above Thresholds? No No No No No No
ALTERNATIVE 2: NO PROJECT/REASONABLE FORESEEABLE DEVELOPMENT
Total 89.72 18.04 39.39 43.64 11.91 0.44
Above Thresholds? No No No No No No
ALTERNATIVE 3: AIRPORT PARK EXPANSION WITHOUT FIELDS
Total 6.46 4.22 2.60 1.69 0.47 0.02
Above Thresholds? No No No No No No
ALTERNATIVE 4: REDUCED PROJECT – EAST PARCEL ONLY
Total 7.21 0.60 2.90 1.88 0.52 0.02
Above Thresholds? No No No No No No
ALTERNATIVE 5: COMMUNITY RECREATION CENTER
Total 29.75 6.83 12.62 7.51 2.08 0.10
Above Thresholds? No No No No No No
1 Source: SCAQMD Air Quality Significance Thresholds 2015.
2 Due to CalEEMod limitations, mitigated VOC values after architectural coatings cannot be estimated with CalEEMod. VOC
values are calculated after the use of low-VOC architectural coatings with an emission factor of 50 grams/Liter, as mandated by
the South Coast Air Quality Management District (SCAQMD).
Refer to Appendix C for CalEEMod output sheets.
5.0 ALTERNATIVES
5-76 Airport Park Expansion Project
Final EIR – January 2018
Table 5-28. Trip Generation Comparison for Alternatives
Land Use A.M. Peak Hour
Trips
P.M. Peak Hour
Trips Total Daily Trips
PROPOSED PROJECT
City Park (to be renovated): -1.5 acres
City Park (Developed, parking lot): 1 acre
Pickleball courts: 3 courts
Community gardens: 80 plots
Soccer Fields (new): 2 fields
35 98 527
ALTERNATIVE 2: NO PROJECT/REASONABLE FORESEEABLE DEVELOPMENT
Community College: 165,000 sf
Government Office Complex: 100,000 sf
609 574 6,638
Change in Trip Generation Compared to Proposed
Project
1639 percent 485 percent 1160 percent
ALTERNATIVE 3: AIRPORT PARK EXPANSION WITHOUT FIELDS
City Park (to be renovated): -1.5 acres
City Park (Developed, parking lot): 3.2 acres
Community gardens: 160 plots
35 39 278
Change in Trip Generation Compared to Proposed
Project
0 percent -60 percent -47 percent
ALTERNATIVE 4: REDUCED PROJECT – EAST PARCEL ONLY
City Park (to be renovated): -0.5 acres
City Park (Developed, parking lot): 1 acre
Community gardens: 80 plots
Soccer Fields (new): 1 field
18 88 310
Change in Trip Generation Compared to Proposed
Project
-49 percent -10 percent -41 percent
ALTERNATIVE 5: COMMUNITY RECREATION CENTER
City Park (to be renovated): -1.5 acres
City Park (Developed, parking lot): 2.7 acres
Pickleball courts: 3 courts
Community gardens: 80 plots
Soccer Fields (new): 1 field
Recreational Community Center: 27,500 sf
74 164 1,474
Change in Trip Generation Compared to Proposed
Project
113 percent 68 percent 180 percent
Source: (Fehr & Peers 2017).
Airport Park Expansion Project 6-1
Final EIR – January 2018
6.0 LIST OF PREPARERS
City of Santa Monica
Rachel Kwok Environmental Planner
Karen Ginsberg Director, Community and Cultural Services
Voneelya Simmons Project Manager
Melissa Spagnuolo Senior Analyst
Amec Foster Wheeler Environment & Infrastructure, Inc.
Dan Gira Project Principal
Erika Leachman Project Manager
Shawn Gaver Deputy Project Manager
Julia Pujo QA/QC
Steve Ochs Senior Air Quality Specialist
Caryn Kelly Toxicologist
Laura Ingulsrud Air Quality Specialist/Analyst
Brian Cook Senior Noise Specialist
Marie Laule Lead Analyst
Erlin Worthington Environmental Analyst
Matthew Buggert Environmental Analyst
Taylor Lane Environmental Analyst
Janice Depew Word Processor
Fehr & Peers
Tom Gaul Principal Investigator/Project Manager
Netai Basu Associate-in-Charge
Jeremiah LaRose Transportation Engineer
Graphics Consultant
Deirdre Stites Graphics Specialist
6.0 LIST OF PREPARERS
6-2 Airport Park Expansion Project
Final EIR – January 2018
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Airport Park Expansion Project 7-1
Final EIR – January 2018
7.0 REFERENCES
INTRODUCTION
City of Santa Monica. 1984. Santa Monica Airport 1984 Agreement.
City of Santa Monica. 2002. Santa Monica Airport Park Environmental Impact Report - State
Clearinghouse No. 2001089096.
City of Santa Monica. 2015. City Council Report March 24, 2015 Agenda Item 8-A. Accessed: 9
May 2017. Retrieved from:
https://www.smgov.net/departments/council/agendas/2015/20150324/s2015032408-
A.htm
City of Santa Monica. 2016. City Council Report September 27, 2016 Agenda Item 8-A.
PROJECT DESCRIPTION
No references.
AIR QUALITY
Coffman Associates. 2017. Briefing Paper - Operational Impact of 3,500-Foot Runway Length -
Santa Monica Airport.
South Coast Air Quality Management District. 2003. Air Quality Management Plan, Appendix
V: Modeling and Attainment Demonstrations. South Coast Air Quality Management
District. Accessed: 18 October 2017. Retrieved from:
http://www.aqmd.gov/home/library/clean-air-plans/air-quality-mgt-plan/2003-aqmp
South Coast Air Quality Management District. 2015. SCAQMD Air Quality Significance
Thresholds. Accessed: 4 August 2016. Retrieved from:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-
significance-thresholds.pdf?sfvrsn=2
South Coast Air Quality Management District. 2016a. National Ambient Air Quality Standards
(NAAQS) and California Ambient Air Quality Standards (CAAQS) Attainment Status for
South Coast Air Basin.
South Coast Air Quality Management District. 2016b. Draft Final 2016 Air Quality Management
Plan.
U.S. Climate Data. 2017. Climate Santa Monica - California and Weather averages Santa
Monica. Accessed: 25 July 2017. Retrieved from:
http://www.usclimatedata.com/climate/santa-monica/california/united-states/usca1024
U.S. EPA. 2017. Lead (Pb) Air Pollution | US EPA. Accessed: 19 July 2017. Retrieved from:
https://www.epa.gov/lead-air-pollution
7.0 REFERENCES
7-2 Airport Park Expansion Project
Final EIR – January 2018
CONSTRUCTION EFFECTS
South Coast Air Quality Management District D. 2016. National Ambient Air Quality Standards
(NAAQS) and California Ambient Air Quality Standards (CAAQS) Attainment Status for
South Coast Air Basin. Accessed: 4 August 2016. Retrieved from:
http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-
plans/naaqs-caaqs-feb2016.pdf
GREENHOUSE GAS EMISSIONS
Air Resources Board. 2016. Executive Order G-16-066 SCAG 2016 SCS ARB Acceptance of
GHG Quantification Determination. Accessed: 25 July 2017. Retrieved from:
https://www.arb.ca.gov/cc/sb375/scag_executive_order_g_16_066.pdf
California Air Resources Board. 2016. California Greenhouse Gas Inventory Data 2000-2014.
Accessed: 12 April 2017. Retrieved from:
https://www.arb.ca.gov/cc/inventory/pubs/reports/2000_2014/ghg_inventory_trends_00-
14_20160617.pdf
City of Santa Monica. 2016. City of Santa Monica 15x15 Climate Action Plan Final Report
2016. Accessed: 8 August 2017. Retrieved from:
https://www.smgov.net/uploadedFiles/Departments/OSE/Climate/CSM_1515_CAP_Fina
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IPCC, Cubash, U., Wuebbles, D., Chen, D., Facchini, M. C., Frame, D., Mahowald, N., et al.
2013. Climate Change 2013: The Physical Science Basis. Contribution of Working
Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate
Change. Cambridge University Press.
IPCC, Edenhofer, O., Pichs-Madruga, R., Sokona, Y., Minx, J., Farahani, E., Kadner, S., et al.
2014. Climate Change 2014: Mitigation of Climate Change. Working Group III
Contribution to the Fifth Assessment Report of the Intergovernmental Panel on Climate
Change. Cambridge University Press.
Office of Planning and Research. 2016. Office of Planning and Research - CEQA. Accessed: 3
January 2017. Retrieved from: https://www.opr.ca.gov/m_ceqa.php
United Nations Framework Convention on Climate Change. 2017. The Paris Agreement - main
page. Accessed: 26 July 2017. Retrieved from:
http://unfccc.int/paris_agreement/items/9485.php
U.S. EPA. 2015. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 2013.
U.S. EPA. 2016. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2014. Accessed:
12 April 2017. Retrieved from: https://www.epa.gov/sites/production/files/2016-
04/documents/us-ghg-inventory-2016-main-text.pdf
7.0 REFERENCES
Airport Park Expansion Project 7-3
Final EIR – January 2018
HAZARDS AND HAZARDOUS MATERIALS
CAL FIRE. 2011. Map of Fire Hazard Severity Zones in Los Angeles County.
Caltrans. 2011. Division of Aeronautics California Airport Land Use Planning Handbook.
City of Los Angeles Department of City Planning. 1996. Safety Element of the Los Angeles
General Plan.
Department of Toxic Substances Control. 2017. EnviroStor Database Search Tool. Accessed: 5
May 2017. Retrieved from: https://www.envirostor.dtsc.ca.gov/public/
Los Angeles County Department of Regional Planning, Airport Land Use Commission. 2004.
Comprehensive Land Use Plan.
National Transportation Safety Board. 2017. Aviation Accident Database & Synopsis. Accessed:
10 May 2017. Retrieved from: https://www.ntsb.gov/_layouts/ntsb.aviation/index.aspx
LAND USE AND PLANNING POLICIES
City of Santa Monica. 1984. Santa Monica Airport 1984 Agreement. Accessed: 20 December
2016. Retrieved from:
http://www.smgov.net/Departments/Airport/About/Airport_Documents_and_Studies.aspx
City of Santa Monica. 1997. Parks and Recreation Master Plan. Accessed: 13 June 2017.
Retrieved from:
https://www.smgov.net/uploadedFiles/Departments/CCS/Places_Parks_Beach/Parks/Park
s_and_Recreation_Master_Plan.pdf
City of Santa Monica. 2001. Open Space Element. Accessed: 11 August 2017. Retrieved from:
https://www.smgov.net/uploadedFiles/Departments/PCD/Plans/General-Plan/Open-
Space-Element/Adopted-Open-Space-Element-1997.pdf
City of Santa Monica. 2002. Santa Monica Airport Park Environmental Impact Report - State
Clearinghouse No. 2001089096.
