Appendix A. Initial Study/NOP/NOP Comment Letters

Transcription

1 Appendix A Initial Study/NOP/NOP Comment Letters

2

3

4

5

6 VERMONT AVE Source: Matrix Environmental, 2009; Rand McNally-Thomas Guide Digital California Edition. HOOVER ST N USC Specific Plan / NOP USC Project Location and Boundaries N

7 N Source: Matrix Environmental, 2009; Google Earth, ADAMS BLVD USC Specific Plan / NOP Existing Uses - Aerial Photograph

8 500-foot Radius Map

9 SCOPING MEETING LOCATION MAP Date: Wednesday, February 18, 2009 Time: 6:00 P.M. to 8:00 P.M. Location: EXPO Center, Community Hall 3980 S. Menlo Avenue Los Angeles, California Source: Google, 2009.

10 CITY OF LOS ANGELES OFFICE OF THE CITY CLERK ROOM 615, CITY HALL LOS ANGELES, CALIFORNIA CALIFORNIA ENVIRONMENTAL QUALITY ACT INITIAL STUDY AND CHECKLIST (Article IV B City CEQA Guidelines) LEAD CITY AGENCY COUNCIL DISTRICT DATE City of Los Angeles 8 and 9 January, 2009 RESPONSIBLE AGENCIES PROJECT TITLE/NO. USC Specific Plan CASE NO. PREVIOUS ACTIONS CASE NO. PROJECT DESCRIPTION: DOES have significant changes from previous actions. DOES NOT have significant changes from previous actions. The University of Southern California Specific Plan (USC) Specific Plan or proposed project has been proposed to guide the physical development of the University Park Campus (UPC) and surrounding area, consistent with the facilities needs of the area through Specifically, the proposed USC Specific Plan provides regulations for development of land within three planning Subareas that are identified in the UPC Master Plan. The proposed project would provide up to approximately 2,500,000 square feet of academic and University-serving uses; up to approximately 350,000 square feet of retail/commercial uses; and up to approximately 2,135,000 square feet of residential development that would provide 5,400 student beds in a variety of housing types and configurations and up to 250 faculty housing units. The proposed project would also provide for a 165,000 square foot hotel and conference center with up to 150 guest rooms with conference and banquet facility areas, sit down restaurant area, and other related amenities. In addition, a new University-affiliated K-8 laboratory school and community educational academy may also be developed. New landscaped public open space areas and associated facilities available for community use would also be provided to enhance the campus and surrounding area. Furthermore, the project also provides for improved pedestrian, bicycle and vehicle circulation and increased pedestrian safety. In some cases, new development would replace existing structures and their related activities. In order to respond to changes in project requirements resulting from future economic needs and demands, the USC Specific Plan also includes an equivalency program to provide flexibility for modifications to land uses and square footages within the Specific Plan, as long as specified environmental thresholds are not exceeded. Further, the USC Specific Plan includes a density transfer provision across the Subareas that comprise the USC Specific Plan. (See attachment A for further description.) ENVIRONMENTAL SETTING: The proposed project is located in a 207 net acre area, in three planning subareas. The project site is located in a generally flat area that is urban and built in nature, consisting of a mixture of commercial, institutional, recreational, educational, and residential uses. (See attachment A for further description.) PROJECT LOCATION The project site includes approximately 207 net acres generally bounded by 30th Street and the alley south of 30th Street to the north, Jefferson Boulevard to the northeast, Exposition Boulevard to the south, Hoover Street and Flower Street to the east, and Vermont Avenue to the west. In addition, the USC Specific Plan also includes a small area to the south of Exposition Boulevard and a second area to the east of the Harbor Freeway (I-110), adjacent to Jefferson Boulevard between Hope and Hill Streets. (See attachment A for further description.)

11 PLANNING DISTRICT South Los Angeles and Southeast Los Angeles EXISTING ZONING SubArea 1: [Q]R4-1, C2-1L. Subarea 2: MR1-2, M2-2. Subarea 3: R4-1-O, [Q]C2-1-O, PF-1-O. MAX. DENSITY ZONING Refer to Attachment A for existing maximum density zoning. STATUS: PRELIMINARY PROPOSED ADOPTED date DOES CONFORM TO PLAN PLANNED LAND USE & ZONE USC Specific Plan: inclusive of academic/university serving, retail, housing, parking, conference/hotel services and/or lab school. SURROUNDING LAND USES Urbanized, consisting of a mixture of commercial, institutional, recreational, educational, and residential uses. MAX. DENSITY PLAN Subarea 1-3:1 FAR. Subarea 2-6:1 FAR. Subarea 3-3:1 FAR. PROJECT DENSITY Subarea 1-3:1. Subarea 2-6:1. Subarea 3-3:1. DOES NOT CONFORM TO PLAN NO DISTRICT PLAN DETERMINATION (To be completed by Lead Agency) On the basis of this initial evaluation: I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions on the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared. I find the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. I find the proposed project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required. SIGNATURE TITLE

12 EVALUATION OF ENVIRONMENTAL IMPACTS: 1) A brief explanation is required for all answers except "No Impact" answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A "No Impact" answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A "No Impact" answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants based on a project-specific screening analysis). 2) All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts. 3) Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less that significant with mitigation, or less than significant. "Potentially Significant Impact" is appropriate if there is substantial evidence that an effect may be significant. If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIR is required. 4) "Negative Declaration: Less Than Significant With Mitigation Incorporated" applies where the incorporation of a mitigation measure has reduced an effect from "Potentially Significant Impact" to "Less Than Significant Impact." The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from Section XVII, "Earlier Analysis," cross referenced). 5) Earlier analysis must be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR, or negative declaration. Section (c)(3)(d). In this case, a brief discussion should identify the following: 1) Earlier Analysis Used. Identify and state where they are available for review. 2) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. 3) Mitigation Measures. For effects that are "Less Than Significant With Mitigation Measures Incorporated," describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project. 6) Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated 7) Supporting Information Sources: A sources list should be attached, and other sources used or individuals contacted should be cited in the discussion. 8) This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project s environmental effects in whichever format is selected. 9) The explanation of each issue should identify: 1) The significance criteria or threshold, if any, used to evaluate each question; and 2) The mitigation measure identified, if any, to reduce the impact to less than significance.

13 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED: The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages. Aesthetics Hazards & Hazardous Materials Public Services Agricultural Resources Hydrology/Water Quality Recreation Air Quality Land Use/Planning Transportation/Traffic Biological Resources Mineral Resources Utilities/Service Systems Cultural Resources Noise Mandatory Findings of Significance Geology/Soils Population/Housing INITIAL STUDY CHECKLIST (To be completed by the Lead City Agency) BACKGROUND PROPONENT NAME City of Los Angeles PROPONENT ADDRESS 200 N. Spring St., Rm 667 AGENCY REQUIRING CHECKLIST PHONE NUMBER DATE SUBMITTED (213) City of Los Angeles PROPOSAL NAME (If Applicable) USC Specific Plan

14 ENVIRONMENTAL IMPACTS (Explanations of all potentially and less than significant impacts are required to be attached on separate sheets) Potentially Significant Impact Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact I. AESTHETICS. Would the project: a. Have a substantial adverse effect on a scenic vista? b. Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings, or other locally recognized desirable aesthetic natural feature within a city-designated scenic highway? c. Substantially degrade the existing visual character or quality of the site and its surroundings? d. Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? II. AGRICULTURAL RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project: a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b. Conflict with existing zoning for agricultural use, or a Williamson Act Contract? c. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use? III. AIR QUALITY. Where available, the significance criteria established by the South Coast Air Quality Management District (SCAQMD) may be relied upon to make the following determinations. Would the project: a. Conflict with or obstruct implementation of the SCAQMD or Congestion Management 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 air basin is non-attainment (ozone, carbon monoxide, & PM 10) under an applicable federal or state ambient air quality standard? d. Expose sensitive receptors to substantial pollutant concentrations? e. Create objectionable odors affecting a substantial number of people?

15 Potentially Significant Impact Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact IV. BIOLOGICAL RESOURCES. Would the project: a. Have a substantial adverse effect, either directly or through habitat modification, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in the City or regional plans, policies, regulations by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c. Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh vernal pool, coastal, etc.) Through direct removal, filling, hydrological interruption, or other means? d. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? e. Conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance (e.g., oak trees or California walnut woodlands)? f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? V. CULTURAL RESOURCES: Would the project: a. Cause a substantial adverse change in significance of a historical resource as defined in State CEQA ? b. Cause a substantial adverse change in significance of an archaeological resource pursuant to State CEQA ? c. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? d. Disturb any human remains, including those interred outside of formal cemeteries? VI. GEOLOGY AND SOILS. Would the project: a. Expose people or structures to potential substantial adverse effects, including the risk of loss, injury or death involving : i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ii. Strong seismic ground shaking?

16 Potentially Significant Impact Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact iii. Seismic-related ground failure, including liquefaction? iv. Landslides? b. Result in substantial soil erosion or the loss of topsoil? c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potential result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? d. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? e. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? VII. HAZARDS AND HAZARDOUS MATERIALS. Would the project: a. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials b. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an existing or proposed school? d. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section and, as a result, would it 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 two 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 area? f. For a project within the vicinity of a private airstrip, would the project result in a safety hazard for the people residing or working in the area? g. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? h. 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?

17 Potentially Significant Impact Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact VIII. HYDROLOGY AND WATER QUALITY. Would the project result in: a. Violate any water quality standards or waste discharge requirements? b. Substantially deplete groundwater supplies or interfere with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of preexisting nearby wells would drop to a level which would not support existing land uses or planned land uses for which permits have been granted)? c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site? d. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in an manner which would result in flooding on- or off site? e. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? f. Otherwise substantially degrade water quality? g. Place housing within a 100-year flood plain as mapped on federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? h. Place within a 100-year flood plain structures which would impede or redirect flood flows? i. Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? j. Inundation by seiche, tsunami, or mudflow? IX. LAND USE AND PLANNING. Would the project: a. Physically divide an established community? b. Conflict with 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, coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c. Conflict with any applicable habitat conservation plan or natural community conservation plan? X. MINERAL RESOURCES. Would the project: a. Result in the loss of availability of a known mineral resource that would be of value to the region and the

18 Potentially Significant Impact Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact residents of the state? b. Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? XI. NOISE. Would the project result in: a. Exposure of persons to or generation of noise in level in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b. Exposure of people to or generation of excessive groundborne vibration or groundborne noise levels? c. A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? d. A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? 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, would the project expose people residing or working in the project area to excessive noise levels? f. For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? XII. POPULATION AND HOUSING. Would the project: a. Induce substantial population growth in an area either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? b. Displace substantial numbers of existing housing necessitating the construction of replacement housing elsewhere? c. Displace substantial numbers of people necessitating the construction of replacement housing elsewhere? XIII. PUBLIC SERVICES. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: a. Fire protection? b. Police protection? c. Schools?

19 Potentially Significant Impact Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact d. Parks? e. Other governmental services (including roads)? XIV. RECREATION. a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? XV. TRANSPORTATION/CIRCULATION. Would the project: a. Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? b. Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways? c. 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. Substantially increase hazards to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e. Result in inadequate emergency access? f. Result in inadequate parking capacity? g. Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? XVI. UTILITIES. Would the project: a. Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? b. Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? c. Require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? d. Have sufficient water supplies available to serve the project from existing entitlements and resource, or are new or expanded entitlements needed?

20 Potentially Significant Impact Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact e. Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project s projected demand in addition to the provider s existing commitments? f. Be served by a landfill with sufficient permitted capacity to accommodate the project s solid waste disposal needs? g. Comply with federal, state, and local statutes and regulations related to solid waste? h. Other utilities and service systems? XVII. MANDATORY FINDINGS OF SIGNIFICANCE. a. Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b. Does the project have impacts which are individually limited, but cumulatively considerable?("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 the effects of probable future projects). c. Does the project have environmental effects which cause substantial adverse effects on human beings, either directly or indirectly?

21 DISCUSSION OF THE ENVIRONMENTAL EVALUATION (Attach additional sheets if necessary) PREPARED BY TITLE TELEPHONE # DATE Stephanie Eyestone Jones Matrix Environmental 6701 Center Drive, Suite 900 Los Angeles, CA President (424) January 2009

22 ATTACHMENT A PROJECT DESCRIPTION A. INTRODUCTION The University of Southern California (University) has completed its 2030 University Park Campus Master Plan (UPC Master Plan), a framework plan that addresses the future physical development of the University Park Campus and the quality of its surrounding community in the coming years. The UPC Master Plan represents a three-year planning effort that was driven by the ideals expressed in the Role and Mission of the University of Southern California (USC) 1 and in support of USC s Plan for Increasing Academic Excellence. 2 The USC Specific Plan or proposed project has been proposed to guide the physical development of the campus and surrounding area, consistent with the facilities needs of the area through Specifically, the proposed USC Specific Plan would set forth regulations for new development occurring within three of the UPC Master Plan Subareas. As discussed in detail below, the USC Specific Plan would provide up to 2,500,000 square feet of academic and University-serving uses; up to 350,000 square feet of retail/commercial uses; and up to 2,135,000 square feet of residential uses providing up to 5,400 student beds in a variety of housing types and configurations and approximately 250 faculty housing units. The Specific Plan would also provide for a 165,000 square foot hotel and conference center with up to 150 guest rooms, conference and banquet facility areas, sit down restaurant area, a swimming pool, and other related amenities. In addition, a new University-affiliated K-8 laboratory school and community educational academy may also be developed. New landscaped public open space areas and associated facilities for community use are also proposed to enhance the campus and surrounding area. Furthermore, the proposed project would also provide for improved pedestrian, bicycle, and vehicle circulation and increased pedestrian safety. In order to respond to the need for future land uses resulting from changing economic and market conditions, the USC Specific Plan also includes an equivalency program to provide flexibility for modifications to the proposed land uses and square footages within the Specific Plan area as long as specified environmental thresholds are not exceeded. Further, the USC Specific Plan includes a density transfer provision across the three Subareas of the USC Specific Plan. 1 2 Adopted by the USC Board of Trustees, February Approved by the USC Board of Trustees, October 6, City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-1 PRELIMINARY WORKING DRAFT Work in Progress

23 Attachment A - Project Description B. GOALS AND OBJECTIVES The primary objectives of the USC Specific Plan include: a) increasing the ratio of academic space per student to a level that better supports academic excellence; b) increasing the amount of University-affiliated housing available in the campus area with the two-fold objective of making existing housing in the project vicinity available to non-university affiliated residents and decreasing the commute time for University students, faculty and staff in order to reduce traffic congestion in the area; and c) providing services that meet the needs of students, faculty and staff and also enhance the community. Incorporating University-affiliated housing as part of the campus community meets two primary UPC Master Plan objectives. Specifically, University-affiliated housing contributes to the residential college model of education, which values and incorporates the 24-hour learning environment and stabilizes and improves the surrounding neighborhood by making more housing available to nonuniversity affiliated residents. In addition, creating a more pedestrian-oriented environment has many positive benefits including reduced traffic, improved air quality and improved neighborhood safety. A detailed list of project goals and objectives will be provided as part of the Environmental Impact Report (EIR) to be prepared for the proposed project. C. PROJECT LOCATION AND SURROUNDING USES Project Location and Surrounding Uses The USC Specific Plan area is comprised of approximately 207 net acres located approximately 1.5 miles southwest of downtown Los Angeles within the South Los Angeles and Southeast Los Angeles Community Plan areas of the City of Los Angeles, as shown in Figure A-1 on page A-3. The proposed USC Specific Plan area is generally bounded by 30 th Street and the alley south of 30 th Street to the north, Jefferson Boulevard to the northeast, Exposition Boulevard to the south, Hoover Street and Flower Street to the east, and Vermont Avenue to the west. In addition, as shown in Figure A-1, the USC Specific Plan also includes a small area to the south of Exposition Boulevard and a second area to the east of the Harbor Freeway (I-110), adjacent to Jefferson Boulevard between Hope and Hill Streets. The USC Specific Plan area excludes properties within Subareas 4, 5, and 6 of the UPC Master Plan located to the north and northeast of the USC Specific Plan boundaries. The majority of the properties in Subareas 4, 5, and 6 are not University-owned, and therefore were excluded from the USC Specific Plan. In addition, a small UPC Master Plan parcel east of the I-110 Freeway, below 37 th Street is also not included in the USC Specific Plan as it is isolated from the remaining parts of the project area. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-2 PRELIMINARY WORKING DRAFT Work in Progress

24 VERMONT AVE Source: Matrix Environmental, 2009; Rand McNally-Thomas Guide Digital California Edition. HOOVER ST USC Specific Plan / Initial Study N USC Figure A-1 Project Location and Boundaries N

25 Attachment A - Project Description The surrounding project vicinity includes a mix of commercial, institutional, recreational, educational, residential and community-serving uses. As shown in the aerial photograph provided in Figure A-2 on page A-5, much of the area to the north and east of the project site includes a varied mix of uses, many of which are Universityserving, such as academic buildings, student-serving uses, various commercial uses, and residential uses, as well as community-serving uses such as the Shrine Auditorium, the Hebrew Union College, the 32 nd Street Elementary School, the USC Catholic Center, the Hillel Center and the Hoover Intergenerational Child Care Center. Exposition Park, a public-serving facility containing a variety of cultural and athletic venues such as the Los Angeles Memorial Coliseum, the Los Angeles Sports Arena, and the National History Museum of Los Angeles County is located to the south. The area further to the east of much of the project site is dominated by the I-110 Freeway, which creates a physical barrier in the area. In addition, the western side of the project site is bounded by Vermont Avenue, a mixed-use, but predominantly commercial corridor, with residential neighborhoods to the west. Access to the project site is provided by I-110 and the Santa Monica Freeway (I-10). Primary roadways serving the project site include Adams Boulevard, Jefferson Boulevard and Exposition Avenue generally in the east-west direction; and Vermont Avenue, Figueroa Street, and Flower Street generally in the north-south direction. Within the project vicinity, Figueroa Street is referred to as the Figueroa Corridor. The Figueroa Corridor links the University and other regional destinations in the project vicinity with downtown Los Angeles. The City recently addressed future development along the Figueroa Corridor through a General Plan amendment which permits increased floor area ratios for mixed-use developments within the corridor. Public transportation in the project vicinity is provided by the Los Angeles County Metropolitan Transportation Authority (Metro), with both local and express lines operating through and/or adjacent to the project site; and the City of Los Angeles DASH service, which links the project site with the downtown area, via the Figueroa Corridor. Additional bus service is provided in the nearby Harbor Transit way which carries buses operated by Metro, LADOT and the Orange County Transportation Authority. In addition, the project site will be served in the future by the Metro Mid City/Exposition Boulevard Light Rail Transit line that passes through the project area, with proposed stops at Jefferson Boulevard/Flower Street, Trousdale Parkway/Exposition Boulevard and Vermont Avenue/Exposition Boulevard. This light rail line, which will run from Downtown Los Angeles to Culver City, is currently under construction south of the project site along Exposition Boulevard. Service is anticipated to begin in The University also operates an extensive private shuttle bus system serving the project vicinity, the Union Station in Downtown Los Angeles, and other University facilities in the region. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-4 PRELIMINARY WORKING DRAFT Work in Progress

26 N Source: Matrix Environmental, 2009; Google Earth, ADAMS BLVD USC Specific Plan / Initial Study Figure A-2 Existing Uses - Aerial Photograph

27 Attachment A - Project Description D. EXISTING PROJECT SITE CONDITIONS The project site comprises a total of approximately 207 net acres. Of this area, approximately 201 net acres are currently owned by the University. In general, these University-owned areas include academic space and University-affiliated uses, residential uses, and retail/commercial uses. The 6 net acres within the project area that are not currently University-owned include the Jessie L. Terry Manor senior housing development, City of Los Angeles Fire Station 15 that is anticipated to be relocated by the Los Angeles Fire Department, a gas station that is proposed to be redeveloped with a mixed-use student housing project, and the United University Church. Existing University development within the project vicinity serves a University population that includes approximately 16,000 undergraduate students, 14,500 graduate students, 1,700 full-time faculty, 5,200 staff employees and 2,000 adjunct professors or lecturers. The project site is located within the boundaries of the South Los Angeles and Southeast Los Angeles Community Plans of the City of Los Angeles, as delineated further below. A portion of the project site is also located within the boundaries of the Community Redevelopment Agency of Los Angeles (CRA/LA) Exposition/University Park Redevelopment Project Area (formerly known as the Hoover and Hoover Expansion Redevelopment Project). The Redevelopment Plan goals call for the elimination of physical, economic and social blight by the creation of catalytic developments that promote a thriving business environment and enhance the surrounding residential community. The Redevelopment Plan s Land Use controls expire January 1, As shown in Figure A-1, the project site includes three planning Subareas. An overview of existing conditions within each of these Subareas is provided below. Subarea 1, referred to as the Academic Core Area is comprised of approximately 166 net acres that contain the core University activities. Approximately 163 net acres of the land within this Subarea are owned by the University. The majority of the area constitutes the generally recognized core campus area. Subarea 1 also includes approximately 4 net acres southeast of the intersection of Exposition Boulevard and Figueroa Street. Overall, Subarea 1 includes approximately 6,030,800 gross square feet (gsf) of building area. Existing buildings include academic/administrative uses; student housing and student life facilities; and athletic and recreation facilities. In addition, Subarea 1 includes parking facilities, roadways and landscaped open space areas that include plazas, courtyards and pedestrian and bicycle paths. Housing is provided for approximately 2,900 students within Subarea 1. Athletic and recreational facilities are concentrated in the western half of the Subarea 1, with playfields, City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-6 PRELIMINARY WORKING DRAFT Work in Progress

28 Attachment A - Project Description competition facilities, practice fields, and buildings and other facilities devoted to intercollegiate and intramural sports. Development along Figueroa Street includes retail/commercial and hotel uses that meet non-university as well as University needs. Buildings within Subarea 1 range in height, with most buildings in the low to midrise/four story range and a few taller buildings of up to approximately 14 stories or 150 feet. The portion of Subarea 1 lying west of Figueroa Street is designated for High Medium Residential uses by the South Los Angeles Community Plan, and zoned [Q]R4-1 (Qualified Multiple Dwelling Zone) by the Los Angeles Municipal Code (LAMC). The Q restriction limits use of the property to University and University-related uses, and requires a Plan Approval for any addition or change to University facilities. Based on the zoning, the allowable Floor Area Ratio (FAR) west of Figueroa Street is 3.0:1, and the height limits are unrestricted. The remainder of Subarea 1, located east of Figueroa Street and west of Flower Street, is designated for Community Commercial uses by the Southeast Los Angeles Community Plan and zoned C2-1L. The Community Plan allows for development at a FAR of 3:1 and/or 4.5:1 for mixed-use projects, subject to certain requirements, and rezoning of such project sites to Height District 2-D. Based on the existing C2-1L zoning, this area is currently limited to a maximum FAR of 1.5:1 and a maximum height of 6 stories and 75 feet. A small parcel lying southeast of Exposition Boulevard and Flower Street in Subarea 1 is designated as Community Commercial in the Southeast Los Angeles Community Plan and currently zoned as C2-1L (FAR of 1.5:1 with a 6 story/75 foot height limit) by the LAMC. Subarea 2, referred to as the East Area consists of approximately 11 net acres located to the east of the I-110 Freeway and north of the railway right of way/extension of Exposition Boulevard. The University owns all of the land in Subarea 2. Existing buildings in Subarea 2 provide University support/administrative/warehouse uses, a parking structure, and Tram parking. These buildings are up to approximately 100 feet in height. The Southeast Los Angeles Community Plan designates the majority of Subarea 2 for Limited Manufacturing uses with a small portion located east of Hope Street for Public Facilities uses. The land in Subarea 2 is primarily designated for Limited Manufacturing uses and zoned MR1-2 (Restricted Light Industrial, Height District 2). Thus, development in this Subarea is limited to an FAR of 6:1, with unlimited City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-7 PRELIMINARY WORKING DRAFT Work in Progress

29 Attachment A - Project Description building heights. One property within Subarea 2 has an Open Space designation with a zoning of M2-2 (Light Industrial). Subarea 3, referred to as the University Village, Cardinal/Century Area includes approximately 30 net acres of land located across Jefferson Boulevard north of the main/core campus area. All of the development within this Subarea is owned by the University, with the exception of an approximately 3 net acre parcel at the western edge of the Subarea that includes the Jessie L. Terry Manor senior housing development, and an existing 0.3--acre fire station site (Fire Station 15) on Jefferson Boulevard that is planned for relocation by the Los Angeles Fire Department. University-owned land within the western side of the Subarea includes residential buildings that provide housing for approximately 1,150 students. Buildings are typically 2 to 3 stories in height. The eastern portion of Subarea 3 includes the University-owned University Village Shopping Center, which includes approximately 289,000 gross square feet of area. This shopping center contains retail space, including a food court, restaurant, cinema, and numerous retail stores, as well as University-affiliated office space. The existing buildings within the shopping center are clustered within a larger surface parking area and are one to two stories in height. The South Los Angeles Community Plan designates the eastern portion of Subarea 3 as Community Commercial. The zoning designation is [Q]C2-1-O. Based on this zoning, this commercial area is restricted to a FAR of 1.5:1 with unlimited building heights. The allowable residential density pursuant to the Q restriction is 1 unit per 800 square feet of the lot area. The property for Fire Station 15 is zoned PF-1-O and designated for Public Facilities uses. The western portion of Subarea 3 is designated in the South Los Angeles Community Plan as High Medium Residential and is zoned R4-1-O. As such, the FAR in the residential area is limited to 3:1, with unlimited building heights, and a residential density of 1 unit per 400 square feet of the lot area and 1 guest room per 400 square feet of the lot area. E. PROJECT BACKGROUND The University of Southern California is one of the world s leading private research universities having served Los Angeles, the nation and international communities for more than 128 years from its current location in University Park. The University was founded in 1880 on a 7.5 acre-site, located on a super block within the then local, urban grid system. Over the years, the University has grown and developed around the original University site. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-8 PRELIMINARY WORKING DRAFT Work in Progress

30 Attachment A - Project Description Recently, the University completed the UPC Master Plan to address current and future University and Community needs and to guide future development of the University Park campus and surrounding area. Preparation of the UPC Master Plan began in The University s planning process was directed by a University Master Plan Committee assisted by a series of working group sub-committees, which were formed to address specific issues as they arose in the planning process. The UPC Master Plan Committee was also assisted by an advisory committee comprised of community stakeholders in the community, and made up of representatives of numerous community groups. The Master Plan moves beyond previous planning efforts in that it addresses current and emerging needs for the University, enhancing the campus amenities and more fully addressing the relationship between the core campus located south of Jefferson Boulevard (Subarea 1) and the surrounding areas. In addition, the UPC Master Plan addresses local community interest regarding impacts of growth on surrounding neighborhoods and reflects the University s efforts to collaborate with the community to create development that will benefit both the University and the community. The proposed USC Specific Plan is a City initiated plan to establish the land use and regulatory framework for the physical development of the USC campus and surrounding area in order to meet University and community goals. F. DESCRIPTION OF PROPOSED PROJECT Proposed University Development The Los Angeles City Council recently initiated the study and preparation of the USC Specific Plan to implement portions of the development and entitlement framework identified in the UPC Master Plan. The USC Specific Plan has been proposed as an appropriate mechanism for regulating future growth in the project area as it provides for University-affiliated development in a comprehensive and orderly manner that addresses the interrelationships between the University and neighboring uses. The proposed project specifically addresses development of University-owned parcels and parcels providing for University-affiliated housing, which may include University-affiliated mixed-uses within the same building. Primary objectives of the proposed project include: a) increasing the ratio of academic space per student to a level that better supports academic excellence; b) increasing the amount of University-affiliated housing available in the campus area with the two-fold objective of making existing housing in the project vicinity available to nonuniversity affiliated residents and decreasing the commute time for University students, faculty and staff in order to reduce traffic congestion in the area; and c) providing services that meet the needs of students, faculty, staff and also enhance the City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-9 PRELIMINARY WORKING DRAFT Work in Progress

31 Attachment A - Project Description community. Incorporating University-affiliated housing as part of the campus community meets two primary UPC Master Plan objectives. Specifically, new housing contributes to the residential college model of education, which values and incorporates the 24-hour learning environment while stabilizing and improving the surrounding neighborhood by making more housing available to non-university affiliated residents. In addition, creating a more pedestrian-oriented environment has many positive benefits including reduced traffic, improved air quality and improved neighborhood safety Development under the proposed USC Specific Plan is intended to meet the needs of the site populations expected by the University, inclusive of the existing populations and small annual increases in student enrollment, staff and faculty through While the University currently has a policy of no growth for undergraduates, in light of historic University growth, a small annual growth rate has been assumed for undergraduate students that could result in an undergraduate student population of approximately 18,500 by In addition, approximately 17,500 graduate students, 1,900 full-time faculty and 8,700 staff workers are anticipated by Adjunct professors and lecturers would also continue to be present on site. When compared with recent enrollment and staffing, this represents an increase of approximately 2,500 undergraduate students, 3,000 graduate students, 200 full-time faculty and 3,500 staff workers through the year As described in more detail below, the proposed USC Specific Plan addresses development within three planning Subareas of the UPC Master Plan. As shown in Table A-1 on page A-11, proposed development within these three Subareas would provide up to approximately 2,500,000 square feet of academic and University-serving uses; up to approximately 350,000 square feet of retail/commercial uses; and up to approximately 2,135,000 square feet of residential development that would provide up to 5,400 student beds in a variety of housing types and configurations and approximately 250 faculty housing units. The proposed project would also provide for a 165,000 square foot hotel and conference center with up to 150 guest rooms, conference and banquet facility areas, sit down restaurant area, a swimming pool, and other related amenities. In addition, a new University-affiliated K-8 laboratory school and community educational academy may also be developed. The USC Specific Plan would also include new landscaped open space areas and associated facilities for community use to enhance the campus and surrounding area. The project would also provide for improved pedestrian, bicycle and vehicle circulation and increased pedestrian safety. In some cases, new development would replace existing structures and their related activities. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-10 PRELIMINARY WORKING DRAFT Work in Progress

32 Attachment A - Project Description Table A-1 Maximum New Development for the Proposed USC Specific Plan a Use Subarea 1: University Park Academic Core Subarea 2: University Park East Subarea 3: University Village Cardinal/ Century Total Permitted by USC Specific Plan Academic/University-Serving 1,500,000 sf 500,000 sf 500,000 sf 2,500,000 sf Retail/commercial 350,000 sf 350,000 sf Housing Amount -- Sq. Ft. 70,000 sf 2,065,000 sf 2,135,000 sf Estimated No. of Student Beds 200 beds 5,200 beds 5,400 beds Estimated No. of Faculty Units units 250 units Hotel/Conference Areas 165,000 sf b 165,000 sf (150 keys) Lab School & Community Educational Academy 80,000 80,000 sf Maximum Subarea Total 1,570,000 sf c 500,000 sf c 3,160,000 sf c 5,230,000 sf a b c The amounts shown in this table represent new development to be constructed by, or in conjunction with, the University. In some cases, the new development would replace existing development and the net increase in development would be less than shown in the table. For example, the new development in Subarea 3 would only result in an increase of approximately 4,050 beds over the existing 1,150 beds in the Subarea. Includes 50,000 sf of conference areas. Each Subarea could exceed the maximum Subarea total through a transfer/equivalency process set forth the USC Specific Plan, but in no case would the Specific Plan entitlement exceed the 5,230,000 square feet maximum total. Source: University of Southern California, As part of the USC Specific Plan, an equivalency program will be included that will provide flexibility for modifications to land uses and square footages within the Specific Plan in order to respond to the need for future land uses resulting from changing economic and market conditions. The equivalency program would permit land uses to be exchanged for certain other permitted land uses so long as no additional environmental impacts result from such an exchange. For example, there may be increases in the square footages of certain land uses (i.e., academic or residential) in exchange for decreases in the square footages of other land uses (i.e., hotel or retail uses), provided that no additional environmental impacts occur. If the City concludes that the proposed exchange in land uses would result in environmental impacts which are greater than those identified the EIR prepared for the project, then additional environmental review would need to be completed prior to a decision by the City to approve the requested exchange of land uses. Additionally, the Specific Plan proposes to allow transfers of floor area entitled by the Specific Plan between Subareas, provided City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-11 PRELIMINARY WORKING DRAFT Work in Progress

33 Attachment A - Project Description that the increase in floor area does not exceed fifteen percent of that permitted for the Subarea, and that the overall floor area entitled by the Specific Plan is not exceeded. The general character of each of the Subareas and the proposed base level amounts of development within each Subarea, prior to density or equivalency transfers would be as follows: Subarea 1, the Academic Core - Under the proposed USC Specific Plan, Subarea 1 would continue to serve as the center of University activities with the addition of up to approximately 1.57 million square feet of new buildings for academic use (teaching and research, with related administration and support services) and the addition of approximately 200 new beds for student housing. New buildings for this Subarea would be developed on existing vacant and/or underutilized sites. Landscaped open space areas and pedestrian paths would integrate the buildings to create a cohesive campus setting. Consistent with the existing building heights occurring on the campus within Subarea 1, the majority of the new buildings would be less than 75 feet in height with some buildings of up to 150 feet in height, consistent with the taller building heights already occurring within the campus. As previously discussed, Subarea 1 would be improved with new landscaped open space areas and pedestrian paths, which would further maintain and enhance the existing park-like setting of the campus. In addition, access and circulation improvements would maintain the pedestrian-oriented nature of the campus and reduce the need for vehicle circulation through the inner areas of the campus. Development within Subarea 1 would be sensitive to the historic resources that help define the character of this Subarea. Subarea 2, East Area Under the proposed USC Specific Plan, development within Subarea 2 would expand the existing ancillary University uses (e.g., administration/support) already occurring in the Subarea. As part of the USC Specific Plan, approximately 500,000 square feet of development could be provided within Subarea 2. In addition, the majority of the buildings would not be expected to exceed heights of six levels and 75 feet. Subarea 3, University Village, Cardinal/Century Under the proposed project, the majority of the existing buildings within Subarea 3 would be replaced with new development that would be organized along pedestrian-friendly streets, landscaped medians, courtyards and plazas. Development within this Subarea is envisioned to create an attractive gathering place where students, faculty, staff, parents and community will have opportunities to live, work, shop, and spend City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-12 PRELIMINARY WORKING DRAFT Work in Progress

34 Attachment A - Project Description leisure time. Proposed uses for Subarea 3 would include approximately 500,000 square feet of new academic space, and approximately 350,000 square feet of neighborhood-serving retail/commercial uses. New residential uses within this Subarea would provide approximately 5,000 student beds within approximately 2,065,000 square feet of area. This number of beds would represent an increase of 4,050 beds within this Subarea when compared with existing conditions. In addition, it is anticipated that approximately 250 faculty housing units could be provided. New housing would include a variety of housing types to serve graduate students, faculty and undergraduate students. Within Subarea 3, the proposed USC Specific Plan may also provide for an approximately 165,000 square foot hotel and conference center with up to 150 guest rooms, conference and banquet areas, sit down restaurant area, swimming pool and other related amenities. A new University-affiliated laboratory, K-8 school and community educational academy may also be provided within Subarea 3. Under the proposed USC Specific Plan, the non-residential uses (retail, academic, etc.) within Subarea 3 would generally be placed at ground level, providing appropriate accessibility for those uses, and providing a mixed-use streetscape. A large portion-of the ground floor retail uses would be provided along pedestrian-friendly streets and plazas. Buildings would generally be a maximum of 75 feet in height with a select number of buildings with heights of up to 150 feet. This Subarea would also include a public open space and park area. Components of the USC Specific Plan As indicated above, the majority of the project development would be implemented under the provisions of a new USC Specific Plan. The USC Specific Plan would set regulatory limits on the allowable development permitted in each Subarea, including limits on densities, heights, floor area ratios. In addition, as indicted above, the USC Specific Plan would include an equivalency program to provide flexibility for modifications to land uses and square footages within the Specific Plan area as well as a density/far transfer provision across the Subareas that comprise the USC Specific Plan as long as specified environmental thresholds are not exceeded. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-13 PRELIMINARY WORKING DRAFT Work in Progress

35 Attachment A - Project Description The USC Specific Plan would also include regulations and guidelines that would address the following: Open Space and Landscaping Proposed development would be implemented with landscaping that enhances building aesthetics and integrates new buildings with open space areas. In accordance with the USC Specific Plan, landscaping would be selected from a palette of materials that help to enforce the park-like, campus setting in Subarea 1 and to provide compatible landscape treatments throughout Subareas 2 and 3, as adapted to the distinctive character of each Subarea and ensuring compatibility with surroundings. Circulation, Parking and Access (Vehicular, Pedestrian and Bicycles) As part of the proposed project, portions of Jefferson and Hoover Boulevards within the project area would be reduced from four through-lanes to two through-lanes, with a dedicated left turn lane and right turn pockets. This improvement would allow for the creation of bike lanes and increased sidewalk widths on both sides of the roadway to increase pedestrian safety and promote pedestrian activity. In addition, a portion of Hoover Street may be realigned to intersect Jefferson Boulevard at a right angle across from Watt Way to provide for improved pedestrian and bicycle connections. The project will also reduce the width of McClintock Ave and restrict through-traffic on this street up to the south of 30 th Street. Overall, the project would generally continue to be served by the existing roadway system. In addition, the project site would continue to be served by the existing University-operated tram system which would tie the planning Subareas together and reduce vehicle travel within Subarea 1. Rerouting of the tram system would occur as necessary. Further, the University would continue to operate its Transportation Demand Management Program, with a focus on utilizing the Exposition Boulevard Light Rail Transit Line planned to be completed by 2010 as described above. Modifications would be made to the pedestrian/bicycle system within Subarea 1, with reductions in vehicles and improved pedestrian and bicycle accommodations within the core campus. These improved pedestrian and bicycle accommodations would link to other such improvements along Jefferson Boulevard and Hoover Street, and extend into the other planning Subareas, particularly Subarea 3 to the north of Subarea 1. Parking would be provided to meet project needs based on parking demand studies that identify parking rates for the University population and various uses proposed under the Specific Plan. For Subarea 1 in particular, the University would continue to rely on a City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-14 PRELIMINARY WORKING DRAFT Work in Progress

36 Attachment A - Project Description parking demand model that assesses parking demand based on parking studies and tracks the parking available within the Campus parking facilities. Under this model, adequate parking would be provided through a pool approach. As a substantial increase in enrollment is not proposed, many of the new academic and University-serving buildings in Subareas 1 and 2 are anticipated to be accommodated through this pool parking approach. In addition, based on demand studies, the requirements for parking would be reflected as development criteria established in the USC Specific Plan. These parking requirements would differ from current LAMC parking requirements and would encourage the use of transit and non-motorized transportation. Sustainability The University currently implements an extensive program to promote sustainability. Sustainability practices are implemented and promoted within all facets of the University including academics, building and infrastructure, transportation, waste management, and water management. Some of the key features of these practices include energy conservation through the selection of energy-efficient fixtures and equipment control systems, waste reduction through the purchase and use of recycled materials and recycling of University waste materials, water conservation through the use of irrigation/sprinkler controls and low consumption fixtures, and smart growth with the construction of new buildings that achieve Leadership in Energy and Environmental Design (LEED) certification per the US Green Building Council (USGBC) guidelines, and transportation programs that encourage alternative modes of transportation. The University would continue its commitment to smart growth and sustainable practices through incorporation of the following project features: (1) substantial amounts of new housing that would eliminate commuting for large numbers of students, faculty and staff; (2) enhancement of pedestrian and bicycle linkages throughout the plan area to reduce the need for vehicles; and (3) accessibility enhancements and linkages that make use of the site s accessibility to nearby freeways, public transit, and in particular, the new Metro Mid City/Exposition Boulevard Light Rail Transit Line. Additionally, the project would further the University s progress in sustainability with specific programs in each of the following areas: (1) Outdoor Environments and Land Use; (2) Transportation; (3) Water; (4) Energy; (5) Waste/Recycling/Hazardous Waste; and (6) Building Design. In addition, new buildings within the proposed USC Specific Plan area would be designed and constructed to achieve LEED certification. Specific sustainability features and practices that may be implemented include such items as selection of landscaping/vegetation that is low in water consumption, controlled watering of landscaping, the use of pervious paving, use of green/cool roofs, use of low-energy lighting, and/or incorporation of energy saving features into building design (e.g. use of passive controls, shading, solar energy, ventilation, appropriate building materials, etc.), City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-15 PRELIMINARY WORKING DRAFT Work in Progress

37 Attachment A - Project Description and use of high-efficiency toilets, urinals, clothes washers and dishwashers. These features and practices would reduce energy and water usage and thus reduce associated greenhouse gas (GHG) emissions. Construction Construction of the project would be implemented in phases over a number of years extending to As part of the project, a Construction Staging and Traffic Management Plan would be implemented during construction to ensure that adequate and safe access and parking remains available within the project site during construction activities. The Construction Staging and Traffic Management Plan will specifically identify traffic control measures, signs, and delineators to be implemented by the construction contractors. F. REQUIRED APPROVALS The City of Los Angeles has the principal responsibility for approving the proposed project. Approvals required for development of the proposed project may include, but not limited to, the following: General Plan Amendments, including street redesignations; Specific Plan, including alcohol approvals; Zone Changes; Development Agreement; Vesting Tentative Tract Map(s), including potential street vacation; Director s Approval/Project Permit Compliance Review; Financings such as bond financing; Approvals under the Exposition/University Park Redevelopment Project Area; Grading, excavation, and building permits; Haul Route Approval, as necessary; and Any additional actions as may be deemed necessary or desirable. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page A-16 PRELIMINARY WORKING DRAFT Work in Progress

38 ATTACHMENT B EXPLANATION OF CHECKLIST DETERMINATIONS The following discussion provides responses to each of the questions set forth in the City of Los Angeles Initial Study Checklist. The responses below indicate those issues that are expected to be addressed in an Environmental Impact Report (EIR) and demonstrate why other issues will not result in a potentially significant environmental impact and thus do not need to be addressed further in an EIR. The questions with responses that indicate a Potentially Significant Impact do not presume that a significant environmental impact would result from the project. Rather, such responses indicate those issues that will be analyzed in an EIR with conclusions of impact reached as part of the analysis within that future document. I. AESTHETICS. Would the project: a. Have a substantial adverse effect on a scenic vista? Potentially Significant Impact. The project site is located in an urbanized area that is essentially flat, without overlooks or features that support long range views. Visual resources in the project area include open space areas (e.g., Exposition Park) and distinctive buildings. The project would provide for the development of new buildings and associated improvements within the project site. Thus, it is recommended that analysis of potential impacts on scenic vistas be addressed further in an EIR. b. Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings, or other locally recognized desirable aesthetic natural feature within a city-designated scenic highway? No Impact. As noted above, the project site is located in an urbanized area. None of the numerous public roadways that pass through, or that are adjacent to, the project site are designated as a scenic highway by the City or the State. Thus, no potential impacts to a City-designated scenic highway would occur and further analysis of this issue is not required. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-1 PRELIMINARY WORKING DRAFT Work in Progress

39 Attachment B Explanation of Checklist Determination c. Substantially degrade the existing visual character or quality of the site and its surroundings? Potentially Significant Impact. The proposed project would provide for the development of new buildings with a range of building heights and building sizes. These new buildings would be integrated with new landscaping and open space areas. These improvements would be implemented in accordance with the proposed USC Specific Plan requirements, which would limit the allowable development permitted in each Subarea, including limits on densities, heights, and floor area ratios. While it is expected that the proposed project would improve the visual character within the Subareas that comprise the site, it is recommended that this issue be analyzed further in an EIR. d. Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Potentially Significant Impact. The project site is located within an urbanized area that is characterized by medium to high ambient nighttime artificial lighting. Traffic on local streets also contributes to overall ambient artificial light levels in the area. The proposed project would require on-site nighttime illumination for architectural highlighting, outdoor activities, pedestrian path lighting, and security purposes. While such lighting is typical of lighting found in the general urban landscape, the project lighting could contribute to increased ambient lighting conditions. Therefore, it is recommended that the potential impacts associated with light and glare be analyzed further in an EIR. Shading impacts are influenced by the height and bulk of a structure, the time of year, the duration of shading during the day, and the sensitivity of the surrounding land uses. Certain uses that rely on lighting, such as swimming pools and solar collectors are considered shadow sensitive uses. Residential and recreation areas are also considered shadow sensitive uses. The proposed project would provide for the development of new buildings, the majority of which would be less than 75 feet in height. However, in select locations, buildings could be up to 150 feet in height and could cast shadows onto shadow sensitive uses. Therefore, it is recommended that the potential impacts associated with shading be analyzed further in an EIR. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-2 PRELIMINARY WORKING DRAFT Work in Progress

40 Attachment B Explanation of Checklist Determination II. AGRICULTURAL RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California agricultural land evaluation and site assessment model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project: a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? No Impact. The project site is not located on designated Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program. According to the 2004 Important Farmland Map, the project site is located in an area designated as Urban and Built-Up Land. 1 In addition, no agricultural or other related activities currently occur on the site or within the project vicinity. Therefore, no impacts to farmland would occur and further analysis of this issue is not required. b. Conflict the existing zoning for agricultural use or a Williamson Act Contract? No Impact. The existing zoning for the project site extends over a far reaching range of zoning designations, including C2, RD1.5, R3, R4, MR1, PF and P1, pursuant to the Los Angeles Municipal Code (LAMC). No agricultural zoning is present in the surrounding area, and no nearby lands are enrolled under the Williamson Act. Therefore, the proposed project would not conflict with agricultural zoning or a Williamson Act contract. No impacts would occur and further analysis of this issue is not required Maps were utilized as 2006 Farmland Maps for Los Angeles County are currently not yet available. State of California Department of Conservation, Farmland Mapping & Monitoring Program, Important Farmland in California, 2004 (available at ftp://ftp.consrv.ca.gov/pub/dlrp/fmmp/pdf/ statewide/ fmmp2004_811.pdf), accessed August 28, City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-3 PRELIMINARY WORKING DRAFT Work in Progress

41 Attachment B Explanation of Checklist Determination c. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to nonagricultural use? No Impact. As discussed above, no agricultural uses exist on the project site or in the project vicinity, nor is the project site or the project vicinity zoned for agricultural use. Thus, the proposed project would not involve the conversion of farmland to nonagricultural uses. No impacts to agricultural land or uses would occur and further analysis of this issue is not required. III. AIR QUALITY. The significance criteria established by the South Coast Air Quality Management District (SCAQMD) may be relied upon to make the following determinations. Would the project result in: a. Conflict with, or obstruct implementation of, the SCAQMD or Congestion Management Plan? Potentially Significant Impact. The project site is located within the 6,600 square mile South Coast Air Basin (Basin). The South Coast Air Quality Management District (SCAQMD) together with the Southern California Association of Governments (SCAG) is responsible for formulating and implementing air pollution control strategies throughout the Basin. The current Air Quality Management Plan (AQMP) was adopted June 1, 2007 and outlines the air pollution control measures needed to meet Federal fine particulate matter (PM 2.5 ) standards by 2015 and ozone (O 3 ) standards by The AQMP also proposes policies and measures currently contemplated by responsible agencies to achieve Federal standards for healthful air quality in the Basin that are under SCAQMD jurisdiction. In addition, the current AQMP addresses several Federal planning requirements and incorporates substantial new scientific data, primarily in the form of updated emissions inventories, ambient measurements, new meteorological data, and new air quality modeling tools. The proposed project would support, and be consistent with, several key policy directives set forth in the AQMP. For example, the project would locate new development proximate to existing transit facilities and would redevelop a site already served by existing infrastructure. Notwithstanding these attributes, the project would increase the amount of traffic in the area and would consequently generate operational air emissions that could affect implementation of the AQMP. Pollutant emissions resulting from the removal of existing on-site structures and construction of the proposed project would also have the potential to affect implementation of the AQMP and Los Angeles County Congestion Management Plan (CMP). Therefore, it is recommended that this issue be analyzed further in an EIR. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-4 PRELIMINARY WORKING DRAFT Work in Progress

42 Attachment B Explanation of Checklist Determination b. Violate any air quality standard or contribute substantially to an existing or projected air quality violation? Potentially Significant Impact. As indicated above, the project site is located within the South Coast Air Basin, which is characterized by relatively poor air quality. State and Federal air quality standards are often exceeded in many parts of the Basin, with Los Angeles County among the highest of the counties that compose the Basin in terms of non-attainment of the standards. The Basin is currently in non-attainment for ozone (O 3 ), particulate matter (PM 10 ), and PM 2.5 on Federal and State air quality standards. The project would result in increased air emissions associated with construction and operation. Therefore, it is recommended that this issue be analyzed further in an EIR. c. Result in a cumulatively considerable net increase of any criteria pollutant for which the air basin is non-attainment (ozone, carbon monoxide, & PM 10) under an applicable federal or state ambient air quality standard? Potentially Significant Impact. As discussed above in Response III(a), the project would result in increases in air emissions from construction and operations (e.g., vehicle trips and stationary sources) in the Basin, which is currently in non-attainment of Federal and State air quality standards for O 3, PM 10, and PM 2.5. Furthermore, the project would contribute new greenhouse gas emissions to the atmosphere. Therefore, it is recommended that this issue be analyzed further in an EIR. d. Expose sensitive receptors to substantial pollutant concentrations? Potentially Significant Impact. Numerous sensitive receptors are located within the project site, as well as in the nearby vicinity. Such sensitive receptors include residential uses, day care uses, and elementary school uses. Construction activities and operation of the proposed uses could increase air pollutant emissions above current levels, thereby potentially affecting nearby sensitive receptors. Therefore, it is recommended that this issue be analyzed further in an EIR. e. Create objectionable odors affecting a substantial number of people? Less Than Significant Impact. Odors are typically associated with industrial projects involving the use of chemicals, solvents, petroleum products, and other strongsmelling elements used in manufacturing processes. Odors are also associated with uses such as agricultural facilities, sewage treatment facilities, and landfills. The project would provide for the development of academic/university serving, retail/commercial, City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-5 PRELIMINARY WORKING DRAFT Work in Progress

43 Attachment B Explanation of Checklist Determination housing, parking, and conference/hotel and/or lab school/educational academy uses. These types of land uses would not introduce any major odors s that would have the potential to affect a substantial number of people. Limited odors associated with project operations would be generated by on-site waste generation and storage, the use of certain cleaning agents, and/or food service establishments, all of which would be consistent with existing conditions on-site and in the surrounding area. In addition, activities and materials associated with proposed construction would be typical of construction projects of similar type and size. Any odors that may be generated during construction or operation of the project would be localized and temporary in nature, and would not be sufficient to affect a substantial number of people or result in a nuisance as defined by SCAQMD Rule 402. Under SCAQMD rules, the project would be required to implement Best Available Control Technology procedures to limit potential odor impacts for applicable sources, e.g. char-broilers. Impacts with regard to odors would be less than significant. Further analysis of this issue is not required. IV. BIOLOGICAL RESOURCES. Would the project: a. Have a substantial adverse effect, either directly or through habitat modification, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations by the California Department of Fish and Game or U.S. Fish and Wildlife Service? No Impact. The project site is located in an urbanized area and is currently developed with institutional, residential, commercial, parking, and other uses. Given the built nature of the project area and the fact that the project site has already been disturbed, the likelihood of the presence of any endangered and/or threatened species is remote. Furthermore, there are no species identified by the California Department of Fish and Game s (CDFG) Natural Diversity Database (CNDDB) or by the U.S. Fish and Wildlife Service (USFWS) that have been designated as endangered and/or threatened within a half-mile radius of the project site. 2 Therefore, while the proposed project would result in the removal and replacement of landscaping, as necessary, it would not adversely affect endangered and/or threatened species. Further analysis of this issue is not required. 2 California Department of Fish and Game s Natural Diversity Database, Geographic Information Systems data search, accessed August 26, City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-6 PRELIMINARY WORKING DRAFT Work in Progress

44 Attachment B Explanation of Checklist Determination b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in the City or regional plans, policies, regulations by the California Department of Fish and Game or U.S. Fish and Wildlife Service? No Impact. The project site is located in an urbanized area and is currently developed with institutional, residential, commercial, and parking uses. In addition, the project site includes lawn areas, mature trees and ornamental landscaping. No riparian habitats or sensitive natural communities are located on-site, nor have they been identified in City or Regional plans, policies, or regulations of the CDFG or USFWS as being within the project site. Thus, no impacts to riparian habitat or other sensitive community would occur as a result of implementation of the project. As such, further analysis of this issue is not required. c. Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? No Impact. The project site has been developed with urban uses since the expansion of Los Angeles into the area at the turn of the last century. There are no federally protected waters or wetlands, as defined by Section 404 of the Clean Water Act, that exist on or in the vicinity of the project site. As such, no adverse impacts to wetlands, marsh vernal pools, or coastal waters would occur as a result of the project. Further analysis of this issue is not required. d. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Less Than Significant Impact. The project site is located within an urbanized area of the City of Los Angeles and is currently developed with a mixture of commercial, institutional, recreational, educational, and residential uses. As such, the project site and surrounding area do not contain, and are not a part of, any migratory wildlife corridors or native wildlife nursery sites. Additionally, no body of water exists on or in the vicinity of the project site that serves as natural habitat in which fish could exist. The site does support mature trees that have the potential to be used for nesting by migratory birds. However, the project would comply with the Migratory Bird Treaty Act (MBTA), which regulates vegetation removal during the nesting season to ensure that significant impacts to migratory birds do not occur. Specifically, in accordance with the City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-7 PRELIMINARY WORKING DRAFT Work in Progress

45 Attachment B Explanation of Checklist Determination MBTA, efforts would be made to schedule removal of mature trees between September 1 and February 14 to avoid the nesting season. If activities were to occur during the nesting season, all suitable habitat would be thoroughly surveyed for the presence of nesting birds by a qualified biologist prior to removal. If any active nests were detected, the area will be flagged, along with a minimum 50-foot buffer (buffer may range between 50 and 300 feet as determined by the monitoring biologist), and would be avoided until the nesting cycle has complete or the monitoring biologist determines that the nest has failed. As such, implementation of the project would not have a significant impact on the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, nor would the project impede the use of native wildlife nursery sites. Further analysis of this issue is not necessary. e. Conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance (e.g., oak trees or California walnut woodlands)? Potentially Significant Impact. The City of Los Angeles Protected Tree Ordinance (Chapter IV, Article 6 of the Los Angeles Municipal Code) regulates the relocation or removal of all California native oak trees (excluding scrub oak), California black walnut trees, Western sycamore trees, and California Bay trees of at least four inches in diameter at breast height (DBH). These native tree species are defined as protected by the City of Los Angeles. However, native trees that have been planted as part of a tree planting program are exempt from this Ordinance and are not considered protected. The Ordinance prohibits, without a permit, the removal of any regulated protected tree, including acts which inflict damage upon root systems or other parts of the tree... and requires that all regulated protected trees that are removed be replaced on at least a two-to-one basis with trees that are of a protected variety. The City also requires that a report be prepared by a tree expert discussing the subject tree(s), their preservation, effects of the proposed construction, and mitigation measures pursuant to the removal or replacement thereof. The project site includes a number of trees, some of which may be removed for implementation of the project. In order to identify whether application of the Protected Tree Ordinance and its provisions may be applicable, it is recommended that this issue be addressed further in an EIR f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? No Impact. As indicated above, the project site is located in an urbanized area and does not provide habitat for any sensitive biological resources. As such, the project site is not subject to a Habitat Conservation Plan, Natural Community Conservation Plan, or City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-8 PRELIMINARY WORKING DRAFT Work in Progress

46 Attachment B Explanation of Checklist Determination other approved local, regional, or state habitat conservation plan. As a result, the project would not result in any impacts associated with or conflict with the provisions of any habitat conservation plans. Further analysis of this issue is not required. V. CULTURAL RESOURCES. Would the project: a. Cause a substantial adverse change in significance of a historical resource as defined in State CEQA ? Potentially Significant Impact. Section (a)(3) of the CEQA Guidelines defines historical resources as any object, building, structure, site, area, place, record, or manuscript determined to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California. Historical resources are further defined as being associated with significant events, important persons, or distinctive characteristics of a type, period or method of construction; as representing the work of an important creative individual; or as possessing high artistic values. In addition, resources identified as eligible for the National Register and/or California Register are typically over 50 years of age, unless they can demonstrate exceptional significance. Based on surveys and other local and State resources, there are potentially historic properties and districts within the project site and vicinity. As part of the project, several buildings would be removed and new buildings would be constructed. Thus, the project has the potential to result in significant impacts to a historic resource. Thus, it is recommended that this issue be further analyzed in an EIR. b. Cause a substantial adverse change in significance of an archaeological resource pursuant to State CEQA ? Potentially Significant Impact. The project site is located within a developed area with previously disturbed soils. Thus, any surficial archaeological resources that may have existed on the project site at one time have likely been disturbed or previously removed. Notwithstanding, excavation in new areas and/or at greater depths than performed previously has the potential to encounter archaeological resources. Thus, it is recommended that this issue be analyzed further in an EIR. c. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Potentially Significant Impact. The project site has been previously graded and is developed with buildings, surface parking, and ornamental landscaping. Based City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-9 PRELIMINARY WORKING DRAFT Work in Progress

47 Attachment B Explanation of Checklist Determination on previous paleontological records searches for development projects within the area, there are no records indicating that prior excavation activities have disturbed any paleontological resources or that any paleontological resources are located within the project area. It appears the project area is underlain by younger Quaternary alluvium of unknown thickness. The nearest known vertebrate fossil localities of similar sediments are located approximately 1.5 miles west of the project site. As such, the potential for the project to impact significant paleontological resources appears to be low. Nonetheless, as the project would require excavation in new areas and/or at greater depths than performed previously, the potential exists to encounter paleontological resources. Thus, it is recommended that this issue be analyzed further in an EIR. d. Disturb any human remains, including those interred outside of formal cemeteries? Potentially Significant Impact. As discussed in Response V(b) above, the project site is located within an urbanized area and has been subject to disturbance as a result of prior grading and development activities. No known traditional burial sites or other type of cemetery usage have been identified on-site or within the project vicinity. Notwithstanding, as the project would require excavation at depths greater than those having previously occurred on the project site, the potential exists for the project to uncover human remains. Thus, it is recommended that potential project impacts on the disturbance of human remains be further analyzed in an EIR. VI. GEOLOGY AND SOILS. Would the project: a. Expose people or structures to potential substantial adverse effects, including the risk of loss, injury or death involving : i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. Potentially Significant Impact. Fault rupture is defined as the displacement that occurs along the surface of a fault during an earthquake. Based on criteria established by the California Geological Survey (CGS), faults can be classified as active, potentially active, or inactive. 3 3 The California Geological Survey was formerly known as the Division of Mines and Geology of the California Department of Conservation. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-10 PRELIMINARY WORKING DRAFT Work in Progress

48 Attachment B Explanation of Checklist Determination The CGS establishes regulatory zones around active faults, called Alquist-Priolo Earthquake Fault Zones (formerly Special Study Zones). These zones, which extend from 200 to 500 feet on each side of the known active fault, identify areas where potential surface rupture along an active fault could prove hazardous and identify where special studies are required to characterize hazards to habitable structures. In addition, the City of Los Angeles designates Fault Rupture Study Zones, which extending along each side of active and potentially active faults to establish areas of hazard potential due to fault rupture. 4 The project site is not located within an Alquist-Priolo Fault Zone or a Fault Rupture Study Area, and neither active nor potentially active faults are known to pass directly beneath the project site. 5 The closest active fault to the project site is the Newport-Inglewood Fault, located approximately 4.5 miles west of the project site, and the closest known blind thrust fault is the Puente Hills Blind Thrust Fault, located approximately 1.6 miles from the site. 6 Although the project would comply with seismic safety requirements set forth in the Uniform Building Code (UBC) and the Los Angeles Municipal Code (LAMC), the project would be exposed to seismic risks. Therefore, it is recommended that this issue be analyzed further in an EIR. ii. Strong seismic ground shaking? Potentially Significant Impact. As with any development in the Southern California region, the project could be subject to strong ground shaking during a seismic event. The project would result in an increase in the intensity of development within the site. Thus, the project would have the potential to result in the increased exposure of people to potential ground shaking impacts. Therefore, it is recommended that this issue be evaluated in an EIR. iii. Seismic-related ground failure, including liquefaction? Potentially Significant Impact. The project site is not located within a delineated liquefaction hazard zone. As discussed above, the project site is located within the seismically active Southern California region; and therefore, it is recommended that potential impacts associated with seismic-related ground failure, including liquefaction, be analyzed in an EIR City of Los Angeles General Plan Safety Element, Exhibit A, adopted by the City Council, November 26, Ibid. Ibid. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-11 PRELIMINARY WORKING DRAFT Work in Progress

49 Attachment B Explanation of Checklist Determination iv. Landslides? No Impact. The project site is characterized by a relatively flat topography with minimally sloping terrain. In addition, the project site is not located in a landslide area as mapped by the City of Los Angeles, or within an area identified as having potential for slope instability. 7 Furthermore, the project does not propose substantial alteration to the existing topography. Therefore, impacts associated with landslides would not occur and further analysis of this issue is not required. b. Result in substantial soil erosion or the loss of topsoil? Potentially Significant Impact. It is anticipated that project construction activities, particularly grading and soil stockpiling, would have the potential to result in minor soil erosion. In addition, changes to on-site drainage patterns resulting from the proposed project (discussed further below in Section VIII) could also result in limited soil erosion. Thus, it is recommended that the potential for soil erosion resulting from construction and operation of the project be analyzed further in an EIR. c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? Potentially Significant Impact. As discussed above, the project site is susceptible to ground shaking. Thus, it is recommended that potential impacts associated with soil stability, lateral spreading, subsidence, liquefaction, and collapse be analyzed further in an EIR. d. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? Potentially Significant Impact. Expansive soils are typically associated with fine-grained clayey soils that have the potential to shrink and swell with repeated cycles of wetting and drying. As part of the environmental review process, a geotechnical report will be prepared to identify the types of soils within the three planning Subareas. Thus, it is recommended that expansive soils be analyzed further in an EIR utilizing the information from the geotechnical report. 7 City of Los Angeles General Plan Framework; City of Los Angeles Planning Department; Exhibit C; adopted November City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-12 PRELIMINARY WORKING DRAFT Work in Progress

50 Attachment B Explanation of Checklist Determination e. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? No Impact. The project site is located in an urbanized area that has existing sewer infrastructure. The project would be served by this existing sewer infrastructure and thus, the project would not require the use of septic tanks or alternative wastewater disposal systems. No impacts would occur and further analysis of this issue is not required. VII. HAZARDS AND HAZARDOUS MATERIALS. Would the project: a. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Potentially Significant Impact. During operation of the proposed project, the type and amount of hazardous materials to be used on-site would be typical of those used for academic/university serving, retail/commercial, housing, parking, and conference/hotel and/or lab school/educational academy uses. Specifically, operation of the academic and commercial uses would involve the use and storage of small quantities of potentially hazardous materials in the form of cleaning solvents, painting supplies, pesticides for landscaping, and petroleum products. The proposed residential uses would involve the limited use of household cleaning solvents and pesticides for landscaping. Construction of the proposed project would involve the temporary use of potentially hazardous materials, including vehicle fuels, oils, and transmission fluids. While it is anticipated that the risk associated with the use of these hazardous materials would be reduced to a less than significant level through compliance with regulatory requirements, it is recommended that this issue be analyzed further in an EIR. b. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Potentially Significant Impact. Portions of the project site are located within a Methane Zone, as mapped by the City of Los Angeles. 8 Thus, operation of the project would require compliance with the City s Methane Ordinance. In addition, removal of 8 City of Los Angeles, Department of Public Works, Bureau of Engineering, Methane and Methane Buffer Zones Basic Grid Map, March 31, City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-13 PRELIMINARY WORKING DRAFT Work in Progress

51 Attachment B Explanation of Checklist Determination buildings has the potential to expose the public and/or the environment to asbestoscontaining materials (ACMs) and lead-based paint (LBP) since a portion of the existing buildings that may be removed were built in the 1800 s and early 1900 s, before ACMs and lead-based paint were identified as hazards for use in building construction. As a result, impacts related to the release of hazardous materials are considered to be potentially significant. Thus, it is recommended that the issue of hazards/hazardous materials be analyzed further in an EIR. c. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Potentially Significant Impact. The USC University Park Campus and the 32 nd Street Elementary School are located within the boundaries of the proposed USC Specific Plan. In addition, several other elementary schools and day care centers are within a one-quarter mile of the project site. As discussed in Response VII(a), the project would involve the use of potentially hazardous materials typical of those currently used in academic/university serving, retail/commercial, housing, parking, and conference/hotel and/or lab school/educational academy uses. Further as noted in Response VII(b), parts of the project site are located in a Methane Zone and site buildings to be removed may have ACMS or LBP. While it is anticipated that the risk of hazards within a one-quarter mile radius of an existing school would be reduced to a less than significant level through compliance with regulatory requirements, it is recommended that this issue be analyzed further in an EIR. d. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section and, as a result, would it create a significant hazard to the public or the environment? Potentially Significant Impact. The USC Specific Plan boundaries may include hazardous materials sites that are listed pursuant to Government Code Section Thus, it is recommended that this issue be further analyzed in an EIR. 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, would the project result in a safety hazard for people residing or working in the project area? No Impact. The project site is not located within an airport land use plan or within two miles of a public airport. The closest airport to the project site is Los Angeles City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-14 PRELIMINARY WORKING DRAFT Work in Progress

52 Attachment B Explanation of Checklist Determination International Airport, approximately 8 miles to the southwest and the nearest public use airport, Hawthorne Airport, is located approximately 7 miles away. As such, the project would not result in a safety hazard for people due to a public airport. No impacts would occur, and further analysis of this issue is not required. f. For a project within the vicinity of a private airstrip, would the project result in a safety hazard for the people residing or working in the area? No Impact. The project site is not located within the vicinity of a private airstrip. As stated above in Response VII(e), the closest airport to the project site is the Los Angeles International Airport, approximately 8 miles to the southwest and the nearest public use airport, Hawthorne Airport, is located approximately 7 miles away. As such, the project would not result in a safety hazard for people due to a private airstrip. No impacts would occur, and further analysis of this issue is not required. g. Impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan? Potentially Significant Impact. Emergency access is provided to the project site via an existing street network. Additionally, Figueroa Street to the east and Martin Luther King Jr. Boulevard to the south are designated disaster routes within the Safety Element of the City of Los Angeles General Plan Framework. 9 While it is expected that the majority of construction activities for the project would be confined on-site, shortterm construction activities may temporarily affect access on portions of the adjacent street rights-of-way during periods of the day. In addition, although the project is expected to provide adequate emergency access and comply with LAFD access requirements, the project would generate traffic in the project vicinity. Therefore, it is recommended that this issue be analyzed further in an EIR. h. 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? No Impact. The project site is located in an urbanized area surrounded by a mixture of commercial, institutional, recreational, educational, and residential uses. No wildlands are present in the immediate vicinity. Furthermore, the site is not designated 9 City of Los Angeles Department of City Planning, Safety Element of the General Plan, Exhibit H, November City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-15 PRELIMINARY WORKING DRAFT Work in Progress

53 Attachment B Explanation of Checklist Determination as a wildfire hazard area or fire buffer zone area by the City. 10 Therefore, the proposed project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires. As no impacts associated with this issue are anticipated to occur, further analysis of this issue is not required. VIII. HYDROLOGY AND WATER QUALITY. Would the proposal: a. Violate any water quality standards or waste discharge requirements? Potentially Significant Impact. Construction of the project would require earthwork activities, including excavation and grading of the site. During precipitation events in particular, construction activities associated with the project would have the potential to result in minor soil erosion from grading and soil stockpiling, subsequent siltation, and conveyance of other pollutants into municipal storm drains. In addition, potential changes in on-site drainage patterns resulting from project implementation and the introduction of new land uses could affect the quality of storm water runoff. Therefore, it is recommended that surface water quality impacts during project construction and operation be evaluated further in an EIR. b. Substantially deplete groundwater supplies or interfere with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned land uses for which permits have been granted)? Potentially Significant Impact. Groundwater levels in the City are maintained through an active process via spreading grounds and recharge basins. The project site is already developed with a mix of commercial, institutional, recreational, educational, and residential uses. Thus, new development within the project site is not expected to substantially reduce the amount of pervious surfaces in the area and reduce groundwater recharge. Furthermore, the project would provide appropriate stormdrain improvements to manage drainage. Nonetheless, is it recommended that the potential for the project to impact groundwater supplies or groundwater recharge be analyzed further in an EIR. 10 City of Los Angeles Department of City Planning, Safety Element of the General Plan, Exhibit D, Selected Wildfire Hazard Areas, November City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-16 PRELIMINARY WORKING DRAFT Work in Progress

54 Attachment B Explanation of Checklist Determination c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or offsite? Potentially Significant Impact. The majority of the project site is developed with buildings, paved areas, and ornamental landscaping. No streams are located within the project vicinity. In addition, the Los Angeles River (LA River), a concrete lined channel, is located approximately 3.5 miles east of the project site. While the project would not directly alter the course of the LA River, the project has the potential to result in changes in existing drainage patterns. Thus, it is recommended that this issue be analyzed further in an EIR. d. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in an manner which would result in flooding on- or off site? Potentially Significant Impact. As noted above, the project may result in modifications to existing drainage patterns on the site and vicinity. Therefore, it is recommended that an analysis of alterations to drainage patterns and the associated potential for flooding be analyzed further in an EIR. e. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? Potentially Significant Impact. As noted above, the project may result in the modification of existing drainage patterns. Therefore, it is recommended that the potential for the project to exceed the capacity of drainage systems or to result in additional sources of polluted runoff be analyzed further in an EIR. f. Otherwise substantially degrade water quality? Potentially Significant Impact. As previously indicated in Response No. VIII(a) above, exposed soils during construction of the project could potentially be transported via stormwater runoff into storm drains. In addition, the project would introduce new uses to the project site. Therefore, it is recommended that the potential for the project to degrade water quality be analyzed further in an EIR. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-17 PRELIMINARY WORKING DRAFT Work in Progress

55 Attachment B Explanation of Checklist Determination g. Place housing within a 100-year flood plain as mapped on Federal Flood Hazard Boundary or Flood Insurance Rate Maps or other flood hazard delineation maps? No Impact. The project site is not located within a Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) or City of Los Angeles designated 100-year flood plain. 11 Therefore, the project would not place housing within a 100-year flood plain as mapped by federal flood hazard boundaries, FIRM maps, or other flood hazard delineation maps. Thus, no impacts would occur and no further analysis of this issue is required. h. Place within a 100-year flood plain structures that would impede or redirect flood flows? No Impact. As stated above, the project site is not located within a FEMA or City of Los Angeles designated 100-year flood plain. As such, the project would not place structures within a 100-year flood plain that would impede or redirect flood flows. No impacts would occur and no further analysis of this issue is required. i. Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? Potentially Significant Impact. The project site is located within a potential inundation area associated with the Hansen Dam, as indicated in the Safety Element of the City of Los Angeles General Plan. 12 However, the dam is located approximately 18 miles northwest of the project site, at a considerable distance, with an extensive amount of intervening structures located in between. A comprehensive storm drain system is also in place throughout the project area. Nonetheless, it is recommended that further analysis of this issue be included in an EIR. j. Inundation by seiche, tsunami, or mudflow? No Impact. The largest body of water near the project site is the Pacific Ocean, located approximately 11 miles to the west. No other large bodies of water are located 11 City of Los Angeles Planning Department, Safety Element of the General Plan, Exhibit F, 100-Year and 500-Year Flood Plains, March City of Los Angeles Department of City Planning, Safety Element of the City of Los Angeles General Plan, Exhibit G, Inundation & Tsunami Hazard Areas, adopted November 26, City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-18 PRELIMINARY WORKING DRAFT Work in Progress

56 Attachment B Explanation of Checklist Determination nearby. Furthermore, the project site is not located within a City-designated potential tsunami hazard area. Thus, the project would not be prone to inundation by a seiche or tsunami. In addition, the project site is not located downslope from an area of mudslide potential, therefore, mudflow risks do not exist. No impacts due to inundation from a seiche, tsunami, or mudflow are anticipated to occur. As such, further analysis of this issue is not required. IX. LAND USE AND PLANNING. Would the project: a. Physically divide an established community? Less Than Significant Impact. The project site is located in a highly urbanized area with a mix of existing land use including commercial, institutional, recreational, educational, and residential uses. Development under the Specific Plan would be consistent and compatible with the established community. Development would consist of infill development in a highly urbanized community with uses that are already present in the area. Therefore, impacts relative to this issue would be less than significant. b. Conflict with 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, coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? Potentially Significant Impact. The project site is located both within the boundaries of the South Los Angeles Community Plan and Southeast Los Angeles Community Plan. Land use designations for the project site by these Community Plans include Community Commercial, High Medium Residential, Limited Manufacturing, and Public Facilities designations. In addition, in accordance with the LAMC, the project site includes a range of zoning designations that specify permitted uses, maximum building heights, floor area ratios, setbacks; distances and other development regulations within the project site. The project site is also subject to various regional plans, including the Southern California Association of Governments Regional Comprehensive Plan and Guide, the South Coast Air Quality Management District s s Air Quality Management Plan, and the Metropolitan Transportation Authority s Congestion Management Plan. Project implementation would include new buildings and other improvements that would require several discretionary approvals. Thus, it is recommended that the project s relationship to applicable land use plans, policies and development regulations be analyzed further in an EIR. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-19 PRELIMINARY WORKING DRAFT Work in Progress

57 Attachment B Explanation of Checklist Determination c. Conflict with any applicable habitat conservation plan or natural community conservation plan? No Impact. The project site is located within an urbanized area. No habitat conservation plans or natural community conservation plans apply to the project area. As such, the project would not conflict with any habitat conservation plans. No impacts would occur, and further analysis of this issue is not required. X. MINERAL RESOURCES. Would the project: a. Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? b. Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No Impact (a and b). No mineral extraction operations occur on the site or in the nearby vicinity. The project site is located within a highly urbanized area of the City of Los Angeles and has been previously disturbed by development. As such, the potential for mineral resources to occur on-site is low. Furthermore, the project site is not located within a City-designated Mineral Resource Zone where significant mineral deposits are known to be present or within a mineral producing area as classified by the CGS. 13,14 The project would not result in impacts to mineral resources or a mineral resource recovery site. Further analysis of this issue is not necessary and no mitigation measures would be required. XI. NOISE. Would the project: a. Exposure of persons to or generation of noise in level in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Potentially Significant Impact. The project site is located within an urbanized area that contains various sources of noise. The most predominate source of noise is 13 City of Los Angeles, Department of City Planning, Los Angeles Citywide General Plan Framework, Draft Environmental Impact Report, January 19, Figure GS State of California Department of Conservation, California Geologic Survey, Map of California Principal Mineral-Producing Localities City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-20 PRELIMINARY WORKING DRAFT Work in Progress

58 Attachment B Explanation of Checklist Determination associated with traffic from roadways. During construction activities, the use of heavy equipment (e.g., bulldozers, backhoes, cranes, loaders, etc.) would generate noise on a short-term basis. In addition, operation of the project could increase existing noise levels as a result of additional residents and employees residing on-site, project-related traffic, and HVAC systems. Therefore, it is recommended that the project s potential to exceed established noise standards or other applicable regulations be analyzed further in an EIR. b. Exposure of people to or generation of excessive groundborne vibration or groundborne noise levels? Potentially Significant Impact. Construction of the proposed project could generate groundborne noise and vibration in association with site grading, clearing activities, and construction truck travel. As such, the project would have the potential to generate and expose people to or excessive groundborne vibration and noise levels during short-term construction activities. Therefore, it is recommended that this issue be analyzed further in an EIR. The project s proposed academic/university serving, retail/commercial, housing, parking, and conference/hotel and/or lab school/educational academy uses would not be expected to generate groundborne noise or vibration levels beyond those that currently exist. Nonetheless, it is recommended that this issue also be analyzed further in an EIR. c. A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? Potentially Significant Impact. As discussed above, project operations may contribute to an increase in ambient noise levels. Such increases in noise levels could potentially affect sensitive receptors including nearby residential and educational uses. Therefore, it is recommended that impacts associated with a permanent increase in ambient noise levels be analyzed in an EIR. d. A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? Potentially Significant Impact. As discussed above, construction-related activities may result in a temporary increase in ambient noise levels in the site vicinity. Additionally, operation of the project could increase ambient noise levels in the project area as a result of increases in project-generated traffic and on-site activities. Thus, it is recommended that this issue be analyzed further in an EIR. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-21 PRELIMINARY WORKING DRAFT Work in Progress

59 Attachment B Explanation of Checklist Determination 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, would the project expose people residing or working in the project area to excessive noise levels? No Impact. As indicated above, the project site is not located within an airport land use plan area or within two miles of an airport. Therefore, implementation of the proposed project would not expose people residing or working in the project area to excessive noise levels associated with airport-related noise sources. No impacts would occur, and further analysis of this issue is not required. f. For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? No Impact. As discussed above, the closest airport to the project site is Los Angeles International Airport, approximately 8 miles to the southwest, and the nearest public use airport, Hawthorne Airport, is located approximately 7 miles away. As such, the proposed project is not located within the vicinity of a private airstrip and would not expose people residing or working in the area to excessive noise levels. No impacts would occur, and further analysis of this issue is not required. XII. POPULATION AND HOUSING. Would the project: a. Induce substantial population growth in an area either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? Potentially Significant Impact. The proposed project would provide for uses that would support and be compatible with the existing University-related uses within the project area. The project would result in a relatively small increase in annual enrollment and staffing within USC s University Park campus and would provide new housing for students and faculty to reside in the vicinity of the campus. In addition, the project would provide employment opportunities associated with the new retail/commercial uses. Therefore, it is recommended that the potential growth anticipated as part of the project be further analyzed in an EIR. Furthermore, the analysis of population will also include a discussion of housing availability in the area. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-22 PRELIMINARY WORKING DRAFT Work in Progress

60 Attachment B Explanation of Checklist Determination b. Displace substantial numbers of existing housing necessitating the construction of replacement housing elsewhere? c. Displace substantial numbers of people necessitating the construction of replacement housing elsewhere? Potentially Significant Impact (b and c). The project would provide up to 5,400 new student beds and up to 250 faculty housing units which will assist in making existing housing in the project vicinity available to non-university affiliated residents.. In addition, while the proposed project would result in the removal of some housing units, particularly in Subarea 3, and most of which are occupied by students, such housing would be replaced with an increased number of units. Further, construction of the new housing units would be phased such that the number of existing units would not decrease. Nonetheless, given the importance of this issue, it is recommended that the replacement of housing as well as affordable housing issues in the surrounding area be analyzed in an EIR. XIII. PUBLIC SERVICES. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: a. Fire protection? Potentially Significant Impact. The Los Angeles Fire Department (LAFD) provides fire protection and emergency medical services for the project site and surrounding area. Two fire stations provide initial emergency response to the project site: Fire Station No. 15 is located within the project area, at 915 West Jefferson Boulevard; and Fire Station No. 14 is located southeast of the project site, at 3401 South Central Avenue. The proposed project would include the development of academic/university serving, retail/commercial, housing, parking, and conference/hotel and/or lab school/educational academy uses. Thus, the project would result in an increased demand for fire protection services. It is recommended that this issue be addressed in an EIR. b. Police protection? Potentially Significant Impact. Police protection services for the project site are provided by the South Bureau of the Los Angeles Police Department (LAPD). The City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-23 PRELIMINARY WORKING DRAFT Work in Progress

61 Attachment B Explanation of Checklist Determination closet police station to the project site is the Southwest Police Station located southwest of the project site at 1546 West Martin Luther King Jr. Boulevard. As discussed above in Response XIII(a)(i), the proposed project would include the development of academic/university serving, retail/commercial, housing, parking, and conference/hotel and/or lab school/educational academy uses. Thus, the project would result in an increased demand for police protection services. It is recommended that this issue be addressed in an EIR. c. Schools? Potentially Significant Impact. The Los Angeles Unified School District (LAUSD) provides public education for children in Kindergarten through 12 th Grades within the project area. The majority of the project site is specifically located in LAUSD District 7, which covers the communities of South Central Los Angeles and Compton, with a small portion of the project site located within District 5, which covers the communities of East Los Angeles, Alhambra, Boyle Heights, and Huntington Park. The proposed project would include the development of academic/university serving, retail/commercial, housing, parking, and conference/hotel and/or lab school/educational academy uses. Thus, while the lab school/educational academy would reduce the demand for LAUSD school facilities, it is recommended that potential impacts on public schools be analyzed in an EIR. d. Parks? Potentially Significant Impact. The Los Angeles Department of Recreation and Parks (LADRP) is responsible for the provision, maintenance, and operation of public recreational facilities for the City. The proposed project would include the development of academic/university serving, retail/commercial, housing, parking, and perhaps conference/hotel and/or lab school/educational academy uses. While the proposed project would include new landscaped public open space areas and associated facilities for community use, it is recommended that potential impacts on existing parks be analyzed in an EIR. e. Other governmental services (including roads)? Potentially Significant Impact. The Los Angeles Public Library (LAPL) provides library services to the City of Los Angeles. Increased housing and increased employment opportunities within the project area could contribute to demand for nearby LAPL library facilities, including the Exposition Park - Dr. Mary McLeod Bethune City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-24 PRELIMINARY WORKING DRAFT Work in Progress

62 Attachment B Explanation of Checklist Determination Regional Library, the Jefferson Library, and the Junipero Serra Library. Therefore, it is recommended that this issue be addressed in an EIR. No other public services would be notably impacted by the project. The project site would continue to be served by the existing road network, and would not require additional government services for the operation and maintenance of these roads. Therefore, the proposed project would result in a less than significant impact on other governmental services. Further analysis of other governmental services (e.g, roadway maintenance) is not required. XIV. RECREATION. a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Potentially Significant Impact. The proposed project would result in a population increase in the local area that could potentially increase the demand for existing neighborhood and regional parks or other recreational facilities. Therefore, it is recommended that this issue be analyzed further in an EIR. b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Potentially Significant Impact. The proposed project includes the provision of new landscaped public open space areas and associated facilities for community use. As such, these new facilities would contribute to the overall impacts of the project. Therefore, it is recommended that the potential physical impacts of these project components be analyzed further in an EIR. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-25 PRELIMINARY WORKING DRAFT Work in Progress

63 XV. TRANSPORTATION/CIRCULATION. Would the project: Attachment B Explanation of Checklist Determination a. Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? Potentially Significant Impact. The proposed project would include the development of academic/university serving, retail/commercial, housing, parking, and conference/hotel and/or lab school/educational academy uses. These uses would increase the number of vehicle trips on the local street system. Thus, operation of the proposed project potentially could adversely impact the existing capacity of the street system or exceed an established LOS standard. In addition, construction of the proposed project would result in a temporary increase in traffic due to constructionrelated truck trips and worker vehicle trips. Thus, traffic impacts during construction could potentially also adversely affect the existing street system. Therefore, it is recommended that this issue be analyzed in an EIR. b. Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways? Potentially Significant Impact. The Metropolitan Transportation Authority (Metro) administers the Congestion Management Program (CMP), a state mandated program designed to address the impacts urban congestion has on local communities and the region as a whole. The CMP provides an analytical basis for the transportation decisions contained in the State Transportation Improvement Project. The CMP for Los Angeles County requires an analysis of any proposed project that could add 50 or more trips to any CMP intersection or more than 150 trips to a CMP mainline freeway location in either direction during either the A.M. or P.M. weekday peak hours. Implementation of the proposed project would generate additional vehicle trips, which could potentially add more than 50 trips to a CMP roadway intersection or more than 150 trips to a CMP freeway segment. Thus, the project could exceed LOS standards for CMP intersections or CMP freeway segments. As such, it is recommended that this issue be analyzed in an EIR. c. 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? No Impact. As stated above in Response VII(e), the closest airport to the project site is the Los Angeles International Airport, approximately 8 miles to the southwest, City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-26 PRELIMINARY WORKING DRAFT Work in Progress

64 Attachment B Explanation of Checklist Determination and the nearest public use airport, Hawthorne Airport, is located approximately 7 miles away. As such, the project would not result in a safety hazard related to air traffic patterns or levels. No impacts would occur, and further analysis of this issue is not necessary. d. Substantially increase hazards to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? No Impact. The project does not propose the construction of any hazardous design features, including sharp curves or dangerous intersections, nor are there any dangerous features existing on-site or off-site. Furthermore, the project does not propose any hazardous or incompatible uses such as use of farm equipment. Since the project would not include any hazardous design features or incompatible uses, no impacts would occur. Further analysis of this issue is not necessary. e. Result in inadequate emergency access? Potentially Significant Impact. Immediate emergency access to the project site would continue to be provided by the existing street network. Additionally, Figueroa Street to the east and Martin Luther King Jr. Boulevard to the south are designated disaster routes within the Safety Element of the City of Los Angeles General Plan Framework. 15 While it is expected that the majority of construction activities for the project would be confined on-site, short-term construction activities may temporarily affect access along portions of the adjacent street rights-of-way during peak travel periods of the day. In addition, while the project is expected to provide adequate emergency access and to comply with LAFD access requirements, existing site access would be modified. Thus, it is recommended that this issue be analyzed in an EIR. f. Result in inadequate parking capacity? Potentially Significant Impact. The proposed uses would utilize both existing and new parking facilities. As a substantial increase in enrollment and staffing is not proposed, many of the new academic and University-serving buildings in Subareas 1 and 2 are anticipated to be accommodated through the University s existing pool of parking. In addition, parking would be provided in accordance with the requirements set forth by the USC Specific Plan, which would be based on detailed demand analyses. It is recommended that these demand analyses be included in an EIR to demonstrate that on-site parking will meet forecasted typical peak parking demand. 15 City of Los Angeles Department of City Planning, Safety Element of the General Plan, Exhibit H, November City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-27 PRELIMINARY WORKING DRAFT Work in Progress

65 Attachment B Explanation of Checklist Determination g. Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? Potentially Significant Impact. The project site is located in an area well served by public transportation, including numerous bus lines and the soon to be completed Exposition Boulevard Light Rail Transit Line. The project area also includes numerous pedestrian and bicycle facilities. As described in Attachment A, portions of Jefferson and Hoover Boulevards within the project area would be reduced from four through-lanes to two through-lanes, with a dedicated left turn lane and right turn pockets. This improvement would allow for the creation of bike lanes and increased sidewalk widths on both sides of the roadway to increase pedestrian safety and promote pedestrian activity. In addition, a portion of Hoover Street may be realigned to intersect Jefferson Boulevard at a right angle across from Watt Way to provide for improved pedestrian and bicycle connections. The project will also reduce the width of McClintock Ave and restrict through-traffic on this street up to the south of 30 th Street. Furthermore, the project would include new buildings and would also include provisions for linking pedestrians and bicyclists with nearby uses and public transit. Further, the University intends to continue implementation of their Traffic Demand Management Program. Nonetheless, it is recommended that the potential for the project to conflict with polices regarding alternative forms of transit be analyzed in an EIR. XVI. UTILITIES. Would the project: a. Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? Potentially Significant Impact. The proposed project would include the development of academic/university serving, retail/commercial, housing, parking, and conference/hotel and/or lab school/educational academy uses. These proposed uses are anticipated to increase wastewater generation on-site. Wastewater generated would be treated at the Hyperion Treatment Plant in El Segundo. The quantity of wastewater generated by the proposed project could potentially result in wastewater treatment impacts. Therefore, it is recommended that this issue by analyzed further in an EIR. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-28 PRELIMINARY WORKING DRAFT Work in Progress

66 Attachment B Explanation of Checklist Determination b. Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Potentially Significant Impact. The proposed project would result in an increase in water demand and wastewater generation. Thus, the project may require upgrades and improvements to existing water and wastewater treatment facilities. Therefore, it is recommended that this issue be analyzed further in an EIR. c. Require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Potentially Significant Impact. The project site is already developed with buildings, paved areas and ornamental landscaping. Thus, new development within the project site is not expected to substantially change on-site and off-site stormwater runoff quantities. Additionally, the project would be expected to include appropriate drainage improvements on-site to accommodate anticipated stormwater flows. Nonetheless, it is recommended that the potential for the project to require new drainage facilities or the expansion of existing facilities be analyzed further in an EIR. d. Have sufficient water supplies available to serve the project from existing entitlements and resource, or are new or expanded entitlements needed? Potentially Significant Impact. The project consists of a mix of uses that would collectively generate a water demand greater than that generated by 500 dwelling units. As such, the project would be subject to the provisions of Senate Bill (SB) 610, which requires that a water supply assessment be conducted by the water service provider to determine if there is sufficient water supply to serve the project during normal, single dry, and multiple dry water years. Since a water supply assessment is required for the proposed project, it is recommended that water supply be analyzed further in an EIR. e. Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project s projected demand in addition to the provider s existing commitments? Potentially Significant Impact. Wastewater generated by the project would be treated at the Hyperion Treatment Plant. As discussed above, the project would result in an increase in wastewater generation. Therefore, it is recommended that the ability City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-29 PRELIMINARY WORKING DRAFT Work in Progress

67 Attachment B Explanation of Checklist Determination of the wastewater treatment system to accommodate the project be analyzed further in an EIR. f. Be served by a landfill with sufficient permitted capacity to accommodate the project s solid waste disposal needs? Potentially Significant Impact. Various public agencies and private companies provide solid waste management services in the City of Los Angeles. Private collectors service most multi-family units and commercial developments, whereas the City s Bureau of Sanitation collects the majority of residential waste from single-family and some smaller multi-family residences. Construction of the project would generate construction and demolition (C&D) debris (e.g., asphalt, glass, concrete, steel, wood), which would be transported and disposed of at one of the several unclassified (inert) landfills in Los Angeles County. In addition, during project operation, the project s academic/university serving, retail/commercial, housing, parking, and conference/hotel and/or lab school/educational academy uses would generate additional solid waste, which would increase the amount of solid waste currently disposed of at Los Angeles County Class III landfills. As such, it is recommended that this issue be analyzed in an EIR. g. Comply with federal, state, and local statutes and regulations related to solid waste? Potentially Significant Impact. The project would comply with applicable regulations related to solid waste, including those pertaining to waste reduction and recycling. Specifically, the project would comply with the City s Recycling Ordinance (No ), which requires that all new development projects provide an adequate recycling area or room for collecting and loading recyclable materials. Furthermore, the project would provide on-site recycling collection facilities for students, employees, guests, residents, and retail patrons. The project would also promote compliance with the California Integrated Waste Management Act of 1989 (AB939) through source reduction and recycling programs. Nonetheless, as the project would result in increased solid waste generated on-site, it is recommended that the project s compliance with federal, state, and local statutes and regulations related to solid waste be further analyzed in an EIR. h. Other Utilities and Service Systems? Potentially Significant Impact. Implementation of the proposed project would result in increased demand for electricity and natural gas services. Electrical City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-30 PRELIMINARY WORKING DRAFT Work in Progress

68 Attachment B Explanation of Checklist Determination transmission to the project site is provided and maintained by the Los Angeles Department of Water and Power (LADWP). The electricity demand generated by the proposed project could potentially result in impacts with respect to the amount of electricity available to serve the project area. Furthermore, additional improvements to existing electricity infrastructure may be needed. Therefore, it is recommended that this issue be analyzed further in an EIR. Natural gas is provided to the project site by the Southern California Gas Company (SCGC). The quantity of natural gas generated by the proposed project could potentially result in impacts with respect to the projected supply of natural gas available. Furthermore, additional improvements to existing natural gas infrastructure may be needed. As such, it is recommended that this issue be further analyzed in an EIR. XVII. MANDATORY FINDINGS OF SIGNIFICANCE. a. Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? Potentially Significant Impact. As indicated above, the proposed project would not substantially reduce the habitat of fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal. However, the project could potentially affect historic resources. Thus, it is recommended that this issue be analyzed in an EIR. b. Does the project have impacts which are individually limited, but cumulatively considerable?("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 the effects of probable future projects). Potentially Significant Impact. The potential for cumulative impacts occurs when the independent impacts of the project and the impacts of related projects in proximity to the project site combine to create impacts greater than those of the project alone. Cumulative effects regarding aesthetics and views, air quality, cultural City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-31 PRELIMINARY WORKING DRAFT Work in Progress

69 Attachment B Explanation of Checklist Determination resources, geology and soils, hazards and hazardous materials, hydrology/surface water quality, land use, noise, population and housing, public services (e.g., fire, police, schools, parks, libraries), recreation, transportation/ circulation (traffic, parking and access), and utilities (water supply, wastewater, solid waste, electricity, and natural gas services) will be analyzed in an EIR. As provided below, the project would not contribute to cumulative impacts for those environmental issues that were demonstrated by this Initial Study to be less than significant or to have no project impact. With regard to cumulative effects for the issues of agricultural, biological, and mineral resources, the project area is a densely built urban area and, therefore, like the project, other developments occurring within the project area would largely occur on previously disturbed land and are not anticipated to have an impact associated with these resources. In addition, these other developments would be subject to applicable rules and regulations regarding biological resources. Thus, no cumulative impacts to these resources would occur and further analysis of this issue is not required. c. Does the project have environmental effects which cause substantial adverse effects on human beings, either directly or indirectly? Potentially Significant Impact. The proposed project could result in potentially significant impacts with regard to aesthetics and views, air quality, cultural resources, geology and soils, hazards and hazardous materials, hydrology/surface water quality, land use, noise, population/housing, public services (fire, police, schools, parks, and libraries), recreation, transportation/circulation (traffic, parking and access), and utilities (water supply, wastewater, solid waste, electricity, and natural gas services). As these impacts could have potential adverse effects on human beings directly and indirectly, it is recommended that these issues be analyzed in an EIR. City of Los Angeles USC Specific Plan Matrix Environmental January 2009 Page B-32 PRELIMINARY WORKING DRAFT Work in Progress

70 STATE OF CALIFORNIA BUSINESS, TRANSPORTATION AND HOUSING AGENCY ARNOLD SCHWARZENEGGER Governor DEPARTMENT OF TRANSPORTATION DISTRICT 7, REGIONAL PLANNING IGRlCEQA BRANCH 100 MAIN STREET, MS # 16 LOS ANGELES, CA PHONE: (213) FAX: (213) Flex your power! Be energy efficient! February 26, 2009 IGRlCEQA No AL, NOP University of Southern California Specific Plan Vic. LA-IIOIPM 20, LA-lO/PM R SCll # Mr. Faisal Roble City of Los Angeles 200 N. Spring Street, Room 667 Los Angeles, CA Dear Mr. Roble: Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced project. The proposed project is to provide up to 2,SOO,000 square feet of academic and University-serving uses; up to 3S0,000 square feet of retail/commercial uses; and up to 2,13S,000 square feet of residential uses providing up to S,400 student beds in a variety of housing types and configurations and approximately 2S0 faculty housing units. The Specific Plan also provides a ISO-room hotel and potentially provides a K-8 laboratory school and community educational academy. To assist us in our efforts to evaluate the impacts of this project on State transportation facilities, a traffic study in advance ofthedelr should be prepared. We wish to refer the project's traffic consultant to our traffic study guideline Website: and we list here some elements of what we generally are expecting in the traffic study: 1. Presentations of assumptions and methods used to develop trip generation, trip distribution, choice of travel mode, and assignments of trips to State Route 10, 110, and all on/off ramps for I-IONermont Ave. and SR-llO/Exposition Blvd. We also have concern about queuing of vehicles using off-ramps back into mainline through lanes. We recommend the City to determine whether project-related plus cumulative traffic is expected to cause long queues on and off-ramps. "Caltrans improves mobility across California"

71 Page 2 of3 2. Consistency of project travel modeling with other regional and local modeling forecasts and with travel data. We may use indices to check results. Differences or inconsistencies must be thoroughly explained. 3. Analysis of ADT, AM and PM peak-hour volumes for both the existing and future conditions in the affected area. This should include freeways, interchanges, and intersections, and all HOV facilities. Interchange Level of Service should be specified (HCM2000 method requested). Utilization of transit lines and vehicles, and of all facilities, should be realistically estimated. Future conditions would include build-out of all projects (see next item) and any plan-horizon years. 4. Inclusion of all appropriate traffic volumes. Analysis should include traffic from the project, cumulative traffic generated from all specific approved developments in the area, and traffic growth other than from the project and developments. That is, include: existing + project + other projects + other growth. 5. Discussion of mitigation measures appropriate to alleviate anticipated traffic impacts. These mitigation discussions should include, but not be limited to, the following: Description of Transportation Infrastructure hnprovements Financial Costs, Fuuding Sources and Financing Sequence and Scheduling Considerations hnplementation Responsibilities, Controls, and Monitoring Any mitigation involving transit, or Transportation Demand Management (TDM) should be justified and the results conservatively estimated. Improvements involving dedication of land or physical construction may be favorably considered. 6. Specification of realistic mitigation measures. Caltrans may accept fair share contributions toward pre-established or future improvements on the State Highway System. Please use the following ratio when estimating project equitable share responsibility: additional traffic volume due to project implementation is divided by the total increase in the traffic volume (see Appendix "B" of the Guidelines). We note for purposes of determining proj ect share of costs, the number of trips from the project on each traveling segment or element is estimated in the context of forecasted traffic volumes which include build-out of all approved and not yet approved projects, and other sources of growth. Analytical methods such as selectzone travel forecast modeling might be used. The Department as commenting agency under CEQA has jurisdiction superceding that of Metro in identifying the freeway analysis needed for this project. Caltrans is responsible for obtaining measures that will off-set project vehicle trip generation that worsens Caltrans facilities and hence, it does not adhere to the Congestion Management Plan guide of 150 or more vehicle trips added before freeway analysis is needed. Los Angeles County's Congestion Management Program in acknowledging "Cattrans improves mobility across California"

72 Page 3 of3 the Department's role, stipulates that Caltrans must be consulted to identify specific locations to be analyzed on the State Highway System. Therefore State Route(s) mentioned in item #1 and its facilities should be analyzed per the Department's Traffic Impact Study Guidelines. To help us to determine the appropriate scope, we request that a select zone model run is performed. We look forward to reviewing the traffic study. We expect to receive a copy from the State Clearinghouse when the DEIR is completed. However, to expedite the review process, and clarify any misunderstandings, you may send a copy in advance to the undersigned. If you have any questions, please feel free to contact me at (213) or Alan Lin the project coordinator at (213) and refer to IGRJCEQA No AL. Si=l~ ELMER ALVAREZ ~ IGRJCEQA Branch Chief cc: Scott Morgan, State Clearinghouse "Caltrans improves mobility across California"

73 One Gateway Plaza Los Angeles, CA Tel metro.net February 5, 2009 Arthi Varma, City Planner City of Los Angeles Planning Department Community Planning Bureau 200 N. Spring Street, Room 667 Los Angeles, CA Dear Ms. Varma: Thank you for the opportunity to comment on the Notice of Preparation (NOP) for the University of Southern California Specific Plan project. This letter conveys recommendations from the Los Angeles County Metropolitan Transportation Authority (Metro) concerning issues that are germane to our agency's statutory responsibilities in relation to the proposed project A Traffic Impact Analysis (TIA), with highway, freeway, and transit components, is required under the State of California Congestion Management Program (CMP) statute. The CMP TIA Guidelines are published in the "2004 Congestion Management Program for Los Angeles County", Appendix D. The geographic area examined in the TIA must include the following, at a minimum: 1. All CMP arterial monitoring intersections, including monitored freeway on/off-ramp intersections, where the proposed project will add 50 or more trips during either the a.m. or p.m. weekday peak hour (of adjacent street traffic); and 2. Mainline freeway-monitoring locations where the project will add 150 or more trips, in either direction, during either the a.m. or p.m. weekday peak hour. Among the required steps for the analysis of development-related impacts to transit are: 3. Evidence that in addition to Metro, all affected Municipal transit operators received the NOP for the Draft EIR; 4. A summary of the existing transit services in the area; 5. Estimated project trip generation and mode assignment for both morning and evening peak periods; 6. Documentation on the assumptions/analyses used to determine the number and percentage of trips assigned to transit; 7. Information on facilities and/or programs that will be incorporated into the development plan that will encourage public transit usage and transportation demand management (TDM) policies and programs; and 8. An analysis of the expected project impacts on current and future transit services along with proposed project mitigation.

74 Metro looks forward to reviewing the Draft EIR. If you have any questions regarding this response, please call me at or by please send the Draft EIR to the following address: Metro CEQA Review Coordination One Gateway Plaza MS Los Angeles, CA Attn: Susan Chapman Sincerely, Susan Chapman Program Manager, Long Range Planning

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92 SCOPING MEETING DATABASE COMMENT NO. 1 USC Specific Plan Scoping Meeting on February 18, 2009 Kim Thomas-Barrios 3951 Roxton Avenue Los Angeles I am a long time resident of this area. I grew up in the area around USC and hoped one day as a child to actually attend. My dream came true as well as my brother's and sister's to attend USC and we did it on full scholarships from the university. I am now a proud parent of two USC students who the univeristy has extended scholarships to and am on staff here ushering in scores of students from the neighborhood to USC and other universities via the Neighborhood Academic Initiative program. USC has long been the purveyor of dreams through the many programs it has in the community. I am proud of this university and know that in tandem with this neighborhood, the further investment in this community in a time of economic downturn is a risk for the university. No other entity is investing as heavily as this university in this community and never has. I've spent the better part of 47 years in this univeristy and so I am grateful that the university continues to work in partnerships with the community in order to better the lives of it's residents. City of Los Angeles USC Specific Plan State Clearinghouse No March 2009 Page 1 PRELIMINARY WORKING DRAFT Work-in-Progress

93 SCOPING MEETING DATABASE COMMENT NO. 2 USC Specific Plan Scoping Meeting on February 18, 2009 Kim Thomas-Barrios 3951 Roxton Avenue Los Angeles I have lived in the community of USC for about 26 years. My parents and grandparents were and are residents as well. USC afforded my parents the possibility of sending me, my sister and brother to USC on full scholarships. My two children are currently on scholarship at USC. I am fortunate to also be on staff at USC after teaching in the community for ten years in the USC Neighborhood Academic Initiative program ushering in hundreds (489 so far) students from the university where 97% of them have gone on to college, all of them graduated from Foshay and Manual Arts and a third of them attends or attended USC on full scholarship, all because of their proximity to the univeristy. USC cares about the community. Investing in the neighborhood over the years and especially now shows the commitment USC has to the residents of the community. No other entity would even consider investing as much as USC does. They are to be commended. City of Los Angeles USC Specific Plan State Clearinghouse No March 2009 Page 2 PRELIMINARY WORKING DRAFT Work-in-Progress

94 Community Benefits Law Center A PROJECT OF THE PARTNERSHIP FOR WORK!NG FAMILIES March 2, 2009 Via Electronic Mail and U,S. Mail Arthi Varma, City Planner City of Los Angeles Planning Department Community Planning Bureau 200 N. Spring St., Room 667 Los Angeles, CA Arthi. varma@lacity.org Re: Scope of Environmental Impact Report for University of Southern California Specific Plan Dear Ms. Varma: On behalf of Strategic Actions for a Just Economy (SAJE), which convenes the Figueroa Corridor Coalition for Economic Justice (FCCEJ), we write to request that the Department of City Planning (the "Department"), in preparing the Environmental Impact Reports (ErRs) as the Lead Agency in the above-referenced matter, consider and evaluate the significant environmental impacts described in this letter, each of which, if not adequately mitigated, would result from projects governed by the University of Southern California Specific Plan (the "Plan"). We therefore further request that the Department consider and evaluate particular versions of the Plan (or alternative plans) containing measures to address the housing access, public health and small business issues that give rise to the environmental impacts discussed below. An alternative plan would help protect and expand the area's affordable housing stock, reduce discrimination in the rental market, ensure continued and improved local access to health services, and protect community-serving local businesses from displacement. The impacts of projects governed by the Plan discussed in this letter either presently occur and/or would occur in a limited geographic area surrounding the Plan area, and containing the neighborhoods (the "Neighborhoods") in which FCCEJ and allied community organizations work. The area is generally bounded by Western Avenue on the West, Washington Boulevard on the North, Grand Avenue on the East, and Vernon A venue on the South. I. Affordable Housing Impacts The significant environmental impacts related to housing by projects governed by the Plan are numerous and substantial. A. Loss of Affordable Units The Neighborhoods have experienced and continue to experience a staggering loss of affordable housing as a result of market rate development. rent increases, evictions and discrimination in the rental market. The 2007 Enterprise Community Partners University Park Housing Study (the "Enterprise Study") helps reveal a fundamental underlying fact: the dramatic growth in the number of students attending the University of Southern California (USC) and wishing to live on-campus or close to campus, coupled with USC's failure to provide housing for the vast majority of those students, is a major cause of these housing-related problems. As the Enterprise Study puts it, "the majority of [housing] displacement has occurred because of market factors that stem in part from the fact that USC has not provided its own housing for students." (Enterprise Study at 6). The Enterprise Study concludes that a total of 6,500-6,700 USC-provided student housing beds "are needed" currently. The Project Description anticipates an increase of 5,500 students (Project Description at A-IO) during the term of the Plan, but proposes a 82B VV< \Nashington Blvd" Los Angek:.s, CZ!1it(-)f'I11.19!-X) "' \\-\:v\v.communitybenefits,org/legai I I I ~

95 maximum of 5,400 beds of USC-provided housing. Thus, in the absence of further mitigation under the Plan, there is little to suggest the loss of affordable housing units caused by the relative shortage of USCprovided student housing will abate. We therefore request that the Department consider and evaluate the impact of affordable housing loss under the Plan. See L.A. City CEQA Thresholds Guide (the "Guide") J.2.1.C ("Would the project result in the net loss of any existing housing units affordable to very low- or low-income households (as defined by federal and/or City standards), through demolition, conversion, or other means?") (emphasis added.) Specifically, we request that the Department pursue the inquiries set forth in the Guide for use in determining the significance of a project's environmental impact: "The total number of residential units to be demolished, converted to market rate, or removed through other means as a result of the proposed project, in terms of net loss of market-rate and affordable units; The current and anticipated housing demand and supply of market rate and affordable housing units in the project area; The land use and demographic characteristics of the project area and the appropriateness of housing in the area... " Guide, J.2.2.A. Among the recommended methods of determining such impacts, the L.A. City Thresholds Guide includes "field research," "published reports," and "market research studies, as appropriate." In this regard we would urge the Department to carefully review the Enterprise Study. We would be happy to furnish the Department with a copy of this study and other infonnational resources, including communitygenerated data on displacement in select sections of the Neighborhoods recently requested by and submitted to the Community Redevelopment Agency Board and City Council offices. B. Consistency with Applicable Land Use Plans There are several important features of applicable land use plans and policies, the Pian's consistency with which should be considered and evaluated in examining the Plan's impact. See L.A. City CEQA Thresholds Guide H.l.C. ("Is the project inconsistent with the General Plan or its elements, or an applicable specific plan, local coastal plan, redevelopment plan, interim control ordinance or adopted environmental goals or policies?") Specifically, the Housing Element of the City's General Plan has as a Goal, "[a] City where housing production and preservation result in an adequate supply of ownership and rental housing that is safe, healthy, sanitary and affordable to people of all income levels, races, ages, and suitable for their various needs." CITY OF LoS ANGELES HOUSING ELEMENT , at 6-1. The City's Housing Element goes so far in this regard as to call for regulation covering the entire City that "requires new housing construction to include provisions for the preservation and/or construction of units that are made affordable to extremely low, very low, low, and moderate income households for at least thirty years." Id. at We find just this sort of regulation in the applicable Redevelopment Plan, which requires "at least IS percent of all new and substantially rehabilitated dwelling units developed within a project area under the jurisdiction of an agency by public or private entities or persons other than the agency shall be available at affordable housing cost to, and occupied by, persons and families of low or moderate income." EXPOSITION/UNIVERSITY PARK REDEVELOPMENT PLAN In addition, the Housing Element includes a Program for assessing housing needs in connection with the adoption of community plans. Specifically, the Program calls on the Department to "identify the housing needs of each community when each Community Plan is updated" and to"[a]ssure that revised Page 2 of6 Comments on Scope of EIR for University of Southcm California Specific Plan I I I I

96 Community Plans include the identification and implementation of measures needed to achieve appropriate housing capacities." CITY OF Los ANGELES HOUSING ELEMENT , at C. Overcrowding The Guide includes "overcrowding" in its discussion of housing problems in the City relevant to CEQA analysis. See Guide J.2.1.B. Community organizations in the Neighborhoods that have engaged in neighborhood tenant surveys report increasing incidences of overcrowding, ranging from moderate to severe (including ten, twelve, fourteen, or more people living in a one-bedroom or studio apartment, sleeping in shifts on almost every available surface, including the bathtub). This overcrowding, they report, correlates with the loss of affordable units described above, which has resulted and will result from a shortage of USC-provided student housing under the Plan. Thus fhe cumulative impact of development governed by the Plan, in the absence of adequate mitigation measures, can reasonably be expected to involve increased levels of overcrowding. We therefore request that the Department consider and evaluate the impact of the Plan, and projects undertaken thereunder, on overcrowding. D. Housing Discrimination Community organizations in the Neighborhoods have for some time been reporting increases in the number of cases of discrimination on the part of landlords in the provision of rental housing. Most often, this discrimination has been based on family status, working against families and in favor of single individual renters and/or groups of unrelated adults. While such discrimination is prohibited by state and federal law, in the absence of more specific mitigation in the Plan, it is reasonable to expect that such discrimination will continue in connection with rental units made available in areas governed by the Plans. This housing discrimination is inexorably related to the issue of access to affordable housing, since mere supply of affordable rental units will not address the issue if landlords discriminate in the leasing of those units. In addition, one of the Policies of the Housing Element is to "Promote and facilitate equal opportunity practices in the sale and rental of housing." Los Angeles City Housing Element , at We therefore request that the Department consider and evaluate the housing discrimination impacts of projects governed by the Plan. II. Public Health Impacts There are several components of CEQA and the attendant regulations and guidance that should lead the Department to examine the public health impacts of projects undertaken under the Plan. See, e.g.. CEQA Guidelines Appendix G III.d. ("Would the project expose sensitive receptors to substantial pollutant concentrations?"). Indeed, exposure of sensitive receptors to pollutants is one of several foreseeable cumulative impacts in the Neighborhoods with a substantial public health aspect. The Neighborhoods already exhibit extremely high rates of asthma, patticularly among children. Moreover, much of the housing stock was constructed before 1970, meaning that demolition or rehabilitation creates an added danger of lead dust and asbestos. In this context, we strongly urge the Department to consider and evaluate the impacts of the Plans and projects undertaken thereunder on the provision of health services. See CEQA Guidelines Appendix G VII.g. ("Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?"); Guide K.2.2.B ("Based on consultation with LAFD's Construction Services Unit, determine the cumulative effect on fire protection and emergency medical services"). In particular, to the extent that zoning or other land use regulations within the Plan areas provide for health-services-related uses, we urge the Department to examine the impact of i I I I Page 3 of6 Comments on Scope of EIR for university of Southem Calif{)ftl!a Specific Plan I

