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b City of Los Angeles Bureau of Street Services, Urban Forestry Division 1149 South Broadway, 4 th Floor' Los Angeles, CA 90015 ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION CENTRAL CITY COMMUNITY PLAN AREA 1212 Flower Street Case Number: ENV-2013-4126-MND Project Location: 1212 Flower Street Council District: 14 Project Description: The subject of the current Addendum is the removal of 10 street trees and replacement with 20 street trees. [Note to Onlli: th e preliminary street tree planting plan I rec eivcd shows 2S :-;1 reet trees (with 3 addil ional groulld floor Irem;). However. 1 was told t hat. lite (Juanl ity of lIew :-;1 ree l will III' hm; 'ft 011 Iighlillg alld 1"('(luin:lllellls for separation lighling awl stre et I rN'S. I ha\,!} allalyz ed I he repla(;ell'f'nt of 20 street Irees, whieh is whal ,,, i ll hI' r'(luir ed based 011 a 2:1 replac e ment ratio 80 ,hal I.hl: City do es lI 't require you to illdude all 28 tr ces. if YOll'(] like me to revise to reflect 28 repla c ement tree s, that' s an ea:,;y change to make. ] APPLICANT: Onni Real Estate IX, LLC PREPARED BY: CAl A Environmental Services, LLC January 2017 ON BEHALF OF: The City of Los Angeles Bureau of Street Services Urban Forestry Division

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Page 1: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

b City of Los Angeles

Bureau of Street Services, Urban Forestry Division 1149 South Broadway, 4th Floor' Los Angeles, CA 90015

ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

CENTRAL CITY COMMUNITY PLAN AREA

1212 Flower Street

Case Number: ENV-2013-4126-MND

Project Location: 1212 Flower Street Council District: 14

Project Description: The subject of the current Addendum is the removal of 10 street trees and

replacement with 20 street trees. [Note to Onlli: the preliminary street tree planting plan I receivcd shows

2S :-;1 reet trees (with 3 addil ional groulld floor Irem;). However. 1 was told t hat. lite (Juanl ity of lIew :-;1 reel tree~ will III' l('~s hm; 'ft 011 stn~et Iighlillg alld 111t~ 1"('(luin: lllellls for separation lwlwl:I~1I :=; tre(~1 lighling awl

stree t I rN'S. TIII ~ n·ron\ I ha\,!} allalyzed I he repla(;ell'f'nt of 20 street Irees, whieh is whal ,,,i ll hI' r'(luired

based 011 a 2:1 replacement ratio 80 ,hal I.hl: City does lI ' t require you to illdude all 28 trces. How(~ver. if YOll'(] like me to revise to reflect 28 replacement trees, that's an ea:,;y change to make.]

APPLICANT: Onni Real Estate IX, LLC

PREPARED BY: CAl A Environmental Services,

LLC

January 2017

ON BEHALF OF: The City of Los Angeles

Bureau of Street Services

Urban Forestry Division

Page 2: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

TABLE OF CONTENTS

I. INTRODUCTION ................................................................................... .... .. .......... .. .. ....... .. .... ... ... ..... ..... ... 1-1

II. PROJECT DESCRIPTION ..................... .... ........... ... .... ..................... ... ... ... ................................................ II-l

III. RA TIONALE FOR PREPARING AN ADDENDUM .... .. ............................. .. ... ...... .. ............................. III-l

IV. ENVIRONMENTAL IMPACT ANALYSIS .... ......... .. ............. .............. ..... .... .... .. ... ............ ................... .IV-l

Aesthetics ................................................ .. ... ..... ..................... .................. ........ ..... ....................... IV-2

Biological Resources .................................................................................................................. .IV-4

Cultural Resources .............................. ... .... ............... ... ........... ... ......... .. .. ..................................... IV-5 Transportation / Traffic ... ......... .. .... ........... ............ ............. .... ............. ...... .. .. ...... ... .... .................. ]V-7

Utilities .. .... .... .. ...... ................................. ....... .... .. .................. .... .... .... .. ............... ......................... IV-9

TABLE

Table IV-I Water Consumption for Street Trees .... .. .................... .......................... .... ................................ .IV-IO

FIGURES

Figure 11-] Existing Tree Location Map ...... ..... ....... .. ............. ... .. ... .......... .... ... ......... .. ... ........................ ......... 11-3

1212 Flower

Addendum to the MND

1. Introduction

Page 1

Page 3: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

I. INTRODUCTION

Introduction

Pursuant to the California Environmental Quality Act (CEQA), a Mitigated Negative Declaration was

prepared for the 1212 Flower Project ("Approved Project") by the City of Los Angeles and published in July of 2014. The City ultimately approved the Project, which is described in greater detail in Section II

ofthis Addendum.

