IV. ENVIRONMENTAL IMPACT ANALYSIS I. PUBLIC SERVICES 1. FIRE PROTECTION

IV. ENVIRONMENTAL IMPACT ANALYSIS I. PUBLIC SERVICES 1. FIRE PROTECTION ENVIRONMENTAL SETTING Within the City of Los Angeles, fire prevention, fire suppression, and emergency medical services are provided by the Los Angeles Fire Department (LAFD), as governed by the Fire Protection and Prevention Plan, an element of the General Plan of the City of Los Angeles ( General Plan ), as well as the Los Angeles Fire Code (Los Angeles Municipal Code [LAMC], Chapter V, Article 7). The Fire Protection and Prevention Plan and Fire Code serve as guides to City Departments, government offices, developers, and the public for the construction, maintenance, and operation of fire protection facilities located within the City. The LAFD operates 103 neighborhood fire stations that are strategically located throughout the Department s 470-square-mile jurisdiction. The LAFD s 3,562 uniformed personnel and 338 professional support personnel protect life, property, and the environment through their involvement in fire prevention, firefighting, emergency medical care, technical rescue, hazardous materials mitigation, disaster response, public education, and community service. A total of 1,091 uniformed firefighters (including 223 firefighter/paramedics), are on duty at all times. LAFD equipment includes engines, trucks, paramedic engines, crash units, hazardous materials response and decontamination units, foam carriers, rescue ambulances, helicopters, and boats. 1 Fire Stations The Project site is located at 26900 South Western Avenue in the Wilmington-Harbor City Community Plan Area (CPA). The LAFD has three existing fire stations that provide initial response to calls for fire protection and emergency medical services in the Project s CPA: Fire Station Nos. 85, 38, and 49. 2 A truck company, engine company, and paramedic rescue team (Station 85) are presently located approximately 1.1 miles from the Project site. Table IV.I-1 lists the LAFD stations that serve the Project site and the surrounding community, along with their equipment, staff, and distance from the Project site. A map of the station locations is provided in Figure IV.I-1. LAFD services and budgeting issues are reviewed on an ongoing basis by the City of Los Angeles. At the present time there are no specific plans to add new LAFD facilities in the Project area. 1 2 LAFD, website: http://www.lafd.org/about.htm, September 3, 2006. LAFD, written correspondence from Douglas L. Barry, Assistant Fire Marshal, Bureau of Fire Prevention and Public Safety, December 7, 2005, and City of Los Angeles, Wilmington-Harbor City Community Plan, adopted July 14, 1999, p. III-26. Page IV.I-1

Slip page for Figure IV.I-1, Police and Fire Station Location Map Page IV.I-2

Table IV.I-1 Fire Stations that Serve the Project Site Distance Station No. Address Equipment 1 Staff 2 from Project Site (mi) 3 85 1331 W. 253 rd St. Harbor City, CA 90710 Task Force Truck and Engine Company Paramedic Rescue Ambulance 12 1.1 38 124 E. I St. Wilmington, CA 90744 Task Force Truck and Engine Company Paramedic Rescue Ambulance 12 2.5 49 4 Wilmington, CA 90744 Boats 3 and 4 13 3.3 400 Yacht St., Berth 194 Single Engine Company 1 Typically, a Task Force consists of a truck company and an engine company, with a total of ten personnel. A truck company includes two vehicles: a truck (i.e., a vehicle with a 100-foot aerial ladder apparatus) and an engine (i.e., a vehicle with a pump). An engine company consists of one vehicle: an engine. 2 Most LAFD personnel are EMT qualified. EMTs provide basic first aid and medical services. 3 Computed to 26900 S. Western Avenue. 4 Battalion 6 Headquarters. Source: LAFD, written correspondence from Douglas L. Barry, Assistant Fire Marshal, Bureau of Fire Prevention and Public Safety, December 7, 2005. In addition, backup support for fire protection services in the Project area is provided through an informal mutual aid agreement between the LAFD and the Los Angeles County Fire Department (LACFD). The decision as to which agency responds to a particular emergency in the Project area is made on a case-bycase basis, based on the nature and location of the emergency, and the availability of fire protection equipment at the time. 3 There are two LACFD fire stations within a two-mile radius of Project site: Station 6 located at 25517 S. Narbonne Avenue in Lomita (approximately 1.5 miles from the Project site), and Station 83 located at 83 Miraleste Plaza in Rancho Palos Verdes (approximately 1.5 miles from the Project site). In addition to fire stations, equipment, and personnel, water flow (also called fire flow ), response distance from available fire protection service facilities, emergency access, and fire hazards are considered to be important factors in the following analysis. 4 Fire Flow In general, the required fire flow for a project is closely related to land use because the quantity of water necessary for fire protection varies with the type of development, life hazard, type and level of occupancy, and degree of fire hazard (based on such factors as building age or type of construction). Fire 3 4 LAFD, telephone conversation with Captain Buzzell, Fire Station 85, February 16, 2006. The Initial Study prepared for the Notice of Preparation (NOP), which is included as Appendix I-1 to this Draft EIR, determined that the Project is not subject to potential adverse impacts related to this issue (see Checklist Questions 7[a] and 7[h] in the Initial Study). As such, further discussion of fire hazards is not required by CEQA. Page IV.I-3

flow requirements, which are established in Section 57.09.06 of the Fire Code, vary from 2,000 gallons per minute (gpm) in low-density residential areas to 12,000 gpm in high-density commercial or industrial areas. In any instance, a minimum residual water pressure of 20 pounds per square inch (psi) is to remain in the water system while the required gpm is flowing. The Project site is not located within an Inadequate Fire Hydrant Service Area recognized by the City of Los Angeles. 5 Water for fire flows for the area surrounding the Project site that is within the City of Los Angeles jurisdiction is provided by the City of Los Angeles Department of Water and Power (LADWP). 6 All water mains and lines that are designed and sized according to LADWP standards take into account fire flow and pressure requirements. In the immediate vicinity of the Project site, there is a 12-inch LADWP water line south of the Project site under Western Avenue that terminates at Avenida Aprenda, and a 49- inch LADWP water line that runs along the southern boundary of the Project site. For further discussion of water infrastructure, refer to Section IV.K.1 (Water) of this Draft EIR. Response Distance and Emergency Access Response distance relates directly to the linear travel distance (i.e., miles between a station and a project site). The Los Angeles Fire Code specifies the maximum response distances allowed between specific sites and engine and truck companies based on land use and fire flow requirements. Pursuant to Section 57.09.07 of the LAMC, the maximum response distance between residential land uses and a LAFD fire station that houses an Engine or Truck Company is 1.5 miles. When response distances exceed these recommendations, all structures must be equipped with automatic fire sprinkler systems and any other fire protection devices deemed necessary by the Fire Chief (e.g., fire signaling systems, fire extinguishers, smoke removal systems, etc.). The LAFD s ability to provide adequate fire protection and emergency response services to a site is also determined by the degree to which emergency response vehicles can successfully navigate the given accessways and adjunct circulation system, which is largely dependent on roadway congestion and intersection Level of Service (LOS) along the response route. As shown in Figure IV.I-1, the paths between Fire Station Nos. 85, 38, and 49 include the following major roadways that would most likely be utilized in the event of an emergency at the Project site: Anaheim Street, Normandie Avenue, Pacific Coast Highway, Palos Verdes Drive North, Gaffey Street, Westmont Drive, and Western Avenue. 7 As discussed in Section IV.J (Transportation and Traffic) of this Draft EIR, the following intersections along potential LAFD response routes currently operate at LOS E or F during peak commuting hours: 5 6 7 Environmental and Public Facilities Maps, Map No. 11: Inadequate Fire Hydrant Service Areas, Los Angeles City Planning Department, 1996. Areas surrounding the Project site that are not within the City of Los Angeles jurisdiction are served by the California Water Service Company. Detailed descriptions of these roadways are included in Section IV.J (Transportation and Traffic) of this Draft EIR. Page IV.I-4

