DRAFT Environmental Impact Report (EIR) EXECUTIVE SUMMARY Los Angeles Trans-Pacific Telecommunications Cable Hub

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1 DRAFT Environmental Impact Report (EIR) EXECUTIVE SUMMARY Los Angeles Trans-Pacific Telecommunications Cable Hub State Clearinghouse No May 2017 City of Los Angeles Department of Public Works, Bureau of Engineering Bureau of Engineering Environmental Management Group

2 Front cover: Aerial photograph of the proposed cable landing site at Dockweiler State Beach, Los Angeles Copyright (C) Kenneth & Gabrielle Adelman, California Coastal Records Project,

3 EXECUTIVE SUMMARY Introduction Pursuant to the requirements of the California Environmental Quality Act (CEQA), this Draft Environmental Impact Report (EIR) has been prepared by the City of Los Angeles (City) for development of the (Project). The purpose of this Draft EIR is to inform decision makers and the general public of potential environmental impacts that could result from the Project. The proposed Project will require approval of certain discretionary actions by the City (main action) and other governmental agencies, and is therefore subject to environmental review requirements under CEQA. For the purposes of complying with CEQA, the City of Los Angeles Department of Public Works, Bureau of Engineering (BOE), is identified as the Lead Agency for the proposed Project. Development of the Project is proposed by the Project Applicant, Tyco Electronics Subsea Communications LLC (TE SubCom, or the Applicant), a global supplier of subsea communications systems. A detailed description of the proposed Project is included in Section 2.0, Project Description, of this Draft EIR. Sections 15121(a) and of the State CEQA Guidelines define an EIR as an informational document that informs public agency decision makers and the public of the significant environmental effects of a project, identifies possible ways to minimize the significant effects, and describes reasonable alternatives to a project. The purpose of this Draft EIR, therefore, is to discuss potential effects on the environment resulting from the Project. The major components of the environmental review developed by the Lead Agency are included in Section 3.0, Environmental Impact Analysis. In addition, feasible mitigation measures are recommended, where applicable, to reduce effects of a potentially significant impact to a less than significant impact. A Mitigation Monitoring and Reporting Program shall be prepared and adopted by the City pursuant to Section of the State CEQA Guidelines. Project Objectives The objectives of the Project are to install a fiber optic cable landing site that would accommodate up to four (4) trans-pacific subsea fiber-optic telecommunication cable systems and to install one of the cable systems (Phase I) to enhance telecommunications capacity between the Asia-Pacific region and mainland United States ([U.S.]Los Angeles region). The Project has been designed to achieve the following objectives: Add direct telecommunications links between the Los Angeles region and the Asia- Pacific region; Increase telecommunications reliability between the Los Angeles region and the Asia- Pacific region; Increase diversity of telecommunication pathways between the Los Angeles region and the Asia-Pacific region; Draft EIR ES-1 May 2017

4 Increase data transmission capacity and speeds to satisfy the burgeoning demands of the trans-pacific region; and Respond to the increasing demand for connectivity between Asia and the Los Angeles region. Project Overview The Applicant proposes to install and operate infrastructure for subsea fiber-optic telecommunications cable systems connecting the U.S. and the Asia Pacific region, referred to as the or the Project. The Project location is in Los Angeles, California. The Project would be implemented in four phases. Phase I would include installation of the Pacific Light Cable Network (PLCN) subsea telecommunication cable system, a second marine cable segment, referred to here as the Trans-Pacific Cable Segment, and construction of associated infrastructure, including horizontal directionally drilled (HDD) bore pipes, underground beach manholes (BMHs), ocean ground beds, and the terrestrial conduit route connecting the BMHs to an existing data center. Phases II, III, and IV would include installation and operation of a subsea cable system to complete the Trans-Pacific Cable Segment (Phase II) and two additional cable systems (Phases III and IV, respectively). These future cable systems are unidentified at this time, and would be analyzed in more detail and permitted separately once proposed. The major work elements for these phases would include the marine installation of two additional cables from the BMH(s) on Dockweiler State Beach through U.S. territorial waters, and installation (terrestrial cable pulling) of the cable(s) through the terrestrial infrastructure installed in Phase I. The Project referred to herein comprises Phase I in its entirety, including installation of subsurface infrastructure that would eventually accommodate Phases II, III, and IV. Project Location and Setting The proposed Los Angeles landing site is located within the northeast corner of a parking lot at Dockweiler State Beach ( N ), immediately west of South Marine Avenue and approximately 230 feet (ft) (70 meters [m]) west of Vista del Mar Boulevard abutting the western boundary of Los Angeles International Airport (LAX) (Figure ES-1). A subsurface terrestrial conduit system would be constructed from the Project-installed BMHs at the Dockweiler State Beach parking lot to an existing data center, requiring conveyance through public street right-of-way (ROW) within the cities of Los Angeles and El Segundo (Figure ES-2). Phase I of the Project also includes the installation of two subsea cables within the City s submerged lands. The PLCN cable would also pass through U.S. territorial waters (Figure ES-3). Draft EIR ES-2 May 2017