The purpose of this Addendum is to address the potential environmental impacts of the removal of 10

street trees and the replacement with 20 street trees on the streets surrounding the Project Site (see my comment on the cover about the number of replacement trees). Pursuant to Section 15164 of the State

CEQA Guidelines, the lead agency or responsible agency shall prepare an addendum to a previously approved environmental document if some changes or additions are necessary but none of the conditions

described in Section 15162 calling for the preparation of a new or expanded MND have occurred. The scope of this addendum focuses on the environmental effects that are associated with the removal of 10

street trees, and the replacement with 20 street trees on the streets surrounding the Project Site (the "Revised Project").

Project Information

Project Title:

Project Location:

Project Applicant:

Lead Agency:

Organization of Addendum

1212 Flower

1212 Flower Street, Los Angeles, CA

Onni Real Estate IX, LLC

City of Los Angeles, Bureau of Street Services, Urban Forestry Division 1149 South Broadway, 4th Floor

Los Angeles, CA 90015

This Addendum is organized into four sections as follows:

1. Introduction: This section provides introductory information such as the Project title, the Project

applicant and the lead agency for the Revised Project.

II. Project Description: This section provides a detailed description of the Revised Project, including

Project characteristics and environmental review requirements.

]]1. Rationale for Addendum: This section contains the rationale for preparing an Addendum pursuant to

Section 15164 of the State CEQA Guidelines.

i212 Flower

Addendum to the MND

I. introduction

Page 1-i

Page 4: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

City of Los Angeles Janumy 2017

IV. Environmental Impact Analysis: This section contains a brief summary of the environmental impacts

disclosed in the prior EIR for each environmental issue area. The evaluation includes an analysis of

how any of the environmental factors may be altered as a result of the Revised Project.

1212 Flower

Addendum to the MND

1. Introduction

Page 1-2

Page 5: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

II. PROJECT DESCRIPTION

PROJECT LOCATION

The Project Site is generally located at 1212 South Flower Street, Los Angeles 90015 and is bounded by South Flower Street, West 12th Street, and South Hope Street, in the DistrictlNeighborhood of South Park,

north of Pico Boulevard. The Project Site has a total lot area of approximately 65,009 square feet

(approximately 1.5 acres).

PROJECT BACKGROUND

Entitlement History

A Mitigated Negative Declaration was prepared for the 1212 Flower Project ("Approved Project") by the City of Los Angles and published in July of 2014. The City ultimately approved the Project, which is

described below.

Description of the Project Presented in the MND (the "Approved Project")

The Project would involve the development of a mixed-use development, consisting of two high-rise residential apartment towers with associated support services such as parking, resident amenity facilities,

storage rooms, bike storage, lobby circulation, and service spaces. Commercial/retail/restaurant space

would be located at the ground level. The Project's two towers would contain a total of 730 residential

units and 7,873 square feet of retail space. Parking would be provided on four underground and seven

podium levels. The existing 72,OOO-square-foot office building located at the northwest comer of the

Project Site would be retained as a component of the Project and would continue to function as an office

building.

ADDENDUM CHARACTERISTICS

An Addendum has been prepared to assess the proposed minor technical changes and modifications to the MND. All information presented below is merely a minor change to the Approved Project, or helps

clarifY, amplify, or make insignificant minor technical modifications to the MND. As discussed in the following sections, the new information is not considered "significant" pursuant to CEQA, and circulation

or preparation of a new formal environmental document is not required (see Guidelines Section 15088.5).

Aside from the proposed modifications, described below, all other impact analyses and associated

mitigation measures proposed within the MND would remain unchanged.

Proposed Modifications

The subject of this Addendum is the removal of 10 existing, non-protected street trees, consisting of the

following:

• Four Callistemon Citrus (Bottlebrush);

1212 Flower Addendum to the MND

11. Project Description Page II-J

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City of Los Angeles January 2017

• One Juniperus Chinensis "Torulosa" (Hollywood Juniper); and

• Five Ficus Microcarpa (Indian Laurel Fig).

Figure II-I provides the locations of the existing street trees. The Revised Project tree replacements would

be comprised of 20 street trees and would include a combination of Platanus Acerifolia "Columbia"

(Columbia Plane Tree) and Cassia Leptophylla (Gold Medallion Tree).

Anticipated Approvals

• Approval of a tree removal permit from the Board of Public Works and any other permit necessary for tree plantings.

1212 Flower

Addendum to the MND

11. Project Description

Page 11-2

Page 7: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

City of Los Angeles

Figure 11-1, Existing Tree Location Map

1212 Flower

Addendum to the MND

January 2017

II. Project Description

PageII-5

Page 8: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

III. RATIONALE FOR ADDENDUM

Section 15160 of the CEQA Guidelines explains that there are several mechanisms, and variations in

environmental documents, that can be tailored to different situations and intended uses of environmental review. Specifically, Section 15160 states that the" ... variations listed [including Subsequent EIRs,

Supplemental EIRs, and Addendums] are not exclusive. Lead agencies may use other variations consistent with the Guidelines to meet the needs of other circumstances." This provision allows Lead

agencies to tailor the use of CEQA mechanisms (such as this Addendum) to fit the circumstances presented to the Lead agency by a project. Here, the City has opted to prepare an Addendum to assess the

minor modifications of the Project that have transpired since preparation of the MND.

Specifically, Section 15164 ofthe CEQA Guidelines states:

(a) The lead agency or responsible agency shall prepare an addendum to a previously certified

MND if some changes or additions are necessary but none of the conditions described in Section

15162 calling for preparation of a subsequent MND have occurred.

(b) An addendum to an adopted negative declaration may be prepared if only minor technical

changes or additions are necessary or none of the conditions described in Section 15162 calling

for the preparation of a subsequent EIR or negative declaration have occurred.

(c) An addendum need not be circulated for public review but can be included in or attached to

the final EIR or adopted negative declaration.

(d) The decision-making body shall consider the addendum with the final EIR or adopted

negative declaration prior to making a decision on the project.

(e) A brief explanation of the decision not to prepare a subsequent MND pursuant to Section

15162 should be included in an addendum to an MND, the lead agency's findings on the project,

or elsewhere in the record. The explanation must be supported by substantial evidence.

Section 15162 of the CEQA Guidelines provides the criteria for preparing a Subsequent EIR or Negative

Declaration. Specifically, a Subsequent EIR or new Negative Declaration is required when there are

substantial changes to a project that involve new significant environmental effects or a substantial

increase in the severity of previously identified significant effects; substantial changes occur with respect

to the circumstances under which the project is undertaken which will require major revisions of the

previously approved MND; or new information of substantial importance, which was not known and could not have been known with reasonable diligence at the time the previous MND was certified, show

more or more severe significant effects, new feasible mitigation measures or alternatives are available but not adopted.

As required in subsection (e), above, substantial evidence supporting the Lead agency's decision not to

prepare a Subsequent EIR or new Negative Declaration pursuant to CEQA Guidelines Section 15162 is

provided in Section IV, Environmental Impact Analysis, of this Addendum. The environmental analysis

1212 Flower

Addendum to the MND

111. Rationale for Addendum

Page lII-l

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City of Los Angeles January 2017

presented in Section IV evaluates the potential impacts of the proposed tree removal and replacement in

relation to the current environmental conditions and in consideration of the environmental findings for the

Project.

As summarized in Section II, Project Description, and further analyzed in greater detail in Section IV,

Environmental Impact Analysis, the changes proposed are relatively minor and would not result in any

new significant environmental impacts. The analysis contained herein demonstrates that all of the impact

issues previously examined in the approved MND would remain unchanged with the proposed

modifications. The tree removal and replacement would result in little to no changes with respect to the

environmental impact conclusions analyzed for the Project.

Therefore, as described in further detail in Section IV, the analysis of the tree removal and replacement supports the determination that the proposed changes would not involve new significant environmental

effects, or result in a substantial increase in the severity of previously identified significant effects which

would call for, as provided in Section 15162 of the State CEQA Guidelines, the preparation of a Subsequent EIR or Negative Declaration. Therefore, the City has elected to prepare this variation of an

Addendum to the approved MND as the appropriate form of documentation to meet the statutory

requirements of CEQA.

1212 Flower

Addendum to the MND

III Rationale for Addendum

Page III-2

Page 10: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

IV. ENVIRONMENTAL IMPACT ANALYSIS

The following analysis addresses the environmental issues that were previously analyzed in the MND for

the Approved Project, and determines whether the removal of 10 street trees and the replacement with 20

street trees creates a new significant impact or increases the severity of an environmental impact as

identified in the MND. Provided below is an assessment of how the tree removal and replacement affects

the conclusions of each respective environmental issue analyzed in the MND.

It has been determined that the tree removal and replacement would not cause any new environmental

effects in the following areas and that no further environmental review of these issues is necessary:

• Agricultural and Forestry Resources. The tree removal and replacement would occur on the

same site as the Approved Project, and the conditions that could affect impacts to agricultural resources would remain unchanged.