Western Avenue/Pacific Coast Highway; and Western Avenue/Palos Verdes Drive North. Western Avenue provides direct emergency access to the Project site via three ingress/egress points at Green Hills Drive, John Montgomery Drive, and Avenida Aprenda. As discussed in Section IV.J (Transportation and Traffic) of this Draft EIR, none of the intersections that provide direct emergency access to the Project site currently operate at LOS E or F during peak commuting hours. ENVIRONMENTAL IMPACTS Thresholds of Significance In accordance with Appendix G to the State CEQA Guidelines, the Project would have a significant environmental impact if it would: Result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for the fire department. Project Impacts Construction Fire resulting from mishaps is a typical construction risk. However, general good housekeeping procedures employed by the construction contractors and the work crews (e.g., maintaining mechanical equipment, proper storage of flammable materials, cleanup of spills of flammable liquid) minimize these hazards. Construction activities also have the potential to affect fire protection services, such as emergency vehicle response times, by adding construction traffic to the street network and by necessitating partial lane closures during street improvements and utility installations. These impacts, while potentially adverse, are considered to be less than significant for the following reasons: Construction activities are temporary in nature and do not create continuing risks; General good housekeeping procedures employed by the construction contractors and the work crews (e.g., maintaining mechanical equipment, proper storage of flammable materials, cleanup of spills of flammable liquid) minimize these hazards; and Partial lane closures would not significantly affect emergency vehicles, the drivers of which normally have a variety of options for dealing with traffic, such as using their sirens to clear a path of travel or driving in the lanes of opposing traffic. Additionally, if there are partial closures Page IV.I-5

to streets surrounding the Project site, flagmen would be used to facilitate the traffic flow until construction is complete. Overall, construction is not considered to be a high-risk activity, and the LAFD is equipped and prepared to deal with construction-related traffic and fires (should they occur). Project construction would not be expected to tax fire fighting and emergency services to the extent that there would be a need for new or expanded fire facilities in order to maintain acceptable service ratios, response times, or other performance objectives of the LAFD. Therefore, construction-related impacts to fire protection and emergency medical services would be less than significant. Operation As discussed in Section IV.H (Population and Housing) of this Draft EIR, the Project is predicted to generate approximately 4,313 residents and 29 employees at the Project site, and would increase the amount of developed square footage on the Project site. Therefore, the Project would result in an increased need for fire protection and emergency medical services at the Project site. The following discussion analyzes the major criteria for determining a project s impacts to fire protection services, including fire flow and response distance. Fire Flow The required fire flow for the Project has been set at 7,500 gpm from five hydrants flowing simultaneously. 8 The Project would replace the existing on-site water system with new water lines configured in a looped system that would be maintained and supplied by the LADWP via two connection points to an existing LADWP water main under Western Avenue. To provide the loop, the 12-inch LADWP water line under Western Avenue would be extended approximately 6,000 feet from the southerly boundary of the Project site north to John Montgomery Drive. 9 The new on-site water system would consist of public lines with private easements (see Section IV.K.1 [Water] of this Draft EIR for further discussion of water infrastructure). The Water Operations Division of the LADWP would perform a detailed fire flow study at the time of permit review in order to ascertain whether further water system or site-specific improvements would be necessary. Hydrants, water lines, and water tanks would be installed per Fire Code requirements for the Project. In addition, the Project applicant would be required to submit the proposed plot plan for the Project to the LAFD for review for compliance with applicable Los Angeles Fire Code, California Fire Code, City of Los Angeles Building Code, and National Fire Protection Association standards, thereby ensuring that the proposed Project would not create any undue fire hazard. LAFD review is a legal prerequisite, and Mitigation Measures I-2, I-4, and I-26 restate this requirement. As such, with respect to fire flows, fire protection services would be adequate and the associated impact would be less than significant. 8 9 LAFD, written correspondence from Douglas L. Barry, op. cit. LADWP, written correspondence from Charles C. Holloway, Supervisor of Environmental Assessment, February 8, 2006. Page IV.I-6