5 Project: Date: 5/2/2017 Created By: GF ³ ³ Site Location 120 Miles Malibu Santa LAX Dockweiler State Beach Hermosa Beach Pacific Ocean Rancho Palos Verdes Nautical Miles 7 Kilometers 14 Legend PLCN Cable Route ERM Environmental Resources Management Trans-Pacific Cable Cable Landing Site ES-1 Location Map Los Angeles Trans-Pacific Telecommunications Cable Hub

6 Created By: GF Date: 5/2/2017 Project: ³ L O S A N G E L E S I N T E R N AT I O N A L A I R P O R T S MARINE AVE 50 Feet 105 Pacific Ocean Hyperion Treatment Plant % "/ Center Street Elementary School 0 1,250 2,500 Feet ERM Environmental Resources Management Legend Terrestrial Conduit Route Construction Method (Proposed) Trenching Horizontal Directional Drill!@ Cable Landing Site "/ Equinix Data Center ES-2 Terrestrial Conduit Route Los Angeles Trans-Pacific Telecommunications Cable Hub

7 Site Location ³ Created By: GF Date: 5/2/2017 Project: ³ ³ Miles Nautical Miles Kilometers Notes: Submerged lands crossed by the cable route within State Waters are under the jurisdiction of the City of Los Angeles ERM Environmental Resources Management Legend PLCN Cable Route Trans-Pacific Cable Segment!@ Cable Landing Site US Territorial Waters (12 nmi) State Waters (3 nmi) ES-3 Marine Cable Alignments in US Territorial Waters Los Angeles Trans-Pacific Telecommunications Cable Hub

8 Alternatives to the Proposed Project CEQA requires the Lead Agency to analyze alternatives to a proposed project that could feasibly achieve the objectives of the proposed project while substantially reducing significant environmental effects. Section of the State CEQA Guidelines emphasizes the selection of a range of reasonable alternatives and an adequate assessment of these alternatives to allow for a comparative analysis for consideration by decision makers. The analysis detailed in Section 4.1 identifies a number of alternatives for the landing site, data center destination, terrestrial conduit route, and technical options for installation. Several alternatives were considered, but eliminated from analysis because they would not be feasible, they would not achieve most of the Project objectives, or they would not reduce or avoid significant impacts of the proposed Project. The following alternatives were retained for full evaluation in the EIR: No Project Alternative Under this alternative, the Project would not be implemented and a trans-pacific telecommunications cable hub would not be installed. Therefore, impacts associated with construction and operation of the Project would not occur. Consequently, existing conditions would remain and change over time with local and regional growth, including other projects planned for development and those that will occur in the future. Beach Landing Location Alternative 2: 11th Street in City of Hermosa Beach The 11th Street site between Hermosa Avenue and Beach Drive in the City of Hermosa Beach is a public parking lot in the commercial district of the City of Hermosa Beach and a viable landing site for a cable hub. This alternative would involve new construction of Power Feed Equipment (PFE), which introduces construction- and maintenance-related air emissions not required for the proposed Project. Impacts associated with noise and transportation and traffic would be similar, if not greater than the proposed Project, given the densely populated area of the City of Hermosa Beach, through which the terrestrial conduit route would be constructed. The alternative site is closer to other existing seabed uses, such as several fiber-optic cables (three different owners); the Hermosa Beach Pier; and AES Redondo Beach Generating Plant, all of which would require coordination during marine installation. Similar to the proposed Project, the alternative location would temporarily preclude off-shore commercial and recreational fishing, recreational boating, anchored vessels, and other marine sports. Furthermore, although the landing location would be separate from the MC Global sites and other existing landing sites in the City of Hermosa Beach, the geographical diversity, and therefore potential reliability, may be lower than that provided by the proposed Project, which is located farther away from existing cables. Therefore, this alternative may not fully satisfy one of the Project objectives (increased diversity and reliability). Draft EIR ES-6 May 2017

9 Data Center Destination Alternative 1: Equinix LA4 The proposed Project currently terminates at the Equinix data center located at 1920 East Maple Avenue, El Segundo (LA3). A viable data center alternative exists in the same immediate industrial area within El Segundo, the Equinix data center located at 445 North Douglas Street (LA4). This alternative considers bypassing LA3 to connect all systems to LA4 or connecting one or more systems to LA3 and extending others to LA4 (i.e., a combined LA3+LA4 alternative). This alternative would have a minor increase in air emissions and extend the time over which they may be concurrent with marine installation-related emissions (a source of significance threshold exceedance). It would also extend temporary increases in ambient noise levels for an additional 10 to 12 days over a length of approximately 0.9 mile, including one to two days adjacent to the outdoor athletic facility of El Segundo High School along East Mariposa Avenue. Impacts on traffic congestion and transportation facilities would extend across the route between LA3 and LA4. Other impacts would be similar to impacts under the proposed Project. Route Alternative 2: Terrestrial Route along Imperial Highway An alternative to install the terrestrial conduit route down Imperial Highway for a majority of the eastward route was considered given the directness of the route and distance from noise sensitive receptors. Imperial Highway is a four-lane major arterial, State Route (SR-90), that runs 41 miles through the Los Angeles metropolitan area. The highway contains intersections with other arterials and collectors and provides access to the cargo functions at LAX. This route alternative would increase potentially significant impacts associated with traffic capacity, congestion, and transportation facilities along Imperial Highway, as compared to the proposed Project (i.e., Imperial Avenue). The alternative would also require increased coordination with LAX and transit authorities. Other impacts would be similar to impacts under the proposed Project. Technical Options Alternative 2: Touchdown Monitoring A proposed alternative method for installation of the marine cables includes the addition of touchdown monitoring during the main cable lay portions of the PLCN cable and Trans- Pacific Cable Segment. This method would require the use of a second cable ship or survey vessel, equipped with a Remotely Operated Vehicle (ROV). The second vessel would follow behind the main lay vessel and deploy the ROV along surface-laid portions of the cable to provide real-time video feed of the status of the cable installation. If the ROV identifies a cable suspension along the route that can be eliminated or minimized by repositioning or introducing additional cable slack, the cable ship would recover the cable and reinstall it along that portion of the route. The touchdown monitoring installation method alternative could reduce the likelihood of cable suspensions along the marine cable route. This would potentially reduce impacts on fishermen and marine species. However, no cases of wildlife entanglement or fishing gear entanglement have been reported for cables installed in the area or elsewhere in the state with or without touchdown monitoring, since There would be no change in impact significance with Draft EIR ES-7 May 2017

10 implementation of this Project alternative. However, impacts on air quality, already significant and unavoidable under the proposed Project, would be greater with the addition of touchdown monitoring. Comparison of Proposed Project and Alternatives Table ES-1, below, provides a comparison of expected impacts resulting from the proposed Project and the five alternatives assessed in this EIR. The table includes all resource areas for which Project impacts would be significant and unavoidable or less than significant after implementation of Applicant Proposed Measures and Mitigation Measures identified in this EIR. None of the alternatives except the No Project Alternative would reduce the significant and unavoidable impacts from air emissions and construction noise to less than significant. Table ES-1: Summary of Impacts Associated with Project and Alternatives Impact Proposed Project Beach Landing Location Alternative Data Center Destination Alternative Terrestrial Route Alternative Technical Options Alternative (Touchdown Monitoring) No Project Air Quality SU SU SU SU SU NI Terrestrial Biological LTS LTS LTS LTS LTS NI Resources Marine Biological LTS LTS LTS LTS LTS NI Resources Cultural Resources LTS LTS LTS LTS LTS NI Land Use and Recreation land LTS LTS LTS LTS LTS NI use Noise SU SU SU SU SU NI Traffic and Transportation LTS LTS LTS SU LTS NI Notes: SU = Significant and Unavoidable LTS = NI = No Impact Environmentally Superior Alternative For this Project, the No Project Alternative is the Environmentally Superior Alternative because it is the only alternative that reduces significant and unavoidable impacts from short-term air emissions and temporary construction noise to less than significant. However, Section , Subdivision (e)(2) of the State CEQA Guidelines states, in part, that If the environmentally superior alternative is the no project alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives (emphasis added). All alternatives other than the Draft EIR ES-8 May 2017

11 No Project Alternative maintain or increase the overall severity of less than significant with mitigation impacts. Based on the above, this EIR recommends the Data Center Destination Alternative 1 (connection to LA4) as the Environmentally Superior Alternative because the data center would fulfill the Project objectives without introducing other potentially significant impacts, as is the case for the other alternatives proposed. Areas of Known Controversy State CEQA Guidelines Section 15123(b)(2) requires that an EIR contain a summary of the areas of controversy known to the Lead Agency, including issues raised by the public and governmental agencies. There were no formal comments received from the public during the scoping period (October 13 to November 14, 2016). Additionally, there were no attendees at the public scoping meeting held on October 25, Formal comments received were from government agencies and representatives of Native American tribes, as detailed in Appendix A of this EIR. The issues and concerns raised in agency commentary do not necessarily represent areas of controversy, but instead generally indicate topics that may need to be investigated and evaluated. Controversial issues tend to be contentious and subject to disagreement and dispute. No contentious issues emerged during the EIR scoping process and no citizens or governmental agencies expressed opposition to the Project. Issues to be Resolved State CEQA Guidelines Section 15123(b)(3) requires that an EIR present issues to be resolved by the Lead Agency, including the choice among alternatives and whether or how to mitigate significant effects. City decision makers will need to decide whether the mitigation measures recommended in this EIR are appropriate and feasible for reducing significant impacts. If so, the measures will need to be adopted as conditions of Project approval. The EIR also identifies certain significant and unavoidable impacts that cannot be effectively reduced to a less than significant level. To approve the Project with such impacts, decision makers will need to adopt a Statement of Overriding Considerations describing the reason(s) for approving the Project despite these impacts. No other unresolved issues were identified at this time. Summary of Project Impacts The EIR identifies and analyzes the potentially significant environmental impacts associated with the proposed Project. The impact analysis is based on information provided by the Applicant, as well as supplementary investigations and research conducted by the EIR preparers. The analysis indicates that the Project would result in certain adverse environmental impacts; however, the majority of these impacts would not be significant. The potentially significant Draft EIR ES-9 May 2017

12 impacts identified in the analysis include effects on air quality, terrestrial and marine biological resources, cultural resources, hydrology and water quality, land use and recreation, noise, and traffic and transportation during construction of the Project. With the exception of air quality and noise, the remainder of Project impacts can be reduced to a less than significant level with the implementation of mitigation measures. Table ES-2 presents a summary of impacts and mitigation measures for the Project by topic area. The table includes each impact that was determined to be less than significant with mitigation or significant and unavoidable by topic area, as well as recommended mitigation measures. Draft EIR ES-10 May 2017

13 Table ES-2: Summary of Environmental Impacts Resulting from the Project Impact Mitigations Significance Conclusion Section 3.2, Aesthetics and Visual Resources Impacts less than significant. No proposed mitigation measures. Section 3.3, Air Quality Impact AIR-1: Project construction emissions could exceed SCAQMD regional emission thresholds for criteria pollutants. Section 3.4, Terrestrial Biological Resources Impact TBIO-1: Project-related activities could result in substantial adverse effects, either directly or through habitat modifications, on El Segundo blue butterfly. Impact TBIO-2: Implementation of Project-related activities could result in substantial adverse effects, either directly or through habitat modifications, on silvery legless and coast horned lizards. Impact TBIO-3: Implementation of Project-related activities could result loss of populations or essential habitat for western snowy plover, California least tern, loggerhead shrike, burrowing owl, and other special-status avian species, including raptors. Impact TBIO-5: Implementation of the Project could interfere with the movement of native resident or migratory wildlife species. MM AIR-1: Emission Reduction Measures MM TBIO-1: El Segundo Blue Butterfly Habitat Avoidance and Pre-construction Survey MM TBIO-2: Worker Environmental Awareness Training MM TBIO-3: Silvery Legless and Coast Horned Lizard Pre-construction Surveys and Avoidance Measures MM TBIO-4: Trench Management Measures MM TBIO-5: Migratory Bird Preconstruction Surveys MM TBIO-6: Artificial Lighting MM TBIO-5: Migratory Bird Preconstruction Surveys MM TBIO-6: Artificial Lighting Significant and Unavoidable Draft EIR ES-11 May 2017

14 Impact Impact TBIO-6: Project activities could potentially conflict with local policies and ordinances. Section 3.5, Marine Biological Resources Impact MBIO-1: Vessel strikes or collisions with marine special-status species in the offshore environment could occur during the installation or repair of the marine components of the Project. Impact MBIO-2: Project vessel movements and noise could disturb marine special-status species. Impact MBIO-3: Marine special-status species could become entangled in cable suspended above the seafloor or in fishing gear caught on suspended cable. Impact MBIO-4: Accidental release of fuel, fuel oil, hydraulic fluids, or drilling mud could impact marine special-status species. Impact MBIO-5: Project-related activities could result in substantial adverse impacts, either directly or through habitat modifications, on grunion. Impact MBIO-7: The Project could impact hard bottom communities that support special-status marine wildlife, kelp forests, and deep-sea corals and sponges. Impact MBIO-8: Implementation of Project activities could result in impacts on federally protected waters. Impact MBIO-10: The Project would pass through designated Essential Fish Habitat (EFH) areas. Mitigations MM TBIO-1: El Segundo Blue Butterfly Habitat Avoidance and Pre-construction Survey MM TBIO-2: Worker Environmental Awareness Training MM MBIO-1: Prepare and Implement Marine Wildlife Monitoring and Contingency Plan (MWMCP) MM MBIO-1: Prepare and Implement Marine Wildlife Monitoring and Contingency Plan (MWMCP) MM MBIO-2: Burial Verification Report and Survey MM MBIO-3: Fishing Gear Retrieval MM MBIO-4: Release detection and monitoring during HDD MM MBIO-5: Grunion Run Monitoring MM MBIO-6: Post-Lay Hard Bottom Report MM MBIO-7: Hard Bottom Mitigation Fee MM MBIO-4: Release detection and monitoring during HDD MM MBIO-6: Post-Lay Hard Bottom Report MM MBIO-7: Hard Bottom Mitigation Fee Significance Conclusion Draft EIR ES-12 May 2017