• Air Quality. The conditions that could affect impacts to air quality would remain unchanged with

the tree removal and replacement. The removal and replacement of these trees would not change

the construction or operational air quality emissions of the Project, alter the consistency with the

AQMP, result in an increase of any criteria pollutants, create any odors, or result in any other air

quality impacts.

• Geology and Soils. The conditions that could affect impacts to geology and soils would remain

unchanged with the tree removal and replacement. The removal and replacement of these trees

would not change the existing geologic conditions of the Project Site, or the engineering and excavation plans for the development. Therefore, the geology and soils impacts would remain

unchanged.

• Hazards and Hazardous Materials. The tree removal and replacement would occur on the same site as the Approved Project. The conditions that could affect impacts to hazards and hazardous

materials would remain unchanged as a result of the tree removal and replacement.

• Hydrology and Water Quality. The conditions that could affect impacts to hydrology and water quality remain unchanged. This would include the impermeable nature of the Project Site, the

location of the Project Site, the construction plan, the size and type ofland uses proposed, and the

Project's compliance with all water quality and waste discharge requirements. Therefore, the

hydrology and water quality impacts would be the same as the impacts for the Approved Project.

• Land UselPlanning. A change in the Project's operational land uses, a substantial increase in floor area or height, or a substantial increase in the number of dwelling units or commercial

square footage could have the potential to change the impacts with respect to land use/planning.

As no changes are proposed to the type and intensity of land uses, the land use/planning impacts

would remain unchanged from the Approved Project.

1212 Flower Addendum to the MND

IV Environmental Impact Analysis Page IV-1

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City of Los Angeles January 2017

• Mineral Resources. The conditions that could affect mineral resources would remain unchanged with the tree removal and replacement because the Project Site does not include any areas of

mineral resource value.

• Noise. The conditions that could affect impacts to noise would remam unchanged with the removal and replacement of trees. The removal and replacement of these trees would not change

the noise or vibration from the Project during either construction or operation, or result in any

other impacts.

• Population and Housing. A change in the Project ' s operational land uses, a substantial increase

in floor area, or a substantial increase in the number of dwelling units could have the potential to

change the impacts with respect to population and housing. The conditions that could affect

impacts to population and housing remain unchanged as no changes are proposed to the type and intensity ofland uses.

• Public ServiceslRecreation. Demand for public services and recreation depends on the type and intensity of land uses. A change in the Project's operational land uses, a substantial increase in

floor area, or a substantial increase in the number of dwelling units or commercial square footage

could have the potential to increase the demand for police, fire, school, parks, and other public

facilities, thereby changing the impacts to public services. The conditions that could affect

impacts to public services remain unchanged as no changes are proposed to the type and intensity

of iand uses. Therefore, the pubiic services and recreation impacts would remain unchanged from

the Approved Project.

AESTHETICS

Approved Project

Visual Character

The Project would be complementary to the surrounding area, as it provides uses that already exist in the vicinity. In addition, it would provide additional housing opportunities in a jobs-rich area, and would

provide ground floor commercial/retail uses to activate the pedestrian network. Further, the density of the

Project adjacent to transit opportunities maximizes the opportunities for residents, visitors, and employees

to use transit. The Project would be constructed in a modem style, of materials such as concrete,

prefinished metal panel, perforated metal panel, stone, and glass. In addition, the Project would comply

with the principles of the Downtown Design Guide and the Los Angeles Sports and Entertainment

District Streets cape Plan. Overall, the Project would result in a less than significant impact with respect to

visual resources, including visual character and views.

1212 Flower Addendum to the MND

IV. Environmental Impact Analysis PageIV-2

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City of Los Angeles January 2017

Shade/Shadow

Shadow cast onto adjacent shadow-sensitive land uses would only be of short duration (less than three

hours in winter and less than four hours in summer). Therefore, shade and shadow impacts from the

Project would be less than significant.

Light and Glare

Though the Project would increase ambient light levels on the Project Site and in the vicinity, the increase

would be considered nominal, as the area is located in an urbanized area of Downtown Los Angeles that

is already illuminated at night and would be compatible with surrounding uses. In addition, exterior

lighting would be designed to confine illumination to the Project Site and off-site areas that do not include

light-sensitive uses. Finally, the Project would comply with all City ordinances limiting reflective

surfaces and materials and would limit reflective surface areas and the reflectivity of architectural

materials used. Therefore, impacts related to light and glare would be less than significant.

Overall, the Project's impacts to aesthetics, including visual resources, shade/shadow, and light and glare,

would be less than significant.