Response Distance As shown in Table IV.I-1, the Project site is located approximately 1.1 miles from the nearest LAFD truck and engine company. Therefore, the Project would be within the LAFD s required response distance of 1.5 miles for residential land uses. Although the installation of automatic fire sprinkler systems is not required pursuant to LAMC Section 57.09.07, the applicant indicates that the proposed structures would be equipped with sprinklers. As discussed above, the LAFD s ability to provide adequate fire protection and emergency response services to a site is also determined by the degree to which emergency response vehicles can successfully navigate the given accessways and adjunct circulation system, which is largely dependent on roadway congestion and intersection LOS along the response route. As discussed in Section IV.J (Transportation and Traffic) of this Draft EIR, upon completion of the Project and implementation of the proposed traffic mitigation measures, potential impacts to all studied intersections, including the intersections of Western Avenue/Pacific Coast Highway and Western Avenue/Palos Verdes Drive North would be mitigated to a less-than-significant level, even taking into account cumulative growth and related projects. Thus, the impact of the Project in conjunction with cumulative growth and related projects upon emergency response times would be less than significant after mitigation. Furthermore, the LAFD has indicated that distance to the nearest fire station is the primary indicator of the LAFD s ability to provide adequate fire protection services for a project. 10 As discussed above, the Project site is approximately 1.1 miles from the nearest LAFD fire station housing both an Engine and Truck Company, and is therefore within the LAFD s 1.5-mile required response distance for residential uses. There are also two other LAFD stations and two LACFD stations in the vicinity of the Project site that could provide supplemental fire and emergency services (see Fire Stations discussion above). Emergency access to the Project would be provided by three ingress/egress points at various locations on Western Avenue at the intersections of Green Hills Drive, the relocated John Montgomery Drive, and Avenida Aprenda. The three access points, which would also provide general, non-emergency access to the site, would be gated with restricted public access; however, the gates would be designed with key or code access for emergency vehicles. An internal roadway system would enable any of these emergency access points to be reached from any location in the Project. In addition, as part of a reciprocal emergency access arrangement, the Project site would have emergency access from its southern access point through the Mary Star of the Sea High School to Taper Avenue. Thus, the Project site would be able to take emergency access from an additional street other than Western Avenue. 11 It is anticipated that the proposed access plan would provide adequate emergency access to the Project site in the event of an emergency. Nonetheless, the Project applicant is required to submit the proposed plot plan for the Project to the LAFD for review for compliance with applicable Los Angeles Fire Code, California Fire 10 11 Draft EIR for the Olympic and Soto Project, Christopher A. Joseph & Associates, 2006. Use of the Taper Avenue emergency access would be strictly limited to emergency conditions necessitating access to the Project site from locations other than Western Avenue. In all other circumstances, access to the Project Site would be taken from Western Avenue. Page IV.I-7

Code, City of Los Angeles Building Code, and National Fire Protection Association standards, thereby ensuring that the proposed Project would not create any undue fire hazard. Furthermore, pursuant to Mitigation Measure D-6 in Section IV.D (Hazardous Materials and Risk of Upset) in this Draft EIR, the Project applicant would submit an emergency response plan for approval by the LAFD. The Project applicant would consult with neighboring land uses and the emergency response plan would include but not be limited to the following: mapping of emergency exits, evacuation routes for vehicles and pedestrians, location of nearest hospitals, and fire departments. Additionally, the Project site is located within a four-mile drive of the following hospitals, all of which house 24-hour emergency departments: Kaiser Permanente, 25825 South Vermont Avenue, Harbor City CA 90710 (approx. 1.5 mi.) San Pedro Peninsula Hospital, 1300 West 7th Street, San Pedro, CA 90732 (approx. 3 mi.) Torrance Memorial Medical Center, 3330 Lomita Boulevard, Torrance, CA 90505 (approx. 4 mi.) For the reasons listed above, impacts related to emergency access would be less than significant. For additional discussion of potential Project impacts related to emergency evacuation, see Section IV.D (Hazardous Materials and Risk of Upset) of this Draft EIR. MITIGATION MEASURES Because the Project would have a less-than-significant impact on fire protection services, mitigation measures are not required pursuant to CEQA Guidelines Section 15126.4. However, the following measures are recommended which reflect existing legal requirements and/or good planning principles, and which would further reduce the Project s less-than-significant impacts: (I-1) (I-2) (I-3) (I-4) (I-5) (I-6) Sprinkler systems shall be installed throughout structures to be built. The number and location of adequate off-site public and on-site private fire hydrants, if required, shall be determined after the Los Angeles Fire Department (LAFD) s review of the plot plan and integrated into the Project design. Private streets and entry gates shall be built to City standards to the satisfaction of the City Engineer and the Fire Department. Plot plans indicating access road and turning area shall be submitted for Los Angeles Fire Department (LAFD) approval. Construction of public or private roadway in the proposed development shall not exceed 15 percent grade. During demolition, the Fire Department access shall remain clear and unobstructed. Page IV.I-8

(I-7) (I-8) (I-9) (I-10) (I-11) (I-12) (I-13) (I-14) (I-15) (I-16) (I-17) (I-18) The width of private roadways for general access use and fire lanes shall not be less than 20 feet clear to the sky. Fire lanes, where required, and dead ending streets shall terminate in a cul-de-sac or other approved turning area. No dead ending street or fire lane shall be greater than 700 feet in length, or secondary access shall be required. No proposed development utilizing cluster, group, or condominium design of one or two family dwellings shall be more than 150 feet from the edge of the roadway of an improved street, access road, or designated fire lane. All access roads, including fire lanes, shall be maintained in an unobstructed manner, and removal of obstructions shall be at the owner s expense. The entrance to all required fire lanes or required private driveways shall be posted with a sign no less than three square feet in area in accordance with Section 57.09.05 of the Los Angeles Municipal Code (LAMC). Fire lane width shall not be less than 20 feet. When a fire lane must accommodate the operation of a Fire Department aerial ladder apparatus or where fire hydrants are installed, those portions shall not be less than 28 feet in width. Where above ground floors are used for residential purposes, the access requirement shall be interpreted as being the horizontal travel distance from the street, driveway, alley, or designated fire lane to the main entrance of individual units. The entrance or exit of all ground dwelling units shall not be more than 150 feet from the edge of a roadway of an improved street, access road, or designated fire lane. Where access for a given development requires accommodation of a Fire Department apparatus, the minimum outside turning radius of the paved surface shall be 35 feet. An additional six feet of clearance space must be maintained beyond the outside radius to a vertical point 13 feet 6 inches above the paved surface of the roadway. No building or portion of a building shall be constructed more then 150 feet from the edge of a roadway of an improved street, access road, or designated fire lane. Where access for a given development requires accommodation of Fire Department apparatus, overhead clearance shall not be less than 14 feet. Where fire apparatus will be driven onto the road level surface of the subterranean parking structure, that structure shall be engineered to withstand a bearing pressure of 8,600 pounds per square foot. The Project shall comply with all applicable State and local codes and ordinances, and the guidelines found in the Fire Protection and Fire Prevention Plan, as well as the Safety Page IV.I-9

Plan, both of which are elements of the General Plan of the City of Los Angeles (C.P.C. 19708). (I-19) (I-20) (I-21) (I-22) (I-23) (I-24) (I-25) (I-26) Any required fire hydrants to be installed shall be fully operational and accepted by the Los Angeles Fire Department (LAFD) prior to any building construction. Private streets shall be recorded as Private Streets and Fire Lane. All private street plans shall show the words Private Street and Fire Lane within the private street easement. All parking restrictions for fire lanes shall be posted and/or painted prior to any Temporary Certificate of Occupancy being issued. Electric gates approved by the Los Angeles Fire Department (LAFD) shall be tested by the LAFD prior to the Los Angeles Department of Building and Safety (LADBS) granting a Certificate of Occupancy. No building or portion of building shall be constructed more than 300 feet from an approved fire hydrant. Distance shall be computed along path of travel, with the exception of dwelling unit travel distance, which shall be computed to front door of unit. Where rescue window access is required, conditions and improvements necessary to meet accessibility standards as determined by the Los Angeles Fire Department (LAFD) shall be provided. All public street fire lane cul-de-sacs shall have the curbs painted red or be posted No Parking Any Time prior to the issuance of a Certificate of Occupancy or Temporary Certificate of Occupancy for any structures adjacent to the cul-de-sac. Definitive plans and specifications shall be submitted to the Los Angeles Fire Department (LAFD) and requirements for necessary permits shall be satisfied prior to commencement of any portion of the Project. CUMULATIVE IMPACTS Of the 174 related projects listed in Table III-2 in Section III (Environmental Setting) of this Draft EIR, 48 projects are located within the City of Los Angeles, nine are located in the City of Rancho Palos Verdes, ten are located in the City of Rolling Hills Estates, 14 are located in the City of Carson, five are located in the City of Long Beach, 47 are located in the City of Torrance, 34 are located in the City of Lomita, and seven are located in the County of Los Angeles. Fire protection service for the County of Los Angeles and the Cities of Rancho Palos Verdes, Rolling Hills Estates, Carson, and Lomita is provided by the LACFD. Fire protection service in the City of Long Beach is provided by the Long Beach Fire Department. Fire protection service in the City of Torrance is provided by the Torrance Fire Department. Therefore, 126 of the related projects (i.e., those that are not located in the City of Los Angeles) would not have the potential to combine with the Project and cumulatively impact fire protection service provided by the LAFD. Page IV.I-10