City of Santa Monica. 2010. General Plan. Accessed: 20 June 2017. Retrieved from:
https://www.smgov.net/Departments/PCD/Plans/General-Plan/
City of Santa Monica. 2015a. City of Santa Monica Municipal Code Zoning Ordinance and Land
Use and Zoning Related Provisions. Accessed: 20 December 2016. Retrieved from:
http://www.smgov.net/Departments/PCD/Zoning/
City of Santa Monica. 2015b. 2010 Santa Monica Land Use & Circulation Element.
City of Santa Monica. 2017. Santa Monica Public Works: Public Landscape. Accessed: 20 June
2017. Retrieved from: https://www.smgov.net/departments/publicworks/landscape.aspx
7.0 REFERENCES
7-4 Airport Park Expansion Project
Final EIR – January 2018
Consent Decree between the Federal Aviation Administration and the City of Santa Monica.
2017. Accessed: 13 June 2017. Retrieved from:
https://www.smgov.net/uploadedFiles/Departments/Airport/Litigation/Consent%20Decre
e%20(FAA%20-%20Santa%20Monica).pdf
Los Angeles County Airport Land Use Commission. 2004. Comprehensive Land Use Plan.
Accessed: 20 June 2017. Retrieved from:
http://planning.lacounty.gov/assets/upl/data/pd_alup.pdf
Southern California Association of Governments. 2012. Regional Transportation Plan /
Sustainable Communities Strategy: Towards a Sustainable Future. Accessed: 20 June
2017. Retrieved from: http://rtpscs.scag.ca.gov/Pages/default.aspx
NOISE
ACOUSTICS. 2011. Prediction of Noise from Small to Medium Sized Crowds. Australian
Acoustical Society. Accessed: 18 July 2017. Retrieved from:
https://www.acoustics.asn.au/conference_proceedings/AAS2011/papers/p133.pdf
AECOM. 2017. Qualitative Noise Analysis, Santa Monica Airport Runway Shortening Project.
Caltrans. 2013a. Technical Noise Supplement to the Traffic Noise Analysis Protocol. California
Department of Transportation. Accessed: 3 August 2017. Retrieved from:
http://www.dot.ca.gov/hq/env/noise/pub/TeNS_Sept_2013B.pdf
Caltrans. 2013b. Transportation and Construction Vibration Guidance Manual. Accessed: 1
February 2016. Retrieved from:
http://www.dot.ca.gov/hq/env/noise/pub/TCVGM_Sep13_FINAL.pdf
City of Los Angeles. 1999. Noise Element. Accessed: 29 June 2017. Retrieved from:
https://planning.lacity.org/cwd/gnlpln/noiseElt.pdf
City of Santa Monica. 1992. Noise Element of the General Plan - Goals, Policies, and
Implementation. Accessed: 14 December 2016. Retrieved from:
http://www.smgov.net/uploadedFiles/Departments/PCD/Plans/General-Plan/Noise-
Element/Adopted-Noise-Element-1992.pdf
City of Santa Monica. 2017. Calendar Year 2016 CNEL Contours Santa Monica Municipal
Airport.
Culbertson, Adams & Associates, Inc. 2002. Santa Monica Airport Park Draft Environmental
Impact Report.
Los Angeles Department of Transportation. 2016. Current Count Data | City of Los Angeles
Department of Transportation. Accessed: 30 June 2017. Retrieved from:
http://ladot.lacity.org/what-we-do/traffic-volume-counts/current-count-data
7.0 REFERENCES
Airport Park Expansion Project 7-5
Final EIR – January 2018
U.S. Department of Transportation. 2006. Handbook - Construction Noise - Noise –
Environment - FHWA. Accessed: 23 May 2017. Retrieved from:
https://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/
TRANSPORTATION AND TRAFFIC
Breeze. 2017. Santa Monica Bike Share. Accessed: 5 June 2017. Retrieved from:
https://santamonicabikeshare.com
City of Santa Monica. 2011. Santa Monica Bike Action Plan. Accessed: 22 June 2017. Retrieved
from: https://www.smgov.net/uploadedFiles/Departments/PCD/Plans/Bike-Action-
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Gibson Transportation Consulting, Inc. 2017. ‘Draft Parking Study for Santa Monica Airport’.
Transportation Research Board. 2010. Highway Capacity Manual 2010. Accessed: 5 June 2017.
Retrieved from: http://hcm.trb.org/?qr=1
OTHER CEQA
AECOM. 2017. Cultural Resources Assessment for the Santa Monica Airport Runway
Shortening Project – Technical Memorandum.
Amec Foster Wheeler. 2016. Santa Monica Post Office Productions Final Initial Study/Mitigated
Negative Declaration.
Amec Foster Wheeler. 2017. Downtown Community Plan - City of Santa Monica Final
Environmental Impact Report.
California Emergency Management Agency. 2009. Tsunami Inundation Map for Beverly Hills
Quadrangle - Los Angeles County. Accessed: 9 July 2017. Retrieved from:
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7-6 Airport Park Expansion Project
Final EIR – January 2018
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Accessed: 24 July 2017. Retrieved from:
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City of Santa Monica. 2014a. Sustainable City Plan. Accessed: 19 July 2017. Retrieved from:
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nable-City-Plan.pdf
City of Santa Monica. 2014b. Sustainable Water Master Plan. Accessed: 8 August 2017.
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from:
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Final_June_2016.pdf
City of Santa Monica. 2015b. Water Shortage Response Plan. Accessed: 8 August 2017.
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2.htm
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lReport2016.pdf
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Accessed: 9 July 2017. Retrieved from:
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Culbertson, Adams & Associates, Inc. 2002. Santa Monica Airport Park Draft Environmental
Impact Report.
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Airport - Panel 06037C1590F. Accessed: 9 July 2017. Retrieved from:
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2C%20Curtis%20Bay%2C%20MD%2021226#searchresultsanchor
HDR. 2013. Zero Waste Strategic Operations Plan for the City of Santa Monica. Accessed: 10
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Strategic%20Plan.pdf
Santa Monica Fire Department. 2017. Fire Station Information. Accessed: 9 July 2017.
Retrieved from: https://santamonicafire.org/Content.aspx?id=7390
7.0 REFERENCES
Airport Park Expansion Project 7-7
Final EIR – January 2018
Santa Monica-Malibu Unified School District. 2016. School Accountability Report Cards
(SARC). Accessed: 9 July 2017. Retrieved from:
http://www.smmusd.org/SARC/index.html
Santa Monica-Malibu Unified School District. 2017. Santa Monica-Malibu Unified Schools List
of Schools. Accessed: 9 July 2017. Retrieved from: http://www.smmusd.org/schools.html
Santa Monica Police Department. 2016. Employee Demographic Report. Accessed: 7 July 2017.
Retrieved from:
https://www.santamonicapd.org/uploadedFiles/Police/About_Us/Org_Chart_Content/Em
ployee%20Demographics%20Race.pdf
ALTERNATIVES
City of Santa Monica. 2016. Santa Monica Municipal Code Chapter 9.15 - Public and Semi-
Public Districts. Accessed: 17 July 2017. Retrieved from:
http://www.qcode.us/codes/santamonica/view.php?topic=9-2-
9_15&showAll=1&frames=on
South Coast Air Quality Management District. 2015. SCAQMD Air Quality Significance
Thresholds. Accessed: 4 August 2016. Retrieved from:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-
significance-thresholds.pdf?sfvrsn=2
7.0 REFERENCES
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8.0 INTRODUCTION TO THE FINAL EIR
8.1 PUBLIC REVIEW PROCESS
The Draft EIR was available for a 45-day public review period between October 27, 2017 and
December 11, 2017. During this period, a total of 4 comment letters on the Draft EIR were received
by the City.
8.2 CEQA REQUIREMENTS
Before approving a project that may cause a significant environmental impact, CEQA requires the
Lead Agency to prepare a Final EIR. CEQA Guidelines Section 15132 specifies that the Final EIR
shall consist of:
(a) The Draft EIR or a revision of the draft;
(b) Comments and recommendations received on the Draft EIR either verbatim or in
summary;
(c) A list of persons, organizations, and public agencies commenting on the Draft EIR;
(d) The responses of the Lead Agency to significant environmental points raised in the
review and consultation process; and
(e) Any other information added by the Lead Agency.
8.3 USE OF THE FINAL EIR
The Final EIR allows the public and the City of Santa Monica an opportunity to review the
response to comments, revisions to the Draft EIR, and other components of the EIR, such as the
Mitigation Monitoring and Reporting Program (MMRP), prior to the City’s decision on the project.
The Final EIR serves as the environmental document to support approval of the Project, either in
whole or in part.
After completing the Final EIR, and before approving the project, the Lead Agency must first
“certify” the Final EIR. As required by Section 15090 of the CEQA Guidelines, certification
consists of three distinct but complementary findings:
• That the Final EIR has been completed in compliance with CEQA;
• That the Final EIR was presented to the decisionmaking body of the Lead Agency, and
that the decisionmaking body reviewed and considered the information in the Final EIR
prior to approving the project; and
• That the Final EIR reflects the Lead Agency’s independent judgment and analysis.
The Final EIR and the findings will be submitted to City decisionmakers for consideration in
connection with the Project.
8.0 INTRODUCTION TO THE FINAL EIR
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CEQA “Findings of Fact” are adopted pursuant to Section 15091(a) of the CEQA Guidelines,
which provides that if an EIR that has been certified for a project identifies one or more significant
environmental effects, the Lead Agency decisionmaking body must make one or more of the
following findings with respect to each significant effect identified in the Final EIR:
• Changes or alterations have been required in, or incorporated into, the project which avoid
or substantially lessen the significant environmental effect as identified in the EIR.
• Such changes or alterations are within the responsibility and jurisdiction of another public
agency and not the agency making the finding. Such changes have been adopted by such
other agency or can and should be adopted by such other agency.
• Specific economic, legal, social, technological, or other considerations, including
provision of employment opportunities for highly trained workers, make infeasible the
mitigation measures or project alternatives identified in the Final EIR.
Each finding must be accompanied by a brief explanation of the rationale for the finding, though
references to supporting text in the EIR documentation is commonly used to satisfy that
requirement. In addition, pursuant to Section 15091(d) of the CEQA Guidelines, the agency must
adopt, in conjunction with the findings, a program for reporting on or monitoring the changes that
it has either required in the project or made a condition of approval to avoid or substantially lessen
environmental effects. These measures must be fully enforceable through permit conditions,
agreements, or other measures. This program is referred to as the MMRP.
Additionally, pursuant to Sections 15091(b) and 15093(b) of the CEQA Guidelines, when a Lead
Agency approves a project that would result in significant, unavoidable impacts that are disclosed
in the Final EIR, the agency must state in writing its reasons for supporting the approved action.
This written statement, known as a Statement of Overriding Considerations, must be supported by
substantial information in the record, which includes this Final EIR.