Revised Project (Tree Removal)

The conditions that could affect impacts to aesthetics (visual resources, shade/shadow, and light/glare)

would remain unchanged and less than significant. In addition, the visual character of the actual Project

buildings would also remain unchanged from the previous analyses. There would be a change to the

visual character of the Project Site based on the removal of the 10 existing street trees on 1ih Street and

Hope Street. However, 20 new trees (of at least 24-inch box size, as required by Regulatory Compliance

Measure 4-1, provided below under "Biological Resources") would be planted around the perimeter of

the Project Site. Therefore, the impacts to the visual character of the Site based on the removal and

replacement of street trees would be less than significant, and in fact, would be improved by the 10

additional street trees compared to existing conditions. In addition, the Project would reconstruct the

public sidewalks bordering the Project Site, as necessary, which would be an additional improvement with respect to the visual character of the Site.

Therefore, with regard to the criteria set forth ill CEQA Guidelines Section IS 162(a), the changes proposed would not result in any new significant impact with respect to aesthetics.

Cumulative Impacts

The cumulative impact would also be the same as for the Approved Project with respect to visual

resources, shade/shadow, and light/glare. The visual character of the Project Site would be altered based

on the tree removal and replacement and the reconstruction of the public sidewalks. However, as

discussed above, the visual character of the Project Site would actually be improved by the 10 additional

street trees and the reconstructed sidewalks when compared to existing conditions. Additional

development projects in the vicinity of the Project Site may also require tree removal and replacement,

1212 Flower Addendum to the MND

IV. Environmental Impact Analysis Page IV-3

Page 13: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

City of Los Angeles January 2017

which would alter the visual character of the area. However, as required of the Project, any related project

proposing the removal of street trees would be subject to the requirement of 2: I replacement (Regulatory

Compliance Measure 4-1, which is a standard City requirement), in order to ensure adequate street tree

replacement. Therefore, with implementation of this standard City requirement, cumulative visual

character impacts as a result of street tree removal and replacement would be less than significant and

would actually be improved by the increased number of street trees in the Project vicinity. Therefore, the

preparation of a subsequent or new MND is not warranted.

BIOLOGICAL RESOURCES

Approved Project

The Project Site is located in a heavily urbanized area of the City of Los Angeles. The Project Site does

not contain any species identified as a candidate, sensitive, or special status species in local or regional

plans, policies, or regulations, or by the California Department of Fish and Game (Fish and Game) or

U.S. Fish and Wildlife Service (USFWS). Nor are there any riparian or other sensitive habitat areas

located on or adjacent to the Project Site. In addition, there are no known locally designated natural

communities on the Project Site or in the Project vicinity.

The Approved Project would not result in the direct removal, filling or hydrological interruption of a

federally protected wetland as defined by Section 404 of the Clean Water Act. Due to the highly

urbanized surroundings, there are no wildlife corridors or native wildlife nursery sites in the Project

vicinity, and the Approved Project would not interfere with the movement of any resident or migratory

fish or wildlife species. There are no known locally designated natural communities on the Project Site or in the development vicinity. Therefore, the Approved Project would not conflict with the provisions of an

adopted Habitat Conservation Plan, Natural Conservation Community Plan, or other approved local,

regional, or State habitat conservation plan. Therefore, the Approved Project was found to have no impact

with respect to biological resources.

Revised Project (Tree Removal)

The Project would continue to be developed on the same Project Site, which is located in a heavily urbanized area of the City of Los Angeles. The Project Site does not contain any species identified as a

candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the

California Department ofFish and Game or U.S. Fish and Wildlife Service. Nor are there any riparian or

other sensitive habitat areas located on or adjacent to the Project Site. In addition, there are no known

locally designated natural communities on the Project Site or in the Project vicinity. The Project would

not result in the direct removal, filling or hydrological interruption of a federally protected wetland as

defined by Section 404 of the Clean Water Act. Due to the highly urbanized surroundings, there are no

wildlife corridors or native wildlife nursery sites in the Project vicinity and the Project would not interfere with the movement of any resident or migratory fish or wildlife species. There are also no known locally

designated natural communities on the Project Site or in the development vicinity. Therefore, the Project

1212 Flower Addendum to the MND

IV. Environmental Impact Analysis Page IV-4

Page 14: ADDENDUM TO THE MITIGATED NEGATIVE DECLARATION

City of Los Angeles January 2017

would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Conservation

Community Plan, or other approved local, regional, or State habitat conservation plan.

However, as part of Project development, 10 street trees would be removed and replaced with 20 street

trees. The 10 existing street trees will be impacted by the proposed construction and therefore, it is

recommended that the 10 street trees be replaced in accordance with the requirements of Mitigation

Measure 4-1, provided in the MND. With implementation of Mitigation Measure 4-1, impacts with

respect to tree removal and replacement would be less than significant.