The Project is located in the Wilmington-Harbor City CPA. Of the 48 related projects located in the City of Los Angeles, 16 projects are located in the Wilmington-Harbor City CPA (related projects 1, 3, 5, 7, 11, 16, 20, 32, 33, 34, 35, 42, 43, 44, 47, and 48), 23 projects are located in the San Pedro CPA (related projects 2, 4, 6, 8, 10, 12, 14, 15, 17, 18, 19, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, and 45), and nine projects are located in the Harbor Gateway CPA (related projects 9, 13, 36, 37, 38, 39, 40, 41, and 46). Initial fire protection and emergency medical response to the 16 related projects located in the Wilmington-Harbor City CPA would be provided by LAFD Stations 85, 38, and 49, the same stations that would serve the Project. Initial fire protection and emergency medical response to the 23 related projects located in the San Pedro CPA would be provided by LAFD Stations 48 and 101, respectively located at 1601 South Grand Avenue and 1414 25 th Street. 12 Initial fire protection and emergency medical response to the nine related projects located in the Harbor Gateway CPA would be provided by LAFD Station 79, located at 18030 South Vermont Avenue. 13 As discussed above, Project impacts to fire protection service would be less than significant, and the Project s less-than-significant impacts would be further reduced by implementation of mitigation measures recommended as Project conditions above. The 16 related projects located in the Wilmington- Harbor City CPA, would, in conjunction with the Project, contribute to the cumulative demand for fire protection services in the Community. Similar to the Project, each of the related projects located within the City of Los Angeles is subject to the requirements of LAMC Section 57.09.07, which mandates the installation of automatic fire sprinkler systems if a project is located at a distance to the nearest fire station that exceeds the LAFD required response distance. Each of the related projects in the City of Los Angeles is also required to consult with LAFD and LADWP during their design phase to establish fire flow requirements for the land uses proposed and to determine adequacy of existing fire flow infrastructure serving their respective project sites. Any LAFD or LADWP-required upgrades to the water distribution systems serving the related projects would be addressed for each individual related project in conjunction with their project approvals. Each of the related projects in the City of Los Angeles is also individually subject to LAFD review and would be required to comply with all applicable fire safety requirements of the LAFD and the City of Los Angeles, including hydrant and access improvements, if necessary, in order to adequately mitigate fire protection impacts. If any of the related projects would create demands on fire protection staffing, equipment, or facilities such that a new station would be required, potential environmental impacts would be addressed in conjunction with the environmental review for that project. Depending on the facility and staffing decisions made by the City of Los Angeles, new or physically altered fire protection facilities may be authorized at some time in the future to meet future demands. The decision to construct these new or altered facilities is part of the City s general planning and budgeting process and is outside the scope of this Draft EIR. Further, until facility decisions are made, their potential impacts on the physical environment, if any, cannot be evaluated. In addition to implementing recommended project specific mitigation measures, the Project would contribute to funding fire protection services in the area, as it would generate $8.3 million (in 2005 dollars) in annual revenue from 12 13 LAFD, Neighborhood Fire Stations, website: http://www.lacity.org/lafd/fsloc.htm, February 20, 2006. Ibid. Page IV.I-11

property taxes that would be deposited into the City s General Fund and could potentially be used to fund the construction of future fire protection facilities (see Appendix IV.F-1 to this Draft EIR). Therefore, the Project s incremental effect is not considered cumulatively considerable, and cumulative impacts would be less than significant. LEVEL OF SIGNIFICANCE AFTER MITIGATION Project-specific impacts to fire protection service would be less than significant. Page IV.I-12