9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
The Final Environmental Impact Report (EIR) provides responses to all written comments
received on the Draft EIR. Comments on the Draft EIR include issues raised by agencies and/or
the public that warrant clarification or correction of certain statements in the Draft EIR. None of
the corrections and additions constitutes significant new information or substantial project changes
as defined by CEQA Guidelines Section 15088.5.
Each comment letter has been assigned an abbreviation (e.g., CALTRANS). The body of each
comment letter has been separated into individual comments, which have been numbered. This
results in a numbering system whereby the first comment in the letter from the Applicant is
depicted as Comment CALTRANS-1, and so on. These numbered comments are included in their
entirety, followed by the corresponding responses. Copies of the comment letters are included in
Appendix G of this Final EIR. The following presents a list of all persons or organizations who
submitted written comments on the Draft EIR:
Table 9-1. Commenters on the Draft EIR
Name Comment ID No.
Governmental Agencies
California Department of Transportation (Caltrans) Division of Aeronautics CALTRANS 1-2
Businesses
Southern California Edison (SCE) SCE 1-4
Public
Vincent Balembois VB 1
John Ayers JA 1-5
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
Letter CALTRANS
December 7, 2017
California Department of Transportation Division of Aeronautics
Philip Crimmins, Aviation Environmental Specialist
1120 N. Street
P.O. Box 942874
Sacramento, CA 94274-0001
Comment CALTRANS-1
The California Department of Transportation (Caltrans), Division of Aeronautics (Division),
reviewed the above-referenced document with respect to airport-related noise and safety impacts
and regional aviation land use planning issues pursuant to the California Environmental Quality
Act (CEQA). The Division has technical expertise in the areas of airport operations safety, noise,
and airport land use compatibility. We are a funding agency for airport projects and we have permit
authority for public-use and special-use airports and heliports. The following comments are offered
for your consideration.
The proposed project is for redevelopment of land at Santa Monica Airport (SMO) for recreational
uses including new sports fields, pathways, restrooms and concession buildings. The project site
will also get improved vehicle circulation and parking facilities. The project site is located at
various distances southeast of Runway 3/21 at Santa Monica Airport. The proposed parking lot is
approximately 650 feet from the runway centerline and one of the proposed regulation-sized sports
fields is approximately 650 feet from the runway centerline.
In accordance with CEQA, Public Resources Code Section 21096, the California Airport Land
Use Planning Handbook (Handbook) must be utilized as a resource in the preparation of
environmental documents for projects within airport land use compatibility plan boundaries or if
such a plan has not been adopted, within two miles of an airport. The Handbook is a resource that
should be applied to all public use airports and is available on-line at
http://dot.ca.gov/hq/planning/aeronaut/documents/alucp/AirportLandUsePlanningHandbook.pdf
Response
The City appreciates Caltrans’ provision of information related to the safe operation of SMO and
Airport Park following implementation of the Project. Airport-related safety hazards following
implementation of the Project are addressed in Section 3.4, Hazards and Hazardous Materials, of
the Draft EIR. The applicability of the Handbook to this Project is described under State Policies
and Regulations in Section 3.4.2, Regulatory Setting. As further discussed under Regional and
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
Local Policies and Regulations in Section 3.4.2, the Handbook was used by the Los Angeles
County Airport Land Use Commission (ALUC) to guide preparation of the Countywide Airport
Land Use Plan (ALUP). ALUP Policy S-4 prohibits the erection or growth of objects within a
designated Runway Protection Zone (RPZ) which rise above an approach surface unless supported
by evidence that it does not create a safety hazard and is approved by the FAA, while Policy S-7
requires substantial modifications of zoning or building ordinances to comply with the height
restriction standards and procedures set forth in FAA Part 77. As discussed under Impact HAZ-4,
the Project site is located outside of the both the general approach area and RPZ of Runway 3/21,
and the Project would not introduce structures, recreational amenities, or sports fields within this
RPZ. As further discussed, a FAA Part 77 Clearance Permit for the Project would be submitted
and approved by the FAA to ensure airport land use compatibility; to avoid new development that
may cause airspace obstructions; and to reduce safety risks associated with airport hazards and
accidents. If the FAA concludes that the Project, as designed, would introduce incompatible uses
to the airport, design revisions would be made in accordance to FAA regulations or not receive
FAA approval. While this comment does not raise a concern regarding the adequacy of the Draft
EIR or provide significant new information or substantial Project changes, the discussion of the
Handbook in Section 3.4.2, Regulatory Setting and Impact HAZ-4 in Section 3.4.4, Project
Impacts and Mitigation Measures have been augmented with the clarifying information provided
by Caltrans, as reflected in the Final EIR and in Section 10, Corrections and Additions.
Comment CALTRANS-2
Portions of the project site appear to currently be within the Sideline Safety Zone (Zone 5) for
SMO as defined in the Handbook. However, as stated in the project’s regulatory framework in the
draft environmental impact report, SMO’s runway will be shortened by early 2018. Shortening or
lengthening the runway at an individual airport, along with the corresponding change in the fleet
of aircraft that will use the runway, could warrant a change to the delineation of the airport safety
zones. It must be determined if additional airport land use compatibility policies should apply to
this project if the project site will be in different Handbook safety zones as a result of the runway
shortening. Likewise, the Airport Land Use Commission should be notified of the new runway
length so they can determine if the SMO airport influence area needs to be reconfigured. The SMO
airport influence area includes the runway protection zone and airport planning boundary.
Response
As noted in this comment, the northern portion of the Project site is located within the Sideline
Safety Zone (Zone 5) for SMO Runway 3/21. The basic compatibility policies of Zone 5 are
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
outlined in Figure 4F (Safety Zone 5 – Sideline Zone, page 4-25) of the Handbook. As disclosed
therein, the risk level in Zone 5 is considered low to moderate, and stadiums and group recreational
uses are generally prohibited in Zone 5, although neither the Handbook or FAA guidelines
specifically define what is considered a group recreational use. A discussion of the Project’s
consistency with the compatible uses in Zone 5 has been added to Section 3.4.2, Regulatory
Framework, and Impact HAZ-4, of the Draft EIR. As discussed therein, the Project has been
designed to place non-recreational features, such as the parking lot, restrooms, and acoustical berm
closest to the runway. The Project’s proposed recreational uses, such as the two sports fields, would
be located outside of Zone 5. As noted by the commenter, the nearest sports field would be located
approximately 650 feet away from the runway centerline.
Additionally, following publication of the Draft EIR, the Runway Shortening Project was
completed. SMO Runway 3/21 is considered a Short General Aviation Runway per the guidelines
of the Handbook. All safety zones would be reduced in size to match the Handbook’s guidelines,
under which no portion of the Project site would be located within the Sideline Protection Zone.
As the owner and operator of SMO, the City would coordinate with the Los Angeles County
Airport Land Use Commission (ALUC) to determine any revisions to the size and location of
safety zones following the Runway Shortening Project. However, the purpose of the Runway
Shortening Project is to reduce the number of overall operations at the airport by reducing the size
of aircraft that can use SMO, particularly small jet aircraft. As a result, it is anticipated that the
hazard potential for SMO and surrounding uses will be reduced in the near future. While this
comment does not raise a concern regarding the adequacy of the Draft EIR or provide significant
new information or substantial Project changes, the discussion of the applicable safety zones in
Section 3.4.2, Regulatory Setting and an explanation of the relationship of the safety zones to the
Runway Shortening Project in Impact HAZ-4 in Section 3.4.4, Project Impacts and Mitigation
Measures have been augmented with the clarifying information provided by Caltrans, as reflected
in the Final EIR and in Section 10, Corrections and Additions.
Letter SCE
November 1, 2017
Southern California Edison
Heather Neely, Environmental Services, Third Party Environmental Reviews
2244 Walnut Grove Avenue
Rosemead, CA 91770
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
Comment SCE-1
SCE’s Electrical Facilities
SCE provides electric service to the City of Santa Monica and maintains electrical transmission
and distribution facilities, as well as substations and supporting appurtenances within the City.
Page 4-19 of the Project’s Draft Environmental Impact Report (DEIR) notes that “An onsite
transformer taking the form of a pad-mounted structure or a below-grade structure would likely be
required to meet the increased demand for electricity to power the Project’s variety of lighting
structures.”
Development within SCE’s Rights-of-Way and Access Roads
The proposed project should not unreasonably interfere with SCE’s ability to access, maintain, and
operate its current and future facilities. Additionally, if any development which includes
permanent, temporary or grading within the Right-of-Way (such as bike lanes and landscaping)
are planned within SCE’s corridors a written consent agreement signed between the developer and
SCE is required. Any parkways or pathways (either by foot, bicycles, or other means) that invite
the public onto SCE’s right-of-way will require the installation of fencing and/or Climbing
Discouragers on each transmission line tower at the customer’s expense. SCE’s rights-of-way and
fee-owned properties are used by SCE to operate and maintain its present and future facilities. SCE
will review any proposed use on a case-by-case basis. Approvals or denials will be in writing based
upon review of the maps provided by the developer and compatibility with SCE right-of-way
constraints and rights. Please forward five (5) sets of plans depicting SCE's facilities and associated
land rights to the following location:
Real Properties Department
Southern California Edison Company
2 Innovation Way
Pomona, CA 91768.
Response
The Project site and surrounding vicinity does not contain any SCE Right-of-Way. Electricity is
delivered to the Project site through above-ground telephone poles adjacent to the south side of
Airport Avenue. At strategic locations (i.e., at the existing bathroom/maintenance building and at
a pad-mounted transformer at the west driveway entrance to the existing parking lot), power lines
run underneath Airport Avenue and into Airport Park, where electricity is then distributed
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
throughout the park in standard voltage (i.e., 110-volt) transmission lines. Beginning at Barker
Hangar (located immediately west of the Project Site), electricity is conveyed to uses north of
Airport Avenue through above-ground lines across Airport Avenue. There, the Project would not
require any development in SCE rights-of-way. However, new facilities (i.e., underground
electrical lines, pad-mounted transformers) may need to be installed to connect the expanded park
facilities to the existing SCE distribution infrastructure. During the Project final design stages, the
City would coordinate with SCE to determine the appropriate connection points and equipment
required, including sending five sets of Project plans to the address listed in the comment. The
City looks forward to coordinating with SCE during final project design and implementation to
avoid interference with SCE’s ability to access, maintain, and operate its current and future
facilities in the Project vicinity. As this comment does not raise a concern regarding the adequacy
of the Draft EIR, no corrections or addition to the Draft EIR, or further response, is required.