Nesting birds are protected under the Federal Migratory Treaty Act (MBTA) (Title 33, United States

Code, Section 703 et seq., see also Title 50, Code of Federal Regulations, Part 10), and California Fish

and Wildlife Code Section 3503. The tree removal is proposed to start in February 2017 and would last

approximately one week. [Mark - please confirm this timing. This keeps LIS from having to include a

mitigation measure with respect to nesting birds.] As such, the proposed tree removal would take place

outside of breeding bird season (which generally runs from March 1 - August 31), and thus, there would

be no impact with respect to nesting birds.

With implementation of Mitigation Measure 4-1, provided in the original MND, impacts with respect to biological resources would be less than significant. With regard to the criteria set forth in CEQA

Guidelines Section 15162(a), the changes proposed would not result in any new significant environmental

impacts upon biological resources or result in a substantial increase in the severity of any previously

identified impacts. Therefore, the biological impacts would be comparable to the impacts of the Approved

Project, and all impacts would be less than significant.

Cumulative Impacts

As discussed in the previous analyses, development of the Project in conjunction with the related projects

would not significantly impact wildlife corridors or habitats for any candidate, sensitive, or special status

species identified in local plans, policies, or regulations, or by the California Department of Fish and

Wildlife or the US Fish and Wildlife Service, as no such habitat is expected to occur in the Project

vicinity due to the high level of existing urban development. However, as discussed above, the tree

removals would require replacement in accordance with Mitigation Measure 4-1, provided in the original

MND. If any of the related projects also require removal of trees, they would also be subject to the

requirements of Mitigation Measure 4-1, which is a standard City requirement. With implementation of

this measure by both the Project and related projects, the cumulative impacts with respect to biological

resources would be less than significant and the preparation of a subsequent or new MND is not warranted.

CULTURAL RESOURCES

Approved Project

Historic Resources

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IV. Environmental Impact Analysis Page IV-5

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City o/Los Angeles January 2017

The Project Site is currently developed with an office building, which would be retained as part of the

Project. The two-story warehouse located to the south of the Project Site, which is not a designated

historic resource, would be demolished in conjunction with the Project. No historic resources would be

demolished, altered, or relocated as a result of the Project, and as such, no impact would occur.

Archaeological Resources

The Project Site is located in an urbanized area of the City and has been previously disturbed by past

development activities. The Project would require excavation for the subterranean parking levels as well

as for utility and foundation work. Although it is likely that any archaeological resources on the Project

Site would have been uncovered during past development activities, there is still the potential for buried

archaeological resources within the Project Site. Therefore, with the implementation of Mitigation

Measure 5-1, impacts with respect to archaeological resources would be less than significant.

Paleontological Resources

The Project Site is located in an urbanized area of the City and has been previously disturbed by past development activities. The Project would require excavation for the subterranean parking levels as well

as for utility and foundation work. Although it is likely that any paleontological resources on the Project

Site would have been uncovered during past development activities, there is still the potential for buried

paleontological resources within the Project Site. Therefore, with the implementation of Mitigation

Measure 5-2, impacts with respect to paleontological resources would be less than significant.

Human Remains

The Project Site is located in an urbanized area of the City and has been previously disturbed by past

development activities. The Project would require excavation for the subterranean parking levels as well

as for utility and foundation work. According to the Native American Heritage Commission (NAHC), a

records search of the NAHC Sacred Lands File failed to indicate the presence of Native American

traditional cultural place(s) in the Project Site. However, there are Native American cultural resources in

close proximity to the Area of Potential Effect (APE). Environmental impacts may result from Project

implementation due to the discovery of unrecorded human remains. With implementation of Mitigation

Measure 5-3, impacts to human remains would be less than significant.

Revised Project (Tree Removal)

Historic Resources

As discussed above, the Project Site does not contain any historic resources. In addition, the existing

street trees are not historic. Therefore, the removal of the 10 existing street trees and the replacement with

20 street trees would not result in any impacts to historic resources.

Archaeological Resources

1212 Flower Addendum to the MND

IV. Environmental Impact Analysis Page IV-6

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City of Los Angeles January 2017

No known prehistoric or archaeological resources have been identified on the Project Site. In the event

that archeological resources are encountered during the removal of the 10 street trees and the replacement

with 20 street trees, implementation of Mitigation Measure 5-1, provided in the MND, would reduce

potential impacts to less than significant.

Paleontological Resources

The Project Site contains no known unique paleontological resources. It is possible that unknown

paleontological resources could be encountered during the removal of the 10 street trees and the

replacement with 20 street trees. Without proper care, unknown resources could be damaged or destroyed.

However, with implementation of Mitigation Measure 5-2, provided in the MND, any potential impact to

paleontological resources would be reduced to less than significant.

Human Remains

The Project Site contains no known Native American traditional cultural places. However, there are

Native American cultural resources in close proximity to the APE. It is possible that unknown human

remains could be encountered during the removal of the 10 street trees and the replacement with 20 street

trees. Without proper care, unknown resources could be damaged or destroyed. However, with

implementation of Mitigation Measure 5-3, provided in the MND, any potential impact to human remains

would be reduced to less than significant.

Overall, these modifications would not change the existing conditions of the Project Site and would not

change the impacts with respect to cultural resources. The Revised Project would implement the same

mitigation measures as the Approved Project (Mitigation Measures 5-1 through 5-3, provided in the

MND). Therefore, the impacts to historic resources, archaeological resources, paleontological resources, and human remains would be less than significant, same as the Approved Project.

Therefore, with regard to the criteria set forth in CEQA Guidelines Section 15162(a), the changes proposed would not result in any new significant environmental impacts upon cultural resources or result

in a substantial increase in the severity of any previously identified impacts.

Cumulative Impacts

As provided above, the tree removal and replacement would not result in any new Project impacts related

to cultural resources. As such, cumulative impacts with respect to cultural resources would continue to be

less than significant and the preparation of a subsequent or new MND is not warranted.

TRANSPORTATIONITRAFFIC

Approved Project

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Intersection Impacts

Prior to the Project (Future Without Project conditions), one study intersection is expected to be operating

at LOS E during the PM peak hour, Flower Street and Pico Boulevard. With this Project, this intersection would remain at LOS E during the PM peak hour. However, the Project impact is not anticipated to

exceed the City of Los Angeles significance threshold at this intersection or any other study intersections. Therefore, no mitigation measures are necessary and impacts would be less than significant.

CMP

The nearest CMP intersections are Wilshire Boulevard/Alvarado Boulevard and Washington Boulevard

and Alameda Street. However, the Project would not add 50 or more trips to these intersections. In

addition, the Project would not add more than 150 new trips to any freeway segment in the study area.

Therefore, no further CMP analysis is warranted.

Revised Project (Tree Removal)

The proposed tree removal and replacement and public sidewalk reconstruction could temporarily affect

traffic and circulation pattell1s in the local vicinity, due to temporary sidewalk and/or road closures, which

may occur as a result ofthe tree removal and replacement and public sidewalk reconstruction. In addition,

the tree removal and sidewalk reconstruction may temporarily disrupt metered parking adjacent to where

work is occurring. All proposed roadway and sidewalk closures, including those as a result of tree

removal and replacement and public sidewalk reconstruction, would be submitted to LADOT for their

review. Therefore, construction traffic impacts as a result of tree removal and replacement and public

sidewalk reconstruction would be less than significant.

The conditions that could affect impacts to traffic during Project operation would remain unchanged with the removal of 10 street trees and replacement with 20 street trees and the public sidewalk reconstruction.

The removal and replacement of these trees and public sidewalk reconstruction would not change the

Project trip generation or intersection impacts, or result in any other traffic impacts. Therefore, with

regard to the criteria set forth in CEQA Guidelines Section 15162(a), the changes proposed would not

result in any new significant environmental impacts upon transportation/traffic or result in a substantial

increase in the severity of any previously identified impacts. The impacts would be similar to the

Approved Project and the preparation of a new or subsequent MND is not warranted.

Cumulative Impacts

As discussed above, the proposed tree removal and replacement and public sidewalk reconstruction could

result in temporary construction traffic impacts due to temporary sidewalk or road closures. However, as discussed above, any proposed closures would be submitted to LADOT for their review, and Project

construction impacts related to tree removal and replacement and public sidewalk reconstruction would be less than significant. If any related projects also require tree removal and replacement, such projects

would also be required to submit any proposed road or sidewalk closures to LADOT for their review. As such, cumulative construction traffic impacts would be less than significant.

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The cumulative operational impacts of the Project combined with the related projects would remain

unchanged from the analysis provided for the Approved Project, as the tree removal and replacement

would not result in any new operational impacts. As such, the preparation of a subsequent or new MND is not warranted.

UTILITIES

Approved Project

Wastewater

The Project is anticipated to generate a net increase of approximately 117,640 gallons per day (gpd) of

wastewater. The sewage generated by the Project would be conveyed to the HTP, which has sufficient capacity for the Project. Additionally, water conservation measures required by City ordinance (e.g.,

installation of low toilets and plumbing fixtures, limitations on hose washing of driveways and parking

areas, etc.) would be implemented as part of the Project and would help reduce the amount of wastewater

generated with respect to sewer service. As such, the Project's impacts with respect to wastewater treatment capacity and infrastructure would be less than significant.

Water

According to the Water Supply Assessment prepared by LADWP and adopted by the Board of Water and

Power Commissioners on May 20, 2014, the Project is anticipated to consume approximately 127,497

gpd or approximately 143 acre-feet per year. The existing water infrastructure serving the Project area

could accommodate the estimated water consumption for the Project. Therefore, Project impacts with

respect to water supply and infrastructure would be less than significant.

Solid Waste

The Project is anticipated to generate a net increase of approximately 8,981 pounds per day of solid waste. The increase in solid waste generated by the Project would be adequately served by the remaining

daily intake permitted at the Sunshine Canyon Landfill, and the Project would not result in the need for additional waste collection routes or recycling and disposal facilities. Therefore, impacts associated with

solid waste service would be less than significant.

Revised Project (Tree Removal)

The only change contemplated in this Addendum is the removal of 10 street trees and the replacement of 20 street trees. This change would not result in any changes to impacts with respect to wastewater

generation, infrastructure, or treatment capacity, or solid waste generation and landfill capacity. With respect to water demand, there would be a net increase of 10 street trees after the removal of 10 street

trees and replacement with 20 street trees. As shown in Table IV-I, the 10 additional street trees would

demand approximately 6,100 gallons per day of water. LADWP prepared a Water Supply Assessment for

the Approved Project, which accounted for 143 acre-feet per year of water, including water for

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City of Los Angeles January 2017

landscaping purposes. As such, the water for the additional street trees would be accommodated within

the approved Water Supply Assessment. In addition, the Project is consistent with the City's General Plan

and therefore has been taken into account in the planned growth of the water system. Further, the

LADWP has indicated in its Urban Water Management Plan that it will provide an adequate water supply

to meet current and future growth until at least 2020. Finally, the Project will comply with Ordinance No.

170,978 by utilizing smart irrigation systems with flow sensors and drip tubing delivery systems. For

these reasons, impacts to water supply would be less than significant and would be comparable to the

impacts of the Approved Project.

Table IV-l Water Consumption for Street Trees

DBH- Total Water Tree Inches a Consumption Rate b Consumption (gpd)

Existing Trees (to be removed) Callistemon Citrinus 4" 10 gallons/inch/day 40 Callistemon Citrinus 5" 10 gallons/inch/day 50 Calli stem on Citrinus 4" 10 gallons/inch/day 40 Callistemon Citrinus 4" 10 gallons/inch/day 40 Juniperus Chinensis "Torulosa" 4" 10 gallons/inch/day 40 Ficus Microcarpa 14" 10 gallons/inch/day 140 Ficus Microcarpa 12" 10 gallons/inch/day 120 Ficus Microcarpa 24" 10 gallons/inch/day 240 Ficus Microcarpa 15" 10 gallons/inch/day 150 Ficus Microcarpa 24" 10 gallons/inch/day 240

Subtotal (to be removed) (1,100) Replacement Trees 20 Replacement Trees C 36" 10 gallons/inch/day 7,200

Subtotal (proposed) 7,200 Less (removed) (1,100)

Total 6,100 a DBH for existing trees is provided in the tree inventory contained in Appendix A to this Addendum. b Calculated using the general rule of thumb assuming 10 gallons of water for every inch of trunk diameter. (hU{2:! Iwww.oaoa.coml{2eo{2lellifgSf]!.lelgardening/article c 72415 {1-ebe9-5add-b 161-d8d678b3039 7. html; hU{2:llwww.colostate.eduIDe12tICoo12ExtI4dmglTrees/caring.htm) C Replacement trees will include a mix of Platanus Acerifolia "Columbia" and Cassia Leptophylla.

The impact to water, wastewater, and solid waste would therefore be less than significant, and comparable

to the Approved Project. Overall, with regard to the criteria set forth in CEQA Guidelines Section

15162(a), the changes proposed would not result in any new significant environmental impacts upon

public utilities or result in a substantial increase in the severity of any previously identified impacts.

Cumulative Impacts

As discussed in the previous analyses, the cumulative impacts of the Project combined with the related

projects would be less than significant with respect to wastewater, water, and solid waste. While the

proposed tree removal and replacement would require slightly more water than the Approved Project,

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there would still be adequate water supply to meet the Project's demand. Therefore, cumulative impacts with respect to utilities and service systems would remain unchanged and the preparation of a subsequent

or new MND is not warranted.

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IV Environmental Impact Analysis Page IV-ll