97 modifying such zoning or regulations, thereby enabling a loss of health services to a heavily healthimpacted community and necessitating the construction of other health services facilities, As well, we would urge the Department to analyze the public health impacts of the housing issues discussed above, as well as related housing issues. A substantial and growing body of scientific literature demonstrates a variety of negative impacts on the mental and physical health of persons in the following conditions caused by an inadequate provision of affordable housing: living in substandard (i.e., slum) housing conditions living in overcrowded housing forced to spend more than a third of their income on housing living under the imminent threat of eviction and consequent displacement from their home, community, and attendant support structures and networks displaced from their home, community, and attendant support structures and networks. III. Small Busiuess Impacts We respectfully request the Department analyze the impacts of the Plan and projects undertaken thereunder on small, locally-owned businesses that have historically contributed to community character and whose presence helps prevent urban decay and contributes to the economy in the Neighborhoods. See Bakersfield Citizensfor Local Control v. City of Bakersfield, 124 Cal. App. 4th 1184 (2004) (holding EIR inadequate where failed to consider projects' individual and cumulative potential to indirectly cause urban/suburban decay by precipitating a downward spiral of store closures and long-term vacancies in existing shopping centers); see also L.A. CEQA Thresholds Guide A.l.I.C ("Would the project result in the removal of one or more features that contribute to the valued aesthetic character or image of the neighborhood, community, or localized area?"). Small business owners in the Neighborhoods have reported several threats to their ability to remain in business in their current location, including increased rents and competition from national chain operations. The 350,000 square feet of commercial/retail development proposed under the Plan will exacerbate these threats if not adequately mitigated. IV. Traffic and Air Qnality Impacts It is clear from the Explanation of Checklist Determination that the Department is prepared to analyse the traffic and associated air quality impacts of the Plan. In so doing, the Department should examine in particular the traffic and associated air quality impacts of trips generated by USC staff, whose numbers are expected to increase by 3500 during the tenn of the Plan (Project Description at A-IO). As the Enterprise Study suggests, the USC programs designed to enable staff to live near campus are either inadequate or ineffective. Accordingly, and given the shortage of affordable family housing in the area. it is reasonable to anticipate that USC staff current! y commute and will increasingl y commute to their jobs at USC from substantial distances away. 1 V. Mitigation Measures In order to mitigate the significant impacts discussed above, we urge the Department to consider and evaluate the following mitigation measures or components of an alternative version of the Plan. First, to address the housing-related impacts discussed above, mitigation measures should ensure that USC, in a timely manner, constructs or otherwise provides on-campus, affordable student housing in an amount (a) commensurate with current and future student populations and (b) adequate to eliminate Page 4 of 6 Comments on Scope of EIR for University of Southern California Specific Plan I I, I I

98 USC's contribution to the cumulative negative housing impacts discussed above. See Guide J.2.I.B. ("Within the City of Los Angeles, the supply of and demand for housing, especially affordable housing, indicates that the existing stock should be preserved, maintained, and expanded in order to provide for the population"); Guide J.2.2.B. (setting forth two "potential mitigation measures" related to housing: "Ie]xceed the statutory requirements for relocation assistance" and "Ii]ncrease the number of housing units affordable to lower income households"). The Department should rely on legitimate study and analysis, such as the Enterprise Study, to determine the minimum amount of USC-provided, on-campus affordable student housing needed to mitigate the housing-related impacts discussed above. The Project Description indicates that USC will provide a maximum of 5400 beds during the tenn of the Plan. (Project Description at A-I). Yet the Enterprise Study indicates that the current need is for beds. In fact, the Enterprise Study strongly suggests that USC can feasibly construct far more student housing than that: in responding to Enterprise surveys, 69% of USC undergraduate students and 60"fc of graduate students say they would opt for USC-owned housing if rents were equal and 78% of undergraduates say they would opt for USC housing if it were guaranteed. (Enterprise Study at. 9-10, 56). If we take the Project Description's projected 2030 student populations (18,500 undergraduate and 17,000 graduate students), supplying USC-owned housing to 69% of undcrgrads (12,765) and 60% of grad students (10,500) would mean adding 16,622 beds to the 6,643 that USC currently provides. Second, mitigation measures should address the significant health-services impacts discussed above by ensuring that resources exist to support and enhance community health-services resources. This simple step is vital to ensuring that health services remain available in the Neighborhood and that additional new facilities need not be constructed. In addition, mitigation measures would ensure the protection of sensitive receptors from airborne pollution and other pollutants associated with demolition, rehabilitation or construction of structures under the Plan. Third, mitigation measures should preserve community character and prevent urban decay by protecting small, locally-owned businesses in the neighborhoods from displacement. The Department has already seen fit to adopt an Interim Control Ordinance in areas covered by the South and Southeast Community Plans regulating the establishment of fast-food chains. There is room for further measures to protect those small local businesses that contribute to the health and economic vitality of the Neighborhoods. Fourth, mitigation measures should address traffic and air quality impacts by providing for (a) more affordable housing uptions in the vicinity of USC's campus for USC staff, as recommended in the Enterprise Study, and (b) local hiring measures to ensure that employment opportunities generated by development under the Plan go to residents of the Neighborhoods. These measures will enable USC staff to actually live where they work, thereby reducing commutes and, accordingly, the cumulative traffic and associated air quality impacts of the Plan. We believe that these mitigation measures are both feasible and consistent with the objectives of the Plan as set forth in the Project Description. VI. Relationship to CPIO Nexus Study We additionally wish to express our understanding of the relationship between (a) the CEQA process for the Plan and (b) the Nexus Study related to the proposed Community Plan Implementation Overlay. We understand the CEQA process for the Plan and the Nexus Study to be wholly independent undertakings. Each one will fully and separately address impacts and issues occurring in the Page 50f6 Comments on Scope of ElR for University of Southern California Specific Plan

99 neighborhoods surrounding the Plan. And the fact that an issue has been or may be addressed in the Nexus Study will in no way obviate the need to address that issue in the CEQA process for the Plan, and vice-versa. Please inform us immediately if this understanding is incorrect in any way. Thank you for your consideration of our comments. Please do not hesitate to contact me with any questions you may have. Very truly yours, ~~- Benjamin S. Beach Staff Attorney Page6of6 Comments 011 Scope of EIR for University of Southern California Specific Plan

100

101

102

103

104

105

106 March 2, 2009 Arthi Varma, City Planner City of Los Angeles, Planning Department Community Planning Bureau 200 North Spring Street, Room 667 Los Angeles, California Transmitted via RE: USC Specific Plan Nexus Study Dear Ms. Varma: The following comments are provided in response to the USC Specific Plan Nexus Study as proposed at the Scoping Meeting for the USC Specific Plan DEIR. I am a resident homeowner and active community member of the residential neighborhood of North University Park. I live here by choice and a proud to be a part of this community. The North University Park neighborhoods comprise a richly diverse community of many ethnic and racial backgrounds that includes many long term residents, young families, students and USC staff and faculty members. We are very concerned with preserving the richness of this community that only such diversity of stakeholders can provide. The North University Park Neighborhood and other adjacent neighborhoods also contain a rich heritage of historic housing stock. USC has continuously expanded into the residential neighborhoods surrounding the Campus. In the late 1970 s and early 80s many residents of the communities north of Campus felt a continued threat of USC expansion. The last big expansion occurred with the Hoover Redevelopment Project, created in the mid to late 1970 s. The Hoover Project, of which USC was a prime beneficiary, allowed USC to tidy up its boundaries by expanding east and west to the Figueroa and Vermont Avenue corridors. North of Campus, a sizeable area of historic housing stock was taken out to create the University Village Shopping Center. The continued growth of the University without adequate provision of student housing has also decreased the supply of affordable housing through removal of existing housing stock for other uses and University and private absorption of existing housing stock for student rooming houses. In addition, as the population density in the area was increasing, other impacts of this transition were not adequately addressed. This Specific Plan as proposed would continue the de facto extension of the existing campus across Jefferson from the current campus edge. Throughout this continual movement of campus activity into the neighborhoods, the potential impacts to the coherence of the surrounding communities have not been adequately addressed. This proposed Nexus Study has the potential to help reverse the trend. First and foremost it must address the provision of much needed USC campus housing for the existing student population. The proposed scope of the Nexus Study is so narrow that it does not address the impact on the surrounding communities except with respect to affordable housing; greenspace; parking; car-sharing opportunities; and, infrastructure needs for the surrounding community areas. The Nexus Study must also address cut-through traffic, impacts related to dividing established communities, noise and public services such as police and fire. Further, issues related to community and campus linkages, pedestrian and bicycle links between the proposed project and other campus and community services, use of the Coliseum as a USC sports venue, relocation and proliferation of campus support services into the

107 March 2, 2009 page 2 Maggi Fajnor surrounding community should be addressed. Without this information, it is not possible to adequately address the potential impacts to the surrounding communities of the USC Specific Plan; thus, preserving the surrounding communities and their heritage and preventing further impacts resulting from the increasing expansion of USC and USC related projects into the surrounding neighborhoods. Secondly, the Nexus Plan process must offer adequate opportunity for community input. All that we are asking is that USC work in partnership with the community to provide for the student and other campus needs and not export its impacts onto the community. By working in concert with the community, the proposed USC Specific Plan activities may become an asset rather than a drain on the community and its resources. Thank you for the opportunity to comment on the proposed Nexus Study. Sincerely yours, Maggi Fajnor 2631 Orchard Avenue Los Angeles, California maggi4f@earthlink.net

108 West Adams Heritage Association Arthi Varma, City Planner City of Los Angeles Planning Department Community Planning Bureau 200 North Spring St., Room 667 Los Angeles, CA RE: ENV EIR University of Southern California Specific Plan March 2, 2009 Dear Ms. Varma: I am writing on behalf of the West Adams Heritage Association (WAHA) as Chair of the organization s Historic Preservation Committee. WAHA represents over three hundred and fifty households in the West Adams area and is dedicated to the preservation of the areas architectural and cultural heritage. It supports preservation and sound planning initiatives both within and outside its formal boundaries. The proposed specific plan area lies within the boundaries of WAHA as outlined in its By-Laws and also lies within and adjacent to historic neighborhoods as defined by HPOZs, Historic Cultural Monuments, and designated and/or surveyed historic areas. These include but are not limited to the Memorial Coliseum, the Exposition Park National Register District, the Flower Drive California Register Historic District, the Menlo Historic District; the Fraternity Sorority Row surveyed District, the Shrine Auditorium, Felix Chevrolet, Chester Place Historic District and the St. James Park Historic District, to name just a few. Any specific plan needs to address impacts on historic resources with a view to making strategic decisions that encourage preservation and historic settings. There are significant issues of parking and circulation, adequate community services and amenities and how planning decisions effect the environment. Too often formulas are embraced out of context for the quality of living in the area. A very significant land mass is University Village which was developed as part of the Hoover project area is a major concern with a view to creating neighborhood serving uses, and mitigating the parking and traffic issues of the area.

109 The concept of transferring neighborhood commercial to Vermont is a questionable strategy, as the Vermont corridor has very narrow depth lots adjoining residential areas that are in the process of rehabilitation and restoration. For the Vermont corridor there is a tension between getting people in and out of the area, against creating attractive and useful commercial. I look forward to reviewing the Draft EIR and the process of creating a specific plan that serves the community. I look forward to additional comment during this process. Jean Frost, Chair WAHA, Historic Preservation Committee c/o 2341 Scarff Street Los Angeles, CA

110

111 SCOPING MEETING DATABASE COMMENT NO. 3 USC Specific Plan Scoping Meeting on February 18, 2009 Gerard Gumbleton 1835 S. Hope Street Los Angeles I would like to urge the Department of City Plannning to review displacement of our homeless community members in your EIR and in the Nexus Study. There are over 73,000 homeless individuals living on the streets in Los Angeles every night and the numbers are growing. I urge you to address the issue of homelessness and the resources available for this marginalized community in and around the University Park Neighborhoods. Additionally, I am interested in receiving your draft EIR, when they are available. City of Los Angeles USC Specific Plan State Clearinghouse No March 2009 Page 3 PRELIMINARY WORKING DRAFT Work-in-Progress

112

113

114

115 Los Angeles 16th February 2009 Arthi Varma, City Planner City of Los Angeles Planning Department, Community Planning Bureau 200 North Spring Street, Room 667 Los Angeles CA RE: University of Southern California Specific Plan ENV EI R I will not be able to attend the public meeting on 18th February 2009, so I'll briefly state my concerns here. Your Notice, dated 30 January 2009 contained a list of "environmental factors potentially affected". Included in that list was the problem of noise. This issue is particularly.important to me, and I trust the planners and builders will take extra care to assure that our residential areas are not affected by noise in excess of that allowed by existing city and state laws. I have lived on South Flower Street for 28 years, and for the last six (6) years, we have been subje~ted to a great deal of noise associated with two USC construction projects (the parking structure at Exposition and Figueroa and the Credit Union building), as well as the construction of the Tuscany apartment building at 3760 South 'Figueroa and now the light rail line on Exposition Boulevard. During this six-year period, two specific issues related to noise have been particularly annoying, and I trust they can be mitigated (or eliminated) this time around. 1. Night Construction, City Ordinances are clear about restrictions on noise in residential areas, especially at night. Please be sure that these projects obey those laws. 2. Backup Beeping on construction vehicles. Contractors and builders seem to assume that backup beeping must be used on large vehicles, and that it doesn't matter how loud the beeping sounds are. This is not the case. First of all, OSHA guidelines and state law allow for silent alternatives, such as human observers to signal to drivers when it is safe (or not safe) to reverse their vehicles. OSHA and state law also allow less-intrusive sounds, such as white-noise or buzzing, rather than penetrative beeping, to be used to meet the requirements of having a sound that is audible above the ambient noise level. Please insist that these projects use these alternatives to standard backup-beeping when working in residential areas. Again, city ordinances forbid excessive noise in residential areas. Backup-beeping must comply with those ordi ces, too. Thank you, Gerald Jones, Box Los Angeles CA

116

117 Laura Meyers 1818 South Gramercy Place, Los Angeles CA Arthi Varma, City Planner City of Los Angeles Planning Department Community Planning Bureau 200 North Spring St., Room 667 Los Angeles, CA RE: ENV EIR University of Southern California Specific Plan March 2, 2009 Dear Ms. Varma: I am writing on behalf of the North University Park Community Association (NUPCA), to submit areas of concern that I would like you to address in the EIR for the USC Specific Plan. I have represented NUPCA on the Community Redevelopment Agency s PAC/CAC for the University-Exposition Park (former Hoover) Project Area since 1989, and am very familiar with the environmental setting. You were quoted in the Daily Trojan as acknowledging that there had been several questions on the boundaries of the plan and that this is just a proposal. The boundaries are subject to change. My comments are predicated in part on that, given that the areas just immediately outside the boundaries printed on the notice include many sensitive historic and cultural resources, including but not limited to the Flower Drive National Register Historic District, the J.M. Stewart Cottage on West 31 st Street, two other National Register Historic Districts, and many individually-designated historic properties. I believe, therefore, it would be most appropriate for the EIR to consider the impacts (positive and/or negative) of this proposed Master Plan/Specific Plan on a wider group of historic resources, and to consider further mitigations beyond the minimal protections, in some instances, currently in place. In addition to noting that, please be sure to consider the following: Parking. In particular, a part of the USC Master Plan called for the re-envisioning of the University Village as a new, more dense, mixed-use complex. At several community meetings, stakeholders have expressed the desire that this possible project and/or others include additional joint use parking to help alleviate parking problems in North University Park. I note that in the current notice for the scoping meeting there is a reference to pool parking for university serving buildings and functions, and that

118 demand studies are contemplated. I feel that this is an insufficient approach. The EIR should not just analyze new projects but also try to mitigate existing conditions. And, currently the residential neighborhoods surrounding the university often have a complete and utter lack of available street parking. Proposal to transfer neighborhood serving commercial to Vermont Avenue. Vermont s existing built form and typical sites are basically strip commercial. On game and event days at the Coliseum all parking is eliminated on Vermont. It would seem that the only way to create viable neighborhood-serving commercial would be to pierce the current adjacent historic residential neighborhoods, including the Menlo Avenue National Register Historic District. The proposed nexus study is in an area that is primarily historic, and thus any discussion of affordable housing and infrastructure needs to be made with due regard for the character of the neighborhood(s). I am not clear how affordable housing plays a role in environmental review, and would like an explanatory response about that as well. I look forward to reviewing the Draft EIR. I do hope that the next public hearing, for that document, could be held at a time that is not in conflict with your own department s other scoping or environmental meetings, since this February 18, 2009, scoping event was scheduled for the exact same time as the City Planning Department s scoping meeting for Washington Square, also in the Historic West Adams District. Thank you very much. Laura Meyers 2 ENV EIR/LETTER FROM NUPCA, LAURA MEYERS

119