Comment SCE-2
General Order 131-D
The construction, modification, and relocation of transmission lines, or electrical facilities that are
designed to operate at or above 50 kilovolts (kV) may be subject to the California Public Utilities
Commission’s (CPUC) General Order 131-D1. If the construction, modification, or relocation of
transmission lines results in significant environmental impacts, they should be identified and
discussed in the Draft EIR, specifically as it relates to aesthetics, biological resources (e.g., nesting
birds), transportation, noise, and air quality. As mentioned, If the analysis is not included, SCE
may be required to pursue a separate, mandatory CEQA review through the CPUC, which could
delay approval of the SCE portion of the project for two years or longer.
Response
The Project would not require the construction, modification, or relocation of transmission lines,
or electrical facilities that are designed to operate at or above 50 kilovolts (kV). As noted in the
response to Comment SCE-2 above, electricity is delivered to the Project site through above-
ground telephone poles adjacent to the south side of Airport Avenue. At strategic locations (i.e.,
at the existing bathroom/maintenance building and at a pad-mounted transformer at west driveway
entrance to the existing parking lot), power lines run underneath Airport Avenue and into Airport
Park, where electricity is distributed throughout the park in 110-volt transmission lines. While the
voltage of the transmission lines along the south side of Airport Avenue is unknown, they would
not require modification to accommodate the Project’s standard-voltage distribution system. The
environmental impacts associated with Project construction, including those associated with the
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
installation of new on-site electrical facilities, are discussed throughout the Draft EIR. As
concluded therein, Project construction would result in either a less than significant impact or a
less than significant impact with the implementation of mitigation measures. Therefore, no
corrections or addition to the Draft EIR, or further response, is required.
Comment SCE-3
General Order 95
SCE must comply with General Order (GO) 95, which establishes rules and regulations for the
overhead line design, construction, and maintenance. GO 95 also includes vertical clearance
requirements from thoroughfares, ground, and railroads, as well as specific minimum clearances
from tree branches and vegetation around overhead wires. The project’s landscaping should not
conflict with SCE’s existing and proposed transmission line designs.
Response
As noted in the response to Comment SCE-1 above, the Project site and surrounding vicinity does
not contain any SCE Right-of-Way. Electricity is delivered to the Project site through existing
above-ground telephone poles adjacent to the south side of Airport Avenue. At strategic locations
(i.e., at the existing bathroom/maintenance building and at a pad-mounted transformer at west
driveway entrance to the existing parking lot), power lines run underneath Airport Avenue and
into Airport Park, where it is then distributed throughout the park in 110-volt transmission lines.
As these existing facilities would remain in place and would not be obstructed by Project
development or landscaping, the Project would not conflict with SCE’s existing transmission lines
and would maintain accessibility to these existing facilities. However, as further noted in the
response to Comment SCE-1 above, new facilities (i.e., underground electrical lines, pad-mounted
transformers) may need to be installed onsite to connect the expanded park facilities to the existing
SCE distribution infrastructure. During the final design process, the City would coordinate closely
with SCE to determine the appropriate connection points and equipment required, including
sending five sets of Project plans to the address listed in the Comment SCE-1. The City looks
forward to coordinating with SCE during final project design and implementation to avoid
interference with SCE’s ability to access, maintain, and operate its current and future facilities in
the Project vicinity. As this comment does not raise a concern regarding the adequacy of the Draft
EIR, no corrections or addition to the Draft EIR, or further response, is required.
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
Comment SCE-4
Method of Service
In order to determine electrical infrastructure necessary to support the proposed project, the project
proponent must submit a signed Method of Service agreement to SCE and pay engineering fees
for an electric service study to be completed. Infrastructure necessary to support this project is
subject to licensing and permitting authority of the CPUC. SCE appreciates the opportunity to
comment on the proposed Airport Park Expansion Project. SCE looks forward to working and
collaborating with the City. If you have any questions regarding this letter, please contact me at
heather.neely@sce.com or 626.476.7839.
Response
As noted in the response to Comment SCE-1 above, new facilities (i.e., underground electrical
lines, pad-mounted transformers) may need to be installed to connect the expanded park facilities
to the existing SCE distribution infrastructure. During the design process, the City would closely
coordinate with SCE to determine the appropriate connection points and equipment required,
including sending five sets of Project plans to the address listed in the Comment SCE-1, as well
as submitting a signed Method of Services agreement to SCE and the payment of engineering fees
for an electric service study to be completed. The City looks forward to coordinating with SCE
during final project design and implementation to submit all required documentation and
payments, as described above. As this comment does not raise a concern regarding the adequacy
of the Draft EIR, no corrections or addition to the Draft EIR, or further response, is required.
Letter VB
November 6, 2017
Vincent Balembois
Comment VB-1
Hello- I received the notice regarding the Airport Park expansion and I was wondering why there
is no addition of any basketball courts. Basketball is a very popular sport in Los Angeles and lots
of people want a place to play.
Response
Thank you for your interest in the recreational amenities proposed by the Project. As discussed in
Section 1.2, Project Background, of the Draft EIR, the recreational amenities proposed by the
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
Project are based on community feedback into the design of the park expansion. Specifically, a
community event was held on June 18, 2016, at the existing Airport Park, attended by
approximately 106 people, in which three park concept schemes were presented. Prior to the event,
City Staff sent email announcements and reminders to the City's parks interest list that includes
several thousand community members and all neighborhood organizations. Based on the
presentation and a survey, written input was gathered at this event, as well as online until July 10,
2016.
Between the community meeting and associated survey, a total of 689 responses were obtained
from both the community event and online feedback. From the feedback, the top chosen amenities
included sports fields (802 points), playgrounds (459), gardens/landscape (455), wildlife habitat
(450), and promenades (392). Between open space and sports fields, 430 respondents indicated a
preference of maximizing sports fields, while 120 respondents indicated a preference for more
open space. Additional written suggestions for amenities included walking, running,
skateboarding, and biking paths, concessions opportunities, and improved pedestrian access.
Comments indicated a need for non-field sports, shading, community gardens, and improvements
to the existing Donald Douglas Loop South roadway.
Therefore, although basketball is a very popular sport in Los Angeles, it was not strongly identified
as a desired amenity at Airport Park, which was designed to be responsive to the community input
received on the Project. As this comment does not raise a concern regarding the adequacy of the
Draft EIR, no corrections or addition to the Draft EIR, or further response, is required. However,
your comment is included in the EIR’s administrative record for consideration by decision-makers
prior to adoption of the Project and certification of the Final EIR.
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
Letter JA
November 30, 2017
John Ayers
Comment JA-1
Writing with interest in learning more about the airport2Park project.
Supportive - just want to learn more.
Please provide information as to how the number of parking spaces were determined to
accommodate the new space.
Response
Thank you for your interest in long-term park planning in the City, as well as the amount of parking
provided for the expansion of Airport Park. The Project includes 5.8 acres of SMO property;
therefore, comments on planning efforts for areas outside the Project are not the topic of this EIR.
Also, the City is not currently engaged in planning for expansion of recreational uses within SMO
beyond the Project site; however, SMO is planned to close in 2028. Future use of SMO post-
closure would be subject to a separate planning process with the City and would involve outreach
to the community at a later date.
Although parking is not a topic required to be analyzed by the California Environmental Quality
Act (CEQA), it is the City’s intent that the proposed number of parking spaces is adequate to
accommodate the park expansion. The number of parking spaces is based on a Draft Parking Study
for Santa Monica Airport (Parking Study) prepared by Gibson Transportation in February 2017.
As concluded in Chapter 3, Typical Event Parking Conditions, of the Parking Study, while the two
parking lots at Airport Park may occasionally be fully utilized following implementation of the
Project, there is more than adequate parking available in the immediate vicinity of the Project Site
to accommodate the projected demand. Parking lots in the immediate vicinity with excess parking
capacity include Parking Areas 3 and 4, located south across Airport Avenue from the Airport
Park. As this comment does not raise a concern regarding the adequacy of the Draft EIR, no
corrections or addition to the Draft EIR, or further response, is required. However, your comment
is included in the EIR’s administrative record for consideration by decision-makers prior to
adoption of the Project and certification of the Final EIR.
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
Comment JA-2
Please provide information as to how the new space will increase or decrease traffic in the area.
Bundy, Walgrove, Beethoven, Airport, etc.
Response
Section 3.7, Transportation and Traffic, of the Draft EIR evaluates the Project’s impacts on traffic
in the proximity of Airport Park. As discussed under Impact T-2, the Project would result in a
significant increase in traffic at Intersection No. 6 (23rd Street & Dewey Street) during the p.m.
peak period, Intersection No. 7 (23rd Street & Walgrove Avenue) during the A.M. peak period, and
Intersection No. 10 (Bundy Drive & Ocean Park Boulevard) during the P.M. peak period during
the Approval Year (2107) Plus Project Scenario. These intersections would also experience a
significant impact under the Future Year (2025) Plus Project Scenario, as would the Intersection
No. 12 (Centinela Avenue & Airport Avenue) during the P.M. peak period. Additionally, the
Project would result in significant impacts at two roadway segments: Roadway Segment No. 1
(23rd Street north of Dewey Street) and Roadway Segment No. 2 (23rd Street south of Dewey
Street). Due to physical limitations (i.e., no available right-of-way to accommodate improvements)
and requirements by the Santa Monica Fire Department to maintain emergency vehicle access, no
feasible mitigation measures are available to reduce these significant impacts associated with
increased traffic during peak hours. As a result, the Draft EIR concludes that the Project would
result in significant and unavoidable impacts at these intersections and roadway segments. As this
comment does not raise a concern regarding the adequacy of the Draft EIR, no corrections or
addition to the Draft EIR, or further response, is required. However, your comment is included in
the EIR’s administrative record for consideration by decision-makers prior to adoption of the
Project and certification of the Final EIR.
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Comment JA-3
What is the schedule?
When does airport cease operation.
Project Start date(break ground)?
Completion date (ribbon cutting)?
Response
Thank you for your interest in the Project’s schedule. The Project’s schedule is dependent on
availability of City funds. For the purposes of this EIR, a conservative project schedule is provided
in Section 2.5, Construction Activities, of the Draft EIR. As discussed therein, if funds are
available, construction could begin as early as 2019, with the expanded portion of the park open
to the public in 2020. The majority of existing Airport Park would be open to the public during the
expansion of project. The closure of Santa Monica Airport is an independent action unrelated to
the Project. However, as discussed in Section 2.2.4, Existing Airport Operations, on February 1,
2017, a consent decree between the City and the Federal Aviation Administration (FAA) was
approved. The agreement established that the City would be able to close SMO by 2028 and
shorten the runway from 4,973 feet in length to 3,500 feet to reduce the number of flight operations
at the airport. Airport runway shortening was recently completed at the end of December 2017. As
this comment does not raise a concern regarding the adequacy of the Draft EIR, no corrections or
addition to the Draft EIR, or further response, is required. However, your comment is included in
the EIR’s administrative record for consideration by decision-makers prior to adoption of the
Project and certification of the Final EIR.
Comment JA-4
What is the budget/estimated cost?
Response
Thank you for your interest in the estimated cost of the Project. As discussed in Section 1.4, EIR
Purpose and Legal Authority, of the Draft EIR, the Draft EIR was prepared in accordance with the
Guidelines for Implementation of the California Environmental Quality Act (CEQA). CEQA does
not require disclosure of Project cost as part of the environmental analysis. Further, at this time,
the cost of construction is unknown. Following City Council approval of the Project and
certification of the Final EIR, the City Community & Cultural Services Department would issue a
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9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
Request for Bid to receive bids for the construction cost of the Project. Each bid would include an
estimated construction cost. The Community & Cultural Services Department would approve the
bid with the best attributes, including cost. As this comment does not raise a concern regarding the
adequacy of the Draft EIR, no corrections or addition to the Draft EIR, or further response, is
required. However, your comment is included in the EIR’s administrative record for consideration
by decision-makers prior to adoption of the Project and certification of the Final EIR.
Comment JA-5
Anything that will improve traffic in the area is greatly appreciated!!! As the growth of Santa
Monica and Playa Vista has dramatically decreased the quality of all of the surrounding
communities due to volume of people, traffic, speeding, cut-thru congestion, etc.
Oh - by the way did I mention the traffic congestion in the area?
Response
Section 3.7, Transportation and Traffic, of the Draft EIR thoroughly evaluates the Project’s
impacts on traffic in the proximity of Airport Park. The Project would generate traffic and cause
congestion during construction from equipment; however, as addressed under Impact T-1, within
mitigation requiring a construction traffic management plan to control construction traffic, impacts
would be less than significant. During operation of the park, as discussed under Impact T-2, the
Project would result in a significant increase in traffic at Intersection No. 6 (23rd Street & Dewey
Street) during the p.m. peak period, Intersection No. 7 (23rd Street & Walgrove Avenue) during
the A.M. peak period, and Intersection No. 10 (Bundy Drive & Ocean Park Boulevard) during the
P.M. peak period during the Approval Year (2107) Plus Project Scenario. These intersections would
also experience a significant impact under the Future Year (2025) Plus Project Scenario, as would
the Intersection No. 12 (Centinela Avenue & Airport Avenue) during the P.M. peak period.
Additionally, the Project would result in significant impacts at two roadway segments: Roadway
Segment No. 1 (23rd Street north of Dewey Street) and Roadway Segment No. 2 (23rd Street south
of Dewey Street). Due to physical limitations (i.e., no available right-of-way to accommodate
improvements) and requirements by the Santa Monica Fire Department to maintain emergency
vehicle access, no feasible mitigation measures are available to reduce these significant impacts.
As a result, the Draft EIR concludes that the Project would result in significant and unavoidable
impacts at these intersections and roadway segments.
As disclosed in Section 3.7.1, Environmental Setting, of the Draft EIR, the Airport Avenue
Improvement Project is a planned project (unrelated to the Project) along Airport Avenue from
Airport Park Expansion Project 9-13
Final EIR – January 2018
9.0 RESPONSE TO COMMENTS ON THE DRAFT EIR
South Bundy Drive to 23rd Street. This Project is anticipated to include sidewalk improvements,
bike lanes, retaining walls, striped crosswalks and curb ramps, street lighting, street trees, and
amenities such as benches, signage and trash containers. When completed, this Project will
improve pedestrian and bicycle connectivity between the Project vicinity and neighborhoods north
and west of Santa Monica Airport in the vicinity of the Project site. As this comment does not raise
a concern regarding the adequacy of the Draft EIR, no corrections or addition to the Draft EIR, or
further response, is required. However, your comment is included in the EIR’s administrative
record for consideration by decision-makers prior to adoption of the Project and certification of
the Final EIR.
Airport Park Expansion Project 9-14
Final EIR – January 2018
Airport Park Expansion Project 10-1
Final EIR – January 2018
10.0 CORRECTIONS AND ADDITIONS
As required by Section 15088 of the CEQA Guidelines, this section provides a summary of
corrections or clarifications to the Draft EIR. None of the corrections and additions constitutes
significant new information or substantial project changes as defined by Section 15088.5 of the
CEQA Guidelines. Corrections and additions to the Draft EIR are provided below in underline or
strikeout text as needed to indicate an addition or deletion, respectively. Minor typographical errors
are not listed below in this section; however, all changes are presented throughout the Final EIR
document in underline and strikeout format.
SECTION 3.4 HAZARDS AND HAZARDOUS MATERIALS
Page 3.4-19, the following paragraph has been added under the “State Policies and Regulations”
subheading:
The Handbook also establishes six Safety Zones to reduce airport hazards to nearby uses. Safety
zones are based, in general, on historical accident location patterns for all airports, together with
consideration for where aircraft fly and how they are being operated during takeoff departures a
The Handbook also establishes six Safety Zones to reduce airport hazards to nearby uses. Safety
zones are based, in general, on historical accident location patterns for all airports, together with
consideration for where aircraft fly and how they are being operated during takeoff departures and
landing approaches. Compatible land uses and development standards are then established for each
Safety Zone, with the goal of protecting people on the ground and in the air from accidents.
According to the Handbook, Runway 3/21 at SMO is considered a Medium General Aviation
Runway (runway length of 4,000–5,999). Based on dimensions established in the Handbook,
portions of the Project site are currently within the Sideline Safety Zone (Zone 5), which extends
500 feet from the runway edge for a Medium General Aviation Runway. The risk level is
considered low to moderate in Zone 5, with the most common accident type being aircraft losing
directional control and veering off the side of the runway. The basic compatibility standards
recommend prohibiting stadiums and group recreational uses in Zone 5, although neither the
Handbook or FAA guidelines specifically define what is considered a group recreational use.
Following completion of the Runway Shortening Project, Runway 3/21 at SMO would 3,500 feet
in length, and therefore, classified as a Short General Aviation Runway (runway length less than
4,000 feet) by the Handbook. Although the size and location of safety zones following the Runway
Shortening Project would ultimately be determined through coordination between the City and
ALUC, in general, Zone 5 extends 250 feet from the runway edge for a Short General Aviation
Runway. No portion of the Project site is located within 250 feet of the runway edge.
10.0 CORRECTIONS AND ADDITIONS
10-2 Airport Park Expansion Project
Final EIR – January 2018
Page 3.4-37, the third paragraph under Impact HAZ-4 that discusses the Project’s relationship to
established airport safety zones has been amended as follows:
The Project site is outside of the general approach areas of the runway. Therefore, no resultant
substantial physical airport-related safety hazards would occur as result of Project implementation.
At SMO, there is an RPZ that encompasses an area of 150 feet on either side of the runway center
line. The northern boundary of the Project site is outside of this RPZ, and no structures, recreational
amenities, or sports fields associated with the Project fall within this RPZ. The Project is also
subject to policies regarding airport safety and development restrictions in RPZs. The Project
would not increase the number of structures within the flight path or RPZs. As discussed above,
portions of the Project site are located within the Sideline Safety Zone (Zone 5) based on the
current length of Runway 3/21. According to the Handbook, stadiums and group recreational uses
are generally prohibited within Zone 5. However, the Project has been designed to place non-
recreational features such as the parking lot, restrooms, and acoustical berm closest to the runway.
The Project’s proposed recreational uses such as the two sports fields would be located outside of
Zone 5, which extends 500 feet from the runway edge for a Medium General Aviation Runway.
Following completion of the Runway Shortening Project, SMO Runway 3/21 would be considered
a Short General Aviation Runway per the guidelines of the Handbook, and it is expected that all
safety zones would be reduced in size to match the Handbook’s guidelines for a Short General
Aviation Airport. For a Short General Aviation Airport, Zone 5 generally extends 250 feet from
the edge of the runway, under which no portion of the Project site would be located within the
runway’s Sideline Safety Zone. In addition, the Project would require a FAA Part 77 Clearance
Permit to be submitted and approved by the FAA to ensure airport land use compatibility; to avoid
new development that may cause airspace obstructions; and to reduce safety risks associated with
airport hazards and accidents. The worst-case scenarios for airport safety hazards would likely be
a busy weekend day when the park hosts sports events (large gatherings); and when SMO sees the
most recreational/training flying activity (most risky). Because of the Project’s proximity to SMO
but outside of the flight path, the potential for aircraft accidents to occur at the park that would
cause a safety hazard for people recreating or working within the Project site is considered remote.
SECTION 3.7 TRANSPORTATION AND TRAFFIC
Page 3.7-67, the discussion of cumulative impacts to alternative transportation has been revised
as follows:
Alternative transportation access from the City’s neighborhoods to the Project site is somewhat
limited. However, with the incorporation of MM T-2 through MM T-4, in conjunction with the
implementation of the Airport Avenue Improvement Project, connectivity is expected to greatly
10.0 CORRECTIONS AND ADDITIONS
Airport Park Expansion Project 10-3
Final EIR – January 2018
improve over the next several years. The Airport Avenue Improvement Project planned along
Airport Avenue from South Bundy Drive to 23rd street would improve pedestrian and bikeway
connectivity near the Project site and would encourage the use of alternative transportation modes.
As part of the Airport Avenue Improvement Project, new 8-foot sidewalks would be installed on
both sides of the street, a new two-way 12-foot wide bicycle lane would be constructed on the
north side of Airport Avenue, and crosswalk improvements would be installed from the SMC Arts
Campus to 23rd Street (see Figure 3.7-6). Additionally, retaining walls, striped crosswalks, curb
ramps, street lighting, street trees, and amenities such as benches, signage and trash containers
would be installed to improve the pedestrian and bicyclist experience (see Figure 3.7-6). When the
Airport Avenue Improvement Project is complete (estimated completion in late 2019, in
conjunction with the Project), the Project Site would be linked to the Sunset Park Neighborhood
and the existing City bike network through Class II or better bicycle facilities. Implementation of
the Airport Avenue Improvement Project would ensure compliance with LUCE and TDM
guidance to support alternative transportation modes through pedestrian-friendly design
With the possibility of revised schedules and routing, implementation of MM T-3 could improve
Big Blue Bus service to the Project site. Implementation of MM T-4 could improve bicycle
connectivity by constructing a north-south bike path following the closure of SMO, and could
encourage bicycling with the addition of amenities such as showers and storage. Additonally, MM
T-4 proposes the expansion of the Breeze Bike Share Program by adding additional spaces at the
existing station and extending the program into nearby neighborhoods to further encourage
bicycling to the site. With other planned and pending transit and bike path improvements,
including those outlined in the Santa Monica Bike Action Plan, transportation service and options
within the City would be expanded. Therefore, the Project’s contribution to cumulative impacts
would be less than significant.
10.0 CORRECTIONS AND ADDITIONS
10-4 Airport Park Expansion Project
Final EIR – January 2018
This page intentionally left blank.
Airport Park Expansion Project 11-1
Final EIR – January 2018
11.0 MITIGATION MONITORING AND REPORTING PROGRAM
The following Mitigation Monitoring and Reporting Program (MMRP) provides a summary of
each Mitigation Measure (MM) for the proposed Airport Park Expansion Project (Project) and
the monitoring implementation responsibility for each measure. The MMRP for the Project will
be in place through all phases of the Project, including design, construction, and operation.
11.1 PURPOSE
The purpose of the MMRP is to ensure that measures provided in the Environmental Impact
Report (EIR) to minimize or avoid significant adverse effects are implemented. The MMRP can
also act as a working guide to facilitate not only the implementation of MMs by the City, but
also the monitoring, compliance, and reporting activities of the implementing agency and any
monitors it may designate.
11.2 RESPONSIBILITIES
The City of Santa Monica Department of Planning and Community Development (Planning
Department) will act as the Lead Agency for implementing and approving the program of
reporting and monitoring for the implementation of approved MMs for this Project, to ensure that
the adopted MMs are implemented as defined in this EIR. For each MMRP activity, the Planning
Department will either administer the activity or delegate it to staff, other City departments (e.g.,
Department of Building and Safety, Department of Public Works, etc.), consultants, or
contractors. The Planning Development would also ensure that monitoring is documented as
required and that deficiencies are promptly corrected. The designated environmental monitor,
which depends on the provision specified below (e.g., City building inspector, project contractor,
certified professionals, etc.,), would track and document compliance with MMs, note any
problems that may result, and take appropriate action to remedy problems. The Planning
Department or its designee(s) will ensure that each person delegated any duties or
responsibilities is qualified to monitor compliance.
As the applicant, the City of Santa Monica Community & Cultural Services Division is
responsible for funding all the MMs in the MMRP, and is responsible for assuring that these
requirements are met by all of its construction contractors and field personnel. Standards for
successful mitigation of impacts are implicit in many MMs that include such requirements as
obtaining permits or avoiding a specific impact entirely. Other MMs include detailed success
criteria. Additional mitigation success thresholds will be established by applicable agencies with
jurisdiction through the permit process and through the review and approval of project specific
plans for the implementation of MMs.
11.0 MITIGATION AND MONITORING REPORTING PROGRAM
11-2 Airport Park Expansion Project
Final EIR – January 2018
11.3 MONITORING PROCEDURES
Many of the monitoring procedures will be conducted during the construction phase of the
Project. The Planning Department or its designee(s) and the environmental monitor(s) are
responsible for integrating the mitigation monitoring procedures into the construction process. To
oversee the monitoring procedures and to ensure success, the environmental monitor assigned to a
monitoring action must be on site during the applicable portion of construction that has the
potential to create a significant environmental impact or other impact for which mitigation is
required. The environmental monitor is responsible for ensuring that all procedures specified in
the monitoring program are followed.
Site visits and specified monitoring procedures performed by other individuals will be reported to
the environmental monitor assigned to the relevant construction phase. A monitoring record form will
be submitted to the environmental monitor by the individual conducting the visit or procedure so
that details of the visit can be recorded and progress tracked by the environmental monitor. A
checklist will be developed and maintained by the environmental monitor to track all procedures
required for each mitigation measure and to ensure compliance with the timing specified for the
procedures. The environmental monitor will note any problems that may occur and take appropriate
action as directed by the Planning Department to rectify the problem.
11.4 MONITORING TABLE
For each MM, Table 11-1 identifies 1) the full text of the MM; 2) the action(s) that needs to be
performed, including the applicable timing; 3) the entity responsible for performing the action;
and 4) the agency responsible for verifying compliance.
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Table 11-1. Mitigation Monitoring and Reporting Program
Avoidance and Minimization Measure Monitoring/ Reporting
Action
Monitoring
Party Responsible Agency
Air Quality
No avoidance and minimization measures for this impact area. N/A N/A N/A
Construction Effects
MM HAZ-1, MM HAZ 2, MM NOI-1, and MM T-1 would apply for this impact area.
See MM HAZ-1,
MM HAZ-2,
MM NOI-1, MM T-1
See MM HAZ-1,
MM-HAZ-2,
MM NOI-1,
MM T-1
See MM HAZ-1,
MM HAZ-2,
MM NOI-1, MM T-1
Greenhouse Gas Emissions
No avoidance and minimization measures are required for this impact area. N/A N/A N/A
Hazards and Hazardous Materials
MM HAZ-1. Prior to the start of construction, the contractor shall conduct a
comprehensive survey of lead based paint (LBP) and asbestos containing materials
(ACM). If such hazardous materials are found to be present, the contractor shall follow all
applicable local, state and federal regulations, including compliance with SCAQMD
Rule 1403 as well as best management practices related to the treatment, handling, and
disposal of LBP and ACM.
Completion of an ACM
and LBP survey prior to
construction; abatement
if necessary
City of Santa
Monica
Community &
Cultural Services
Division; licensed
contractor(s)
South Coast Air
Quality Management
District and the City of
Santa Monica
Planning &
Community
Development
Department, Building
and Safety Division
MM HAZ-1b Hazardous Materials Contingency Plan. Prior to the start of excavation
or grading in areas of known soils contamination, the construction contractor shall submit
a Soils Management Plan and a Transportation Plan to the appropriate cleanup agency
(e.g., Los Angeles Regional Water Quality Control Board [LARWQCB], Department of
Toxic Substances Control [DTSC], Santa Monica Fire Department [SMFD]) for review
and approval. The Soils Management Plan and Transportation Plan shall include the
following tasks.
Approval of Soils
Management Plan and
Transportation Plan prior
to construction; routine
site inspections during
Project construction.
City of Santa
Monica
Community &
Cultural Services
Division; City of
Santa Monica
Office of
Sustainability or
City of Santa Monica
Planning &
Community
Development
Department, Building
and Safety Division;
Los Angeles Regional
Water Quality Control
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Table 11-1. Mitigation Monitoring and Reporting Program
Avoidance and Minimization Measure Monitoring/ Reporting
Action
Monitoring
Party Responsible Agency
Soils Management Plan
Affected soils shall be either directly loaded into awaiting trucks for immediate offsite
disposal or temporarily stockpiled on plastic sheeting prior to load-out and offsite
disposal. If temporarily stockpiled, soil removed from the excavations shall be placed
next to or as close as possible to the excavation from which it came.
Prior to load-out, the construction contractor shall prepare waste profiles and example
waste manifests for approval by the receiving facilities. Soil and material segregation,
stockpile handling, truck loading, and storm water management practices shall be
followed during the remedial action according to the following.
Soil and Material Segregation
Overburden soils shall be screened with an organic vapor analyzer (OVA) in accordance
with South Coast Air Quality Management District (SCAQMD) Rule 1166. Any affected
soils shall be segregated and disposed of in accordance with federal, state, and local
regulations.
Stockpile Management
Any stockpiled soils for load-out shall be segregated by waste classification:
•Nonhazardous waste.
•Volatile Organic Compound (VOC)-contaminated nonhazardous waste with OVA
readings greater than 50 parts per million (ppm) but less than 1,000 ppm.
•VOC-contaminated nonhazardous waste with OVA readings of 1,000 ppm or
greater. These soils shall be immediately sprayed with water or suppressant and
placed in a sealed container (roll-off bin) or directly loaded into a suitable transport
truck, moistened with water, and covered with a tarp for offsite transportation to
the appropriate disposal facility, as specified in the SCAQMD Rule 1166
Mitigation Plan.
The temporary stockpiles containing affected soils shall be managed as follows:
•The temporary stockpiles for non-VOC contaminants shall be placed on plastic
Santa Monica Fire
Department
Board, Department of
Toxic Substances
Control; Santa Monica
Fire Department
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Table 11-1. Mitigation Monitoring and Reporting Program
Avoidance and Minimization Measure Monitoring/ Reporting
Action
Monitoring
Party Responsible Agency
sheeting and kept moist during working hours and covered with plastic sheeting at
the end of the day to control dust.
•The VOC-contaminated stockpiles shall be placed on plastic sheeting and
immediately covered with plastic sheeting. The edges of the plastic shall have an
overlap of at least 24 inches. The plastic shall be secured at the base of the
stockpile and along the seams of overlapping plastic sheeting with sandbags or
equivalent means. The stockpiles shall remain covered until load-out.
•Daily inspections of the stockpiles shall be conducted to verify the integrity of the
stockpile covers. Any gaps, tears, or other deficiencies shall be corrected
immediately. Daily records shall be kept of stockpile inspections and any repairs
made.
•If necessary, commercial vapor suppressants and sealants shall be prepared and
applied to VOC-contaminated soil in accordance with the manufacturer’s
recommendations.
•During stockpile generation and removal, only the working face of the stockpile
shall be uncovered.
Decontamination Methods and Procedures
Each piece of equipment used for the excavation of affected soils shall have a clean-out
bucket or continuous edge across the cutting face of its bucket. No excavation of affected
soil shall be permitted with equipment utilizing teeth across the cutting edge of its bucket.
Entry to the contaminated areas (i.e., work exclusion zones) shall be limited to avoid
unnecessary exposure and related transfer of contaminants. In unavoidable circumstances,
any equipment or truck(s) that come into direct contact with affected soil shall be
decontaminated to prevent the onsite and offsite distribution of contaminated soil. The
decontamination shall be conducted within a designated area by brushing off equipment
surfaces onto plastic sheeting. Trucks shall be visually inspected before leaving the site,
and any dirt adhering to the exterior surfaces shall be brushed off and collected on plastic
sheeting. The storage bins or beds of the trucks shall be inspected to ensure the loads are
properly covered and secured. Excavation equipment surfaces shall also be brushed off
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Table 11-1. Mitigation Monitoring and Reporting Program
Avoidance and Minimization Measure Monitoring/ Reporting
Action
Monitoring
Party Responsible Agency
prior to removing the equipment from contaminated areas.
Movement of affected soils from the excavation area to temporary stockpiles shall be
conducted using enclosed transfer trucks, if possible. If affected soils must be moved
within an open receptacle (e.g., loader bucket), the travel path for the loader shall be
scraped following this activity, with scraped soils placed in the temporary stockpile for
load-out.
Sampling equipment that comes into direct contact with potentially contaminated soil or
water shall be decontaminated to assure the quality of samples collected and/or to avoid
cross-contamination. Disposable sampling equipment intended for one-time use shall not
be decontaminated, but shall be packaged for appropriate offsite disposal.
Decontamination shall occur prior to and after each designated use of a piece of sampling
equipment, using the following procedures:
•Nonphosphate detergent and tap-water wash, using a brush if necessary.
•Tap-water rinse.
•Initial deionized/distilled water rinse.
•Final deionized/distilled water rinse.
Truck Loading
Trucks may be loaded directly from the excavation or temporary stockpile based on truck
availability and excavation logistics. Trucks shall be routed and stockpile areas shall be
located so as to avoid having trucks pass through impacted areas. The truckloads shall be
wetted and tarped prior to exiting the site. All soil hauled from the site shall comply with
the following:
•Materials shall be transported to a Class II landfill in accordance with applicable
rules and regulations for the handling and disposal of hazardous materials. If
contamination in the soils is at or above regulatory levels, the Department of Toxic
Substances Control (DTSC) shall be contacted and notified to determine
appropriate action.
•No excavated material shall extend above the sides or rear of the truck/trailer.
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Table 11-1. Mitigation Monitoring and Reporting Program
Avoidance and Minimization Measure Monitoring/ Reporting
Action
Monitoring
Party Responsible Agency
•Trucks/trailers carrying affected soils shall be completely tarped/covered to prevent
particulate emissions to the atmosphere. Prior to covering/tarping, the surface of
the loaded soil shall be moistened.
•The exterior of the trucks/trailers shall be cleaned off prior to leaving the site to
eliminate tracking of material offsite.
Storm Water Management
The good housekeeping practices prescribed in the City’s Urban Runoff Mitigation Plan
(Municipal Code Section 7.10.060) shall be implemented during soil excavation activities
to contain and control storm water runoff that might convey contaminated or excessive
sediments. If rainfall is expected, the areas around open excavations shall be graded and
bermed to prevent storm water from flowing into the excavation. Any standing water that
collects in the bottom of the excavations shall be removed and handled in accordance with
federal, state, and local regulations. The water shall be sampled and analyzed either as
standing water in the excavation or following containment in a temporary above-ground
storage tank. Depending on the volume of water and the sampling results, options for
handling the standing water could include:
•Pumping the standing water into temporary above-ground storage tanks for reuse
onsite for dust suppression.
•Pumping the standing water through filters and a carbon adsorption filter (if
required based on analytical results) prior to discharge to a storm drain, subject to
approval by the City of Santa Monica Water Resources Protection Programs
Division.
•Pumping the standing water into vacuum trucks for transport and disposal at a
recycling facility.
Transportation Plan
All affected soils shall be transported offsite for lawful management and disposal. Prior to
load-out, the construction contractor shall prepare waste profiles for the receiving facility
using analytical data from the previous environmental site assessment
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Table 11-1. Mitigation Monitoring and Reporting Program
Avoidance and Minimization Measure Monitoring/ Reporting
Action
Monitoring
Party Responsible Agency
On-Site Soils Remediation Plan
If remediation for contaminated soils remaining on site is required, all remediation
activities shall be accomplished in a manner that reduces risk to below applicable
standards and shall be completed prior to opening the park to the public. Closure report or
other reports regarding investigation and/or remediation activities regarding contaminated
soil shall be submitted to DTSC for review and approval. Approved reports that document
the successful completion of required remediation activities for contaminated soils shall
be submitted to the DTSC prior to opening the park to the public.
Land Use and Planning
No avoidance and minimization measures for this impact area. N/A N/A N/A
Noise
MM NOI-1 Construction Noise Management Plan. A Construction Noise Management
Plan shall be implemented during Project construction. The Plan would address noise and
vibration impacts and outline measures that would be used to reduce impacts. Measures
would include:
• To the extent that they exceed the applicable construction noise limits, excavation,
foundation-laying, and conditioning activities shall be restricted to between the
hours of 10:00 AM and 3:00 PM, Monday through Friday, in accordance with
Section 4.12.110(d) of the Santa Monica Municipal Code.
• The construction contracts shall require implementation of the following
construction best management practices (BMPs) by all construction contractors
and subcontractors working in or around the Project site to reduce construction
noise levels:
o Contractors and subcontractors shall ensure that construction equipment is
properly muffled according to manufactures specifications or as required by
the City’s Department of Building and Safety, whichever is the more stringent.
o Contractors and subcontractors shall place noise-generating construction
equipment and locate construction staging areas away from sensitive uses,
Approval of
Construction Noise
Management Plan prior
to construction;
implementation of plan
during construction,
including written
confirmation from on-
site construction
manager that noise
attenuation techniques
are used to reduce noise
levels.
City of Santa
Monica
Community &
Cultural Services
Division; City of
Santa Monica
Planning &
Community
Development
Department; on-
site construction
manager.
City of Santa Monica
Community &
Cultural Services
Division; City of Santa
Monica Planning &
Community
Development
Department
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Table 11-1. Mitigation Monitoring and Reporting Program
Avoidance and Minimization Measure Monitoring/ Reporting
Action
Monitoring
Party Responsible Agency
where feasible, to the satisfaction of the Department of Building and Safety.
o Contractors and subcontractors shall implement noise attenuation measures
which may include, but are not limited to, noise barriers or noise blankets to
the satisfaction of the City’s Department of Building and Safety.
•Contracts with its construction contractors and subcontractors shall include the
requirement that construction staging areas, construction worker parking and the
operation of earthmoving equipment within the project site, are located as far away
from vibration- and noise-sensitive sites as possible. Contract provisions
incorporating the above requirements shall be included as part of the Project’s
construction documents.
•Contract specifications shall instruct that heavily loaded trucks used during
construction shall be routed away from residential streets to the extent possible.
Contract specifications shall be included in the Project’s construction documents.
Transportation and Traffic
MM T-1. The City shall prepare, implement and maintain a Construction Impact
Mitigation Plan for review and approval prior to issuance of a building permit to address
manage traffic during construction and shall be designed to:
•Prevent traffic impacts on the surrounding street network
•Minimize parking impacts both to public parking and access to private parking to
the greatest extent practicable
•Ensure safety for both those constructing the Project and the surrounding
community
•Prevent substantial truck traffic through residential neighborhoods
•Provide for coordination with adjacent or nearby construction Projects
The Construction Impact Mitigation Plan shall be subject to review and approval by the
following City departments: Public Works, Fire, Planning & Community Development,
and Police to ensure that the Plan has been designed in accordance with this mitigation
measure and meets City standards. This review shall occur prior to issuance of grading or
Review and approval of
the Construction Impact
Mitigation Plan prior to
construction; routine site
inspection during Project
construction.
City of Santa
Monica
Departments,
including Public
Works, Fire,
Planning &
Community
Development, and
Police; on-site
construction
manager.
City of Santa Monica
Community &
Cultural Services
Division; City of Santa
Monica Planning &
Community
Development
Department,
Transportation
Division
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Table 11-1. Mitigation Monitoring and Reporting Program
Avoidance and Minimization Measure Monitoring/ Reporting
Action
Monitoring
Party Responsible Agency
building permits. It shall, at a minimum, include the following:
Ongoing Requirements throughout the Duration of Construction
•A detailed Construction Impact Mitigation Plan for work zones shall be
maintained. At a minimum, this shall include parking and travel lane
configurations; warning, regulatory, guide, and directional signage; and area
sidewalks, bicycle lanes, and parking lanes. The plan shall include specific
information regarding the Project’s construction activities that may disrupt normal
pedestrian and traffic flow and the measures to address these disruptions. Such
plans shall be reviewed and approved by the Strategic and Transportation Planning
Division prior to commencement of construction and implemented in accordance
with this approval.
•Work within the public right-of-way shall be performed between 9:00 AM and
4:00 PM. This work includes dirt and demolition material hauling and construction
material delivery. Work within the public right-of-way outside of these hours shall
only be allowed after the issuance of an after-hours construction permit.
•Streets and equipment shall be cleaned in accordance with established Public
Works Department requirements.
•Trucks shall only travel on a City-approved construction route. Truck
queuing/staging shall not be allowed on Santa Monica streets. Limited queuing
may occur on the construction site itself.
•Materials and equipment shall be minimally visible to the public; the preferred
location for materials is to be onsite, with a minimum amount of materials within a
work area in the public right-of-way, subject to a current Use of Public Property
Permit.
•Any requests for work before or after normal construction hours within the public
right-of-way shall be subject to review and approval through the After Hours
Permit process administered by the Building and Safety Division.
•Provision of off-street parking for construction workers, which may include the use
of a remote location with shuttle transport to the Project site, if determined
A
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Table 11-1. Mitigation Monitoring and Reporting Program
Avoidance and Minimization Measure Monitoring/ Reporting
Action
Monitoring
Party Responsible Agency
necessary by the City of Santa Monica.
Project Coordination Elements That Shall Be Implemented Prior to Commencement of
Construction
•The City shall advise the traveling public of impending construction activities
(e.g., information signs, portable message signs, media listing/notification, and
implementation of an approved Construction Impact Mitigation Plan).
•The City shall provide timely notification of construction schedules to all
affected agencies (e.g., MTA, Big Blue Bus, Police Department, Fire
Department, Public Works Department, and Planning and Community
Development Department) and to all owners and residential and commercial
tenants of property within a radius of 500 feet.
•The City shall coordinate construction work with affected agencies in advance of
start of work. Approvals may take up to two weeks per each submittal.
Cumulative Impacts
No avoidance and minimization measures for this impact area. N/A N/A N/A
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City Council
Report
City Council Meeting: September 27, 2016
Agenda Item: 8.A
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To: Mayor and City Council
From: Susan Cline, Director, Public Works, Architecture Services
Subject: Airport Park Expansion Modification to the Design Agreement
Recommended Action
Staff recommends that the City Council:
1. Approve the conceptual direction for the Airport Park Expansion Project based
upon the Phase 1-feasibility analysis, public input and proposed concept design;
and direct staff to proceed with design and construction documents.
2. Authorize the City Manager to negotiate and execute a second modification to
the Professional Services Agreement No. 10238 (CCS) in the amount of
$1,113,561 (includes a 10% contingency) with Rios Clementi Hale Studios
(RCHS), a California-based company, to provide Phase 2 - design services for
the Airport Park Expansion Project. This will result in an amended agreement
with a new total amount not to exceed $1,324,761, with future year funding
contingent on Council budget approval.
3. Authorize the Director of Public Works to issue any necessary change orders to
complete additional work within contract authority.
Executive Summary
The City is committed to an expansion of Airport Park that will more than double the
available park acreage. The design of the expansion is focused on adding amenities,
including needed additional playfields, in the context of a much larger and more varied
mix of active and natural park uses anticipated with the future closure of Santa Monica
Airport.
As part of this phase of Airport Park expansion, a community design process has be en
completed for the new park space. Three concept schemes were presented to the
community online and at the site as well as to the Recreation and Parks and Airport
Commissions for public review and input. Based on that feedback, the proposed hybrid
concept offers expanded outdoor leisure and recreational opportunities for the
community, including sports fields, pickleball courts, Community Gardens, native
meadow habitat, pathways and children’s play and picnic areas. Staff recommends that
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Council provide input and approve the recommended hybrid concept and authorize
modification of the agreement to Rios Clementi Hale Studios (RCHS) for Phase 2
design services in the amount $1,113,561 (includes a 10% contingency) for a total not
to exceed amount of $1,324,761.
Background
On March 24, 2015 (Attachment A), the City Council heard a presentation by staff
regarding the Santa Monica Airport and future options regarding its operations and the
City's use of the land now occupied by the Airport. Reflecting Santa Mon ica’s
commitment to parks and open space, as part of a larger Council action, the City
Council unanimously voted to provide direction to staff to develop recreational uses
(primarily sports fields) on the twelve-acre non-aviation parcels at the Santa Monica
Airport and to do so within three (3) years.
Following a competitive process, on January 26, 2016 (Attachment B), the City Council
authorized the City Manager to negotiate and execute a contract with RCHS in an
amount not to exceed $211,200 (includes a 10% contingency) for the feasibility study
and design of the Airport Park Expansion Project. Execution of the first modification to
include reimbursables to the contract is complete and within the Council approved
contract amount.
On August 9, 2016 (Attachment C), the City Council authorized the City Manager to
negotiate and execute a contract with AMEC Environment & Infrastructure, Inc., a
California-based company, in an amount not to exceed $257,933 (includes a 10%
contingency) to provide environmental consulting services to comply with the California
Environmental Quality Act (CEQA) in regards to land use at the Santa Monica Airport.
Discussion
Based on a thorough examination of the site opportunities (2 relatively flat six acres
parcels) and constraints (limited access and bifurcation by Donald Douglas Loop) with
the directive to maximize sports fields on the site, the design team developed three
concept schemes (Attachment D/Exhibit 1).
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Option 1, Runway: Major features of Option 1 include four synthetic turf fields comprised
of the existing FIFA regulation size field, one new FIFA regulation size field and two
small, multi-purpose fields; retention of Donald Douglas Loop in its current location,
resulting in bifurcation of the park; 60 community garden plots in a slightly isolated
location between a new 250 space north parking lot and broad recreational path;
modification of the existing south parking lot resulting in a new drop-off area and
reduction in the size of both the existing children’s playground and dog park.
Option 2, Landing Strips: Major features of Option 2 include four synthetic turf fields,
unlike the previous scheme, in addition to the existing FIFA regulation size field, two
new FIFA regulation size fields are proposed with one small, multi-purpose field;
realignment of Donald Douglas Loop to the western boundary of the park resulting in
continuity of the park space and greater safety for users of the park: placement of 60
community garden plots in a very isolated location between the flight runway and a new
218 space north parking lot; and similar to Option 1, modification of the existing south
parking lot resulting in a new drop-off area and reduction in the size of both the existing
children’s playground and dog park.
Option 3, Flight Path: Major features include three synthetic turf fields, two new FIFA
regulation size fields, in addition to the existing FIFA regulation size field; realignment
of Donald Douglas Loop is extended to include the northern park edge allowing visitors
to the Airport Administration Building, as well as, users of a newly incorporated northern
drop-off to proceed without circulating through a new 60 space north parking lot; 60
community garden plots are centrally located within the park adjacent to othe r new park
amenities; and unlike the previous schemes, in addition to the south parking lot
remaining unchanged, the size of the existing children’s playground and dog area are
retained.
Vendor Selection
RCHS’ clear understanding of the project and knowledge of the project site, combined
with the firm’s collaborative abilities, professionalism and performance record during
Phase 1 of the Airport Park Expansion project demonstrate their qualification to provide
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Phase 2 design services. Execution of a second modification to the contract with RCHS
would facilitate the momentum of the project and prevent a delay to the overall project
schedule.
The agreement modification to be awarded to RCHS for Phase 2 design services
including schematic design, design development, construction documentation and
reimbursable expenses is $1,113,561. The amount includes a 10% contingency and
results in an amended agreement total not to exceed $1,324.761.
Public Outreach
On June 18, 2016, a community event was held at Airport Park and was attended by
approximately 106 people. Prior to the event, staff sent email announcements and
reminders to the City's parks interest list that includes several thousand community
members and all neighborhood organizations. The event was also marketed on the
City's social media accounts and City TV, through a press release to local newspapers,
advertisements in the Santa Monica Daily Press and with fliers distributed to local
businesses and at the COAST event.
At the community event, Mark Rios, principal at RCHS, presented the three concept
schemes and invited participants to offer commentary on the amenities and sports field
options provided. The entire consultant team was available to meet with interested
community members and answer questions. Written input was gathered at the event on
“passports” (Attachment E/Exhibit 2). In order to gain a more comprehensive sampling
of public opinion, the presentation and a survey were offered online until July 10, 2016,
with an additional 583 respondents participating. Full results of public input gathered at
the community event and online are attached as Attachment F/Exhibit 3.
Public surveys solicited demographic information including respondent age,
neighborhood of residency and park specific feedback con sisting of favored Santa
Monica parks and preferred amenities. Surveys from the public event also invited
respondents to identify the mode of transportation utilized to attend the event.
Noteworthy, 75% of all respondents who participated at the workshop o r took the survey
are residents of Santa Monica; approximately 73% reported being either field sports
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athletes or responsible for care of an athlete, and the desirability to open the park to a
pedestrian and cyclist access point on Centinela Avenue averaged 44% for “absolutely”
and 37% for “maybe.” Also, of significance, the top five favorite amenities selected at
the park were (in descending order of importance): sports fields, gardens or
landscapes, wildlife habitat, children’s playground and a walking/cycling promenade.
Concept Option 2 was the preferred design scheme, selected by 60% of all respondents
as their first choice.
Commission Actions
Recreation and Parks Commission: On July 21, 2016, the three concept schemes were
presented to the Recreation and Parks Commission, along with the data collected from
the community on their preferences for park amenities. The Commission adopted a
unanimous motion in favor of Option 3, Flight Path, and recommended the addition of a
“loop” pathway to surround the combined park areas; provision of a pedestrian entry at
Centinela Avenue; placement of the Community Gardens away from the runway and
within close proximity to other new amenities; retention of the size of both the existing
children's playground and dog park, and that consideration be given to add
concessions, a water feature and pickleball courts.
Airport Commission: On July 25, 2016, the three concept schemes were presented to
the Airport Commission, along with the data collected from the community on their
preferences for the park. The Commissioners did not have a preference for any
particular concept option, preferring to defer to public input and the recommendations of
the Recreation and Parks Commission.
Recommended Hybrid Concept
Based on the Council directive to maximize sports fields, community input , and the
recommendations of the Recreation and Parks Commission, the design team re-
examined the initial concept schemes and developed a new hybrid concept balancing
active recreation amenities including fields and play spaces, with landscaped less
formal areas and organized to facilitate further expansion of the park in the future.
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RECOMMENDED HYBRID CONCEPT
Like the three concept schemes, the proposed hybrid concept intersperses garden and
green space among fenced synthetic turf sports fields and similar to Option 3, relocates
Donald Douglas Loop to the south and west preventing bifurcation of the park by the
roadway. To further maintain continuity of the park and in response to community input
from gardeners and Commissioners, the hybrid concept places 60 new community
garden plots away from park edges to a more central location within the park, making
them readily accessible to other park amenities including a generously sized, natural
turf multi-purpose area for gathering and informal play use. As proposed, the gardens
are still in close proximity to parking since gardeners routinely bring supplies to their
plots. Naturally landscaped areas interspersed throughout the design incorporate
vegetation selections offering shade, seasonal variation and bird and butterfly habitat,
and serve as high-performance ecological counterpoints to the athletic spaces. Diverse
programs and the varied topography provides interest by inspiring play and contrasting
with the minimal slope required of the fields. The hybrid concept supports spaces for
sports viewing, children’s play spaces, native meadow habitat to capture and treat site
storm water, shaded picnic areas, and strolling gardens.
Comparable to Option 3, in addition to the existing regulation-sized FIFA field, the hybrid
concept incorporates two new regulation-sized FIFA fields, each suitable for lacrosse
and capable of division to accommodate three simultaneous soccer matches on each
field. The hybrid concept locates shaded spectator areas overlooking the FIFA fields in
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close proximity to sun-screened children's play spaces, retains the size of the existing
children’s playground and dog park areas, and, at the request of Recreation and Park
Commission, integrates a maximum of six pickle ball courts.
The broad multi-purpose recreational path as shown in all three concept schemes is
retained in the hybrid scheme and traverses the length of the park towards a large
flexible-use green space adjacent to Donald Douglas Loop and the Barker Hanger.
Additionally, the hybrid scheme incorporates an extensive loop path as suggested by
public input and recommended by the Recreation and Parks Commission. The loop and
multi-purpose paths provide access to two new restroom facilities that augment the
existing restroom building located at the park's midpoint and serve the play fields,
pedestrian entry and the new north parking lot. Accessed by Donald Douglas Loop, the
new north parking lot accommodates approximately 12 8 vehicles, 70 more than
currently available, and together with the existing and unchanged 58 -stall south parking
lot, provides parking for approximately 186 vehicles.
Staff believes that the proposed hybrid scheme meets the goals for providing additional
athletic fields and other park amenities to serve a broad range of users. Additionally,
staff finds that the hybrid scheme is designed to allow for further park expansion in the
future.
Next Steps
Upon Council approval of the recommended conceptual dire ction for the design of the
Airport Park Expansion Project, staff anticipates the following next steps:
Preparation of an EIR and CEQA approval.
Staff to return to Council by December 2016 with proposed guidelines and
regulations for the east six acres parcel to facilitate interim public use of this
space until the park expansion is constructed.
Staff to return to City Council in early 2018 for approval of the final design and
award of a contract for construction commencement in Spring 2018.
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Financial Impacts and Budget Actions
The agreement modification to be awarded to RCHS for Phase 2 design services
including schematic design, design development, construction documentation and
reimbursable expenses is $1,113,561 (includes a 10% contingency), for an amended
agreement total not to exceed $1,324,761. Funds are available in the FY 2016 -17
Capital Improvement Program budget in accounts:
C019120.589000 $1,094,045
P019120.589000 $19,516
TOTAL $1,113,561
While General funds have been identified to support the design phase for the Airport
Park Expansion Project, alternative financing will be required for the construction phase.
Estimated construction phase costs total approximately $39.3 million, which is more
than the General Fund CIP annual allocation will be able to support. Alternative
financing could come from a variety of sources including parks and recreation
development impact fees, bond proceeds from a potential future County parks bond
measure, and proceeds from a potential future local general obligation bond. Staff will
continue to explore alternate financing options and provide recommendations to Council
for the construction contract and also to add money for RCHS to complete final design
services in the construction phases related to bidding and construction administration
work.
Prepared By: Voneelya Simmons, Project Manager
Approved
Forwarded to Council
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Attachments:
A. March 24, 2015 Staff Report
B. January 26, 2016 Staff Report
C. August 9, 2016 Staff Report
D. Exhibit 1
E. Exhibit 2
F. Exhibit 3
G. Written Comments
REFERENCE:
Ordinance No. 2569
(CCS)