15 Impact Section 3.6, Cultural Resources Impact CR-1: Ground disturbance during terrestrial construction activities could disturb unknown historic or archaeological resources. Impact CR-2: Ground disturbance during terrestrial construction activities could directly or indirectly destroy a unique paleontological resource. Impact CR-3: Disturbance of human remains could result from terrestrial construction activities, including remains interred outside of formal cemeteries. Section 3.7, Geology and Soils Impacts less than significant. No proposed mitigation measures. Section 3.8, Greenhouse Gases Impacts less than significant. No proposed mitigation measures. Section 3.9, Hazards and Public Safety Impacts less than significant. No proposed mitigation measures. Section 3.10, Hydrology and Water Quality Impact HWQ-1: Terrestrial Project construction could adversely impact surface water quality by creating pollution, contamination, or nuisance, or by causing regulatory standards to be violated. Mitigations MM CR-1: Cultural and Paleontological Resources Management Plan MM CR-2: Documentation of Potentially Eligible Historic Structures MM CR-1: Cultural and Paleontological Resources Management Plan MM CR-3: Appropriate Treatment of Human Remains MM MBIO-4: Release detection and monitoring Significance Conclusion Draft EIR ES-13 May 2017

16 Impact Section 3.11, Land Use and Recreation Mitigations MM LU-1: Site Access Management MM MBIO-2: Burial Verification Report and Survey Significance Conclusion MM MBIO-3: Fishing Gear Retrieval Impact LU-1: Project activities could conflict with an applicable land use plan, policy, or regulation of an agency with jurisdiction over the Project adopted for the purpose of avoiding or mitigating an environmental impact. MM MBIO-4: Release detection and monitoring during HDD MM TBIO-1: El Segundo Blue Butterfly Habitat Avoidance and Pre-construction Survey MM TBIO-2: Worker Environmental Awareness Training MM TBIO-3: Silvery Legless and Coast Horned Lizard Pre-construction Surveys and Avoidance Measures MM CR-1: Cultural and Paleontological Resources Management Plan MM CR-2: Documentation of Potentially Eligible Historic Structures Draft EIR ES-14 May 2017

17 Impact Impact LU-2: Terrestrial construction activities could temporarily preclude or disrupt existing land uses. Impact LU-3: Project activities could preclude or disrupt existing marine uses. Section 3.12, Noise and Vibration Impact NOISE-1: The Project could expose persons to or generate noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies Impact NOISE-3: Result in a substantial temporary or periodic increase in ambient noise levels in the Project vicinity above levels existing without the Project. Section 3.13, Public Services IMPACT PUB-2: Construction of terrestrial and marine Project components could temporarily limit access to portions of Dockweiler State Beach and the El Segundo Dog Park, and could shift demand for use to other areas of the Beach and Park Mitigations MM LU-1: Site Access Management MM MBIO-5: Grunion Run Monitoring MM NOISE-1: Construction Noise Reduction Measures MM TR-1: Construction Timing Restrictions MM MBIO-2: Burial Verification Report and Survey MM MBIO-3: Fishing Gear Retrieval MM MBIO-4: Release detection and monitoring during HDD MM MBIO-6: Hard Bottom Survey MM MBIO-7: Hard Bottom Mitigation Fee MM NOISE-1: Construction Noise Reduction Measures MM NOISE-1: Construction Noise Reduction Measures MM LU-1: Site Access Management. Significance Conclusion Significant and Unavoidable Significant and Unavoidable Draft EIR ES-15 May 2017

18 Impact Section 3.14, Traffic and Transportation Impact TR-1: Project-related construction activities could temporarily impact traffic capacity on roads and at intersections, and could conflict with applicable measures of performance. Impact TR-2: Project-related construction activities could temporarily impact traffic capacity on roads and at intersections, and could conflict with congestion management plans. Impact TR-3: Project-related construction activities could temporarily impact emergency response or access. Impact TR-4: Project-related construction activities could temporarily impact transit, bicycle, and pedestrian facilities. Mitigations MM TR-1: Construction Timing Restrictions MM TR-1: Construction Timing Restrictions MM TR-1: Construction Timing Restrictions MM TR-1: Construction Timing Restrictions MM TR-2: Maintenance of Pedestrian/Bicycle Connectivity Significance Conclusion Draft EIR ES-16 May 2017

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