iv. environmental impact analysis j.4 public services .... parks... · ross valencia pocket park, a...

City of Los Angeles Boyle Heights Mixed-Use Community Project SCH. No. 2008061123 October 2011

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WORKING DRAFT – Not for Public Review

IV. Environmental Impact Analysis J.4 Public Services—Parks and Recreation

1. Introduction

This section analyzes the potential impacts of the proposed project on parks and recreational facilities. The analysis identifies the existing parks and recreational facilities in the project vicinity and determines whether they can accommodate the growth generated by the project. The analysis also evaluates the proposed project’s provisions for recreational facilities and open space relative to applicable City goals and regulatory requirements. Information regarding parks and recreational facilities surrounding the project site was provided in part by the City of Los Angeles Department of Recreation and Parks (DRP). This section is based in part on information provided by the DRP included in Appendix K-1 of this Draft EIR.

2. Environmental Setting

a. Existing Conditions

(1) Local Area

The City of Los Angeles Department of Recreation and Parks is responsible for the provision, operation, and maintenance of parks and recreational facilities in the project vicinity. Currently, the DRP maintains and operates more than 390 sites for recreational use including: 180 recreation centers, 59 swimming pools, 13 municipal golf courses, nine lakes, seven camps (both within and outside of City limits), more than a dozen museums and historic sites, and hundreds of programs for youth, seniors, the physically disabled, and volunteers. The DRP also administers more than 15,600 acres of parkland, including 4,217 acres in Griffith Park, one of the largest municipal parks within the boundaries of an American city.90 As of 2008 (the existing conditions year for the project), the City of Los Angeles as well as the Boyle Heights Community Plan Area, within which the project site is

90 Los Angeles Department of Recreation and Parks, Who We Are, www.laparks.org/dos/dept/who.htm, accessed August 2, 2010.

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located, both had a park ratio of 0.70 acre of neighborhood and community parkland per 1,000 residents.91 (Further discussion of parkland ratios is provided below.)

The project site is located in the Metro Region of the DRP’s jurisdiction. Several park and recreational facilities are located within a 2-mile radius of the project site.92 As shown in Figure IV.J-4 on page IV.J-82, these park and recreational facilities include the following:93

Lou Costello Recreation Center, located immediately southeast of the project site at 3141 East Olympic Boulevard, includes Costello Pool, the Costello Senior Citizen Center, and Hostetter Playground, as well as various ball courts and fields, a gymnasium, picnic area, auditorium, and community room.

Monseignor Ramon Garcia Recreation Center (formerly Fresno Park Recreation Center), a 7.26-acre neighborhood facility located at 1016 South Fresno Street, approximately 0.25 mile northeast of the project site, which includes ball courts, a gymnasium, playground, picnic area, auditorium, and community room.

Boyle Heights Sports Center, an 8.20-acre neighborhood park located at 933 South Mott Street, approximately 0.32 mile north of the project site, which includes a ball field and courts, a playground, picnic area, and community room.

Hollenbeck Park and Recreation Center, Skate Park, and Lake, a 21.24-acre community facility located at 415 South Saint Louis Street, approximately 0.70 mile north of the project site. This facility includes ball courts, a gymnasium, playground, picnic area, auditorium, and community room.

Evergreen Recreation Center and Childcare Center, a 6.45-acre community facility located at 2839 East 4th Street, approximately 0.96 mile northeast of the project site, which includes ball courts, a gymnasium, playground, picnic area, auditorium, and community room.

Ross Valencia Pocket Park, a 0.08-acre pocket park located at East 1st Street and Chicago Street, approximately 1.19 miles north of the project site.

91 Written communication, Jon Kirk Mukri and Michael Shull, City of Los Angeles Department of Recreation and Parks, July 18, 2008.

92 Distances listed for each park are approximate driving distances. 93 Written communication, Jon Kirk Mukri and Michael Shull, City of Los Angeles Department of Recreation

and Parks, July 18, 2008; and the Department of Recreation and Parks website, www.laparks.org, accessed May 11, 2010.

Figure IV.J-4

Locations of Existing Parks and Recreation Facilities

in the Vicinity of the Project Site

Boyle Heights Mixed Use Community ProjectSource: Google Earth Pro, 2010; Matrix Environmental, 2010.

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Lou Costello Recreation Center3141 East Olympic Boulevard

Monseignor Ramon Garcia Recreation Center1016 South Fresno Street

Boyle Heights Sports Center933 South Mott Street

Hollenbeck Park and Recreation Center,Skate Park, and Lake415 South Saint Louis Street

Evergreen Recreation Centerand Childcare Center2839 East 4th Street

Ross Valencia Pocket ParkEast 1st Street & Chicago Street

Pecan Recreation Center127 South Pecan Street

Prospect Park612 North Echandia Street

State Street Recreation Center716 North State Street

Wabash Recreation Center2765 Wabash Avenue

Ross Snyder Recreation Center1501 East 41st Street

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Pecan Recreation Center, a 4.28-acre neighborhood park located at 127 South Pecan Street, approximately 1.36 miles northwest of the project site, includes Pecan Park Pool, several ball courts, a playground, gymnasium, picnic area, and community room.

Prospect Park, a 2.68-acre neighborhood park located at 612 North Echandia Street, approximately 1.75 miles north of the project site, includes a playground.

State Street Recreation Center, a 2.56-acre neighborhood park located at 716 North State Street, approximately 1.76 miles north of the project site, includes a ball field and courts, a playground, auditorium, and community room..

Wabash Recreation Center, a 1.34-acre neighborhood park located at 2765 Wabash Avenue, approximately 1.93 miles northeast of the project site, includes ball courts, a gymnasium, playground, auditorium, and community room.

Ross Snyder Recreation Center, an 11.46-acre community park located at 1501 East 41st Street, approximately 2 miles southwest of the project site, which includes the Ross Snyder Pool, various ball courts and fields, a gymnasium, playground, picnic area, auditorium.

Given its location adjacent to the project site, Costello Recreation Center is the DRP facility most easily accessible to existing site residents. The center is heavily used by local residents, particularly in summer months when the pool is open, and a variety of classes and organized activities are held. Over time, the facilities at the center have deteriorated and are currently in need of repair. In addition to extensive graffiti throughout the park, numerous facilities and equipment exhibit dilapidated conditions, including play equipment that is damaged and unusable; several buildings show visible signs of structural decay; and equipment storage facilities are inadequate. The City has proposed plans to demolish and rebuild the swimming pool and bathhouse, with improvements to the pool pump house, basketball court, playground, parking lot, perimeter fencing, landscaping, and irrigation system. While some funding has been identified via park fees and voter-approved taxes, substantial additional funding is needed before the project can commence.

(2) Project Site

The existing site’s open space and yard areas in relation to the building footprints and paved areas, including the amount of acreage devoted to each type of use, is illustrated in Figure IV.J-5 on page IV.J-84. As shown, the existing contiguous grassy open space consists of approximately 9.5 acres. This calculation takes into account green space that is clearly bounded by public walkways on all sides, that has buildings fronting all sides, and that is not associated with any one building in particular, such as a forecourt, streetscape, parking area, driveway, or area that has been claimed by an adjacent unit with fencing. Photographs depicting the character and location of the existing publically

Boyle Heights Mixed Use Community ProjectSource: Torti Gallas and Partners, Inc. 2011.

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Overview of Existing Conditions

Including Existing Open Space

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accessible open space are provided in Figure IV.J-6 on page IV.J-86. The existing open space is irregular in shape and characterized by narrow fingers that protrude into developed areas of the site. While the open space is relatively significant in size, its awkward configuration, and uneven grade, limits its usefulness and makes it difficult to provide high quality passive and active recreational opportunities for the residents of the existing site and the surrounding community. The lawn and planted areas are in varying state of disrepair. The functionality, attractiveness and use of the existing space is further diminished by the multiple asphalt pedestrian pathways running throughout the open space as well as the fact that some existing residents have fenced or walled in portions of the public open space so as to create private yards for themselves.

In addition to the contiguous open space there are approximately 9.71 acres of “interstitial open space” composed of bits and pieces of open space formed by the gaps between buildings or courtyards within buildings. Photographs depicting the character and location of the existing interstitial open space are provided in Figure IV.J-7 on page IV.J-87. In some cases these spaces have grass or plantings, and in some cases theses spaces are comprised of dirt surfaces. While some of these areas are grassy, because they are small, irregularly shaped, and often tightly sandwiched between buildings, roads, and parking lots, they do not significantly contribute to the open space at the project site. There are another approximately 17.25 acres of unfenced “yard space” which are composed of the areas between the façades of each building and the adjacent asphalt pathways. Photographs depicting the character and location of the existing unfenced yard space are provided in Figure IV.J-8 on page IV.J-88. In addition, there are another 3.55 acres of private yards that were originally either interstitial open space or common open space that have been claimed by individual units as private open space through the use of fencing. Photographs depicting the character and location of the existing fenced yard space are provided in Figure IV.J-9 on page IV.J-89. Existing “courtyard” spaces, which in many cases consist of the yard space in the middle of a U-shaped building or the space in between two U-shaped buildings facing each other, are included in either the “interstitial open space” or unfenced “yard space” categories. Photographs depicting the character and locations of the existing courtyard spaces are provided in Figure IV.J-10 on page IV.J-90. There are also an additional 8.2 acres of asphalt-covered surface parking lots.

The largest expanse of open space at the site, known as the Mall, is approximately 80 feet wide and approximately one-third of a mile in length. This lawn area functions as an open space/drainage channel running from west to east, surrounded by pedestrian pathways, and with a perpendicular section bisecting the channel from north to south. Running the length of the Mall is a 40 foot wide surface drainage channel over which the City of Los Angeles has an easement that was granted in 1939. Overtime, the extensive tree root systems compounded by settlement of compacted subsurface conditions provide poor water penetration into the soil, resulting in pooling and standing water within the City’s drainage easement area and parts of the Mall are prone to flooding where it does not drain

FIFTEENGROUP LAND AND DEVELOPMENTTorti Gallas and Partners / M E L É N D R E Z

OPEN SPACE ANALYSIS EXISTING CONDITIONSJULY 7, 2011

Character of Existing Publically Accessible Open Space

Figure IV.J-6

Existing Publically Accessible Open Space

Page IV.E.1-23

Boyle Heights Mixed-Use Community ProjectSource: Fifteen Group Land and Development; Torti Gallas and Partners; Melendrez, 2011.

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OPEN SPACE ANALYSIS EXISTING CONDITIONSJUNE 14, 2011

Character of Existing Interstitial Open Space

Figure IV.J-7

Existing Interstitial Open Space

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Character of Existing Unfenced Yard Space

Figure IV.J-8

Existing Unfenced Yard Space

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Character of Existing Fenced Yard Space

Figure IV.J-9

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OPEN SPACE ANALYSIS EXISTING CONDITIONSSEPTEMBER 20, 2011

Character of Existing Courtyards

Figure IV.J-10

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adequately. Over time, this condition has caused site erosion, particularly through the center of the site within the Mall and along adjacent build entryways and porches. Please see View 3 in Figure II-5 in Section II, Project Description, of this Draft EIR. The resulting erosion has worn away the finished ground surface in areas such that the site's open space is rutted and uneven in grade and the erosion of the top soil has exposed underground pipes in places, thus rendering the open space less functionally usable for recreation. Nonetheless, the Mall and the interstitial open space areas are used occasionally for passive recreation. In addition, there is a small area of the Mall that includes recreational equipment for children.

In summary, because of the configuration of the site on six superblocks and the organization of the residential buildings around the Mall, access and sight lines through the open space areas are limited. The configuration of the existing buildings means that much of the contiguous open space cannot be accessed physically or visually from the residential units. In most cases, building entrances are on the other side of the units from the green spaces. The inability of residents to monitor these areas from the existing buildings is a security concern and is particularly noticeable at the Mall. There is also a lack of connectivity between the various fingers of open space, and a lack of direct access from existing buildings to existing open space. The interstitial spaces are often perceived as neither public nor private and hence are underutilized, neglected, and often unsafe. In addition, over the years occupants of individual units have claimed some common open space areas for private use through the erection of fences and walls, leaving such areas unavailable for the enjoyment of the community. Please refer to Figures IV.J-5 through IV.J-9 for photos illustrating these existing site conditions.

b. Regulatory Framework

(1) State Level

(a) Quimby Act

Section 66477 of the California Government Code, also known as the Quimby Act, was enacted in an effort to promote the availability of park and open space areas in response to California’s rapid urbanization and decrease in the number of parks and recreational facilities. The Quimby Act authorizes cities and counties to enact ordinances requiring the dedication of land, or the payment of fees for park and/or recreational facilities in lieu thereof, or both, by developers of residential subdivisions as a condition to the approval of a tentative map or parcel map. Los Angeles Municipal Code (LAMC) Section 17.12 was authorized pursuant to the Quimby Act.

The Quimby Act requires that parkland dedications not exceed 3 acres of parkland per 1,000 persons residing within a subdivision and that in-lieu fee payments not exceed



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the proportionate amount necessary to provide 3 acres of parkland, unless the amount of existing neighborhood and community parkland exceeds that limit. As stated above, the current ratio of parkland in the project area is 0.70 acre per 1,000 residents. Thus, since the parkland standard is not exceeded in the project area, the maximum parkland dedication requirement for the proposed project under the Quimby Act would be 3 acres of parkland per 1,000 residents.

(2) Local Level

The DRP has completed a number of planning documents that address the need for parks and recreational facilities within the City of Los Angeles. The most recent document completed by DRP is a Citywide Community Needs Assessment, discussed below. In addition, the City of Los Angeles General Plan indicates that the adequacy of the public park and recreation system is based on three general standards: (1) sufficient land area reserved for parks and recreation; (2) appropriate distribution of park and recreation facilities throughout the City; and (3) a full complement of park and recreation facility types (i.e., active and passive recreation for all age groups) to accommodate a wide variety of users. The General Plan further states that parks and recreational facilities should be provided at the neighborhood, community, and regional levels.

The Public Recreation Plan (PRP), a component within the Service Systems Element of the City’s General Plan, establishes policies and standards related to parks, recreation facilities, and open space areas in the City. The PRP provides citywide goals, objectives, and recommendations concerning parks and recreation facilities. In addition to the standards established in the PRP, park and open space requirements pursuant to the Quimby Act are also set forth in Sections 12.21 and 17.12 of the LAMC. The following provides information regarding both the PRP and applicable LAMC standards and requirements, as well as relevant objectives and policies from the Boyle Heights Community Plan.

(a) Citywide Community Needs Assessment

Recognizing the importance of parks and open space in the community, in 2009 the DRP completed a Citywide Community Needs Assessment (Assessment) that examines current and future recreational needs in the City as a first step in developing a Citywide park master/strategic plan and a five-year capital improvement plan. The overall objectives of the Assessment are to identify, quantify, and preliminarily prioritize the need for recreation and open space within the City, address needs for additional recreational facilities and parkland, identify improvements to facilities to meet current and future



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demands, prevent future maintenance issues, and offer positive alternatives to an increasingly dense and urbanized population.94 The Assessment provides a number of key recommendations to be implemented through a detailed master planning process. These recommendations include, but are not limited to, working with the City’s Planning Department to modify Section 17.12 of the LAMC and update the PRP, developing an updated pricing and revenue plan to offset capital and operational costs, and implementing a land acquisition strategy involving developer impact agreements based on the standards for open space desired.95

Based on the Assessment, the expectation as to how far people are willing to travel to parks and recreational facilities has changed drastically since the time that the PRP (discussed below) was adopted in 1980. Specifically, 63 percent of survey respondents for the Assessment stated that they would travel at least 1 mile to visit a neighborhood park, and 38 percent of respondents would travel at least 2 miles. Additionally, 71 percent of respondents would travel at least 2 miles to visit a community park, while 37 percent would travel more than 3 miles. Given the accessibility of public transit, people have the opportunity to access parks further than 0.5 mile from their place of residence.

The Assessment identifies some of the challenges faced by the DRP, including acquiring additional recreation and park land, preventing future maintenance problems through effective asset management and offering positive recreational alternatives to an increasingly dense and urbanized population.

The Assessment sets forth guidelines for the DRP with respect to the size of parks and recommended service levels for the City’s residents as follows:

Mini parks of less than 1 acre in size: 0.10 acre per 1,000 persons;

Neighborhood parks between 1 and 5 acres in size: 1.5 acres per 1,000 persons;

Community parks between 10 and 50 acres in size: 2 acres per 1,000 residents; and

94 Los Angeles Department of Recreation and Parks, Citywide Community Needs Assessment, www.laparks.org/planning/pdf/exeSum.pdf, accessed August 30, 2010.

95 Los Angeles Department of Recreation and Parks, Final Report of the Citywide Community Needs Assessment, www.laparks.org/planning/pdf/finalReport.pdf, accessed August 30, 2010.



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Regional and large urban parks of greater than 50 acres in size: 6 acres per 1,000 residents.

The Assessment also makes the following findings:

The City lacks the appropriate levels of neighborhood and community parks that are close to home, and parks are not equitably distributed.

The amount of park land available in the City is low for the level of density in the City, and people would like more land for mini‐parks, neighborhood parks, community parks and downtown parks. More parks are needed in redevelopment areas.

There is a concern that some parks are unsafe and controlled by gangs and lack significant security, keeping people from using such parks in a productive manner.

Parks are in need of infrastructure improvements to restrooms, parking areas, playgrounds, picnic facilities, sports courts, security lighting, irrigation systems, and sports fields. Poor general site conditions encourage vandalism and keep the community from using the parks in a positive manner.

Sports fields are a needed amenity.

Sustainable landscapes in parks are an important design element that the DRP should incorporate into design standards.

Some existing parks are outdated in design. The DRP needs to develop new design standards for parks in the future and customize the parks to the people living in the area that will be using each park.

The walkability of the City and the ability to walk in City parks are important.

The DRP must create a balance of park types and manage park and amenity standards that promote equal access.

Many citizens indicate that parks are overused on weekends.

Los Angeles River improvements were brought forward as opportunity sites that could be developed and improved for parks and recreational purposes.

(b) Public Recreation Plan

Adopted in 1980 by the Los Angeles City Council, the PRP focuses on the development of physical facilities by emphasizing the provision of neighborhood and community recreation sites, including community buildings, gymnasiums, swimming pools,



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and tennis courts.96 To a large extent, the PRP focuses on facility planning in residential areas, as these areas generate the greatest demand for parks and recreational facilities. The PRP also establishes general locations for future facilities based on a proposed service radius and projected population levels.

According to the standard park characteristics identified in the PRP, park facilities are discussed in terms of local parks and regional facilities. Local parks (while not discussed in the PRP) are generally accepted to include neighborhood and community recreation sites, open space, and “small” parks, which are usually characterized as less than 1 acre in size. A neighborhood park typically provides space and facilities for outdoor and indoor recreational activities intended to serve residents of all ages within the immediate neighborhood. Neighborhood parks typically include a recreation building, multi-purpose field, hard court area, play apparatus, picnic area, off-street parking, and a maintenance area. Although the PRP states that minimum desirable acreage of a neighborhood park is 5 acres and the ideal size for a neighborhood park is considered to be 10 acres, such parks within the City of Los Angeles are typically between 1 to 5 acres in size. Community parks are designed to serve residents of all ages in several surrounding neighborhoods and include such facilities as community buildings, multi-purpose fields, hard court areas, parking, maintenance service areas, and play areas. These facilities may also include baseball diamonds, football and soccer fields, tennis and handball courts, and a swimming pool. According to the PRP, the minimum desirable acreage of a community park is 15 acres and the ideal size for a community park is considered to be 20 acres. Regional parks are generally at least 50 acres and provide specialized recreational facilities such as lakes, golf courses, campgrounds and museums. Regional parks serve residents throughout the Los Angeles basin.

The PRP also states that the location and allocation of acreage for neighborhood and community park and recreational facilities should be determined on the basis of the service radius within residential areas throughout the City. The desired long-range standard for local parks is based on a minimum of 2 acres per 1,000 persons for neighborhood parks with a service radius of 0.5 mile, and a minimum 2 acres per 1,000 persons for community parks with a service radius of 2 miles. However, the PRP also notes that these long-range standards may not be reached during the life of the plan and, therefore, includes more attainable short- and intermediate-range standards of 1 acre per 1,000 persons within a 1-mile service radius for neighborhood parks and 1 acre per 1,000 persons within a 2-mile service radius for community parks. These standards are

96 City of Los Angeles, Public Recreation Plan, a portion of the Service Systems Element of the Los Angeles General Plan, approved October 9, 1980.



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Citywide goals and are not intended to be requirements for individual development projects. Furthermore, as indicated above, the Citywide Community Needs Assessment states that since the time that the PRP was adopted in 1980, the expectation as to how far people are willing to travel to parks and recreational facilities has changed drastically. Given the accessibility of public transit, it is now easy and convenient for people to access parks further than 1 or 2 miles from their place of residence.

(c) Los Angeles Municipal Code

Section 12.21 of the LAMC requires that all residential developments containing six or more dwelling units on a lot provide, at a minimum, the following usable open space area per dwelling unit: 100 square feet for each unit having less than three habitable rooms, 125 square feet for each unit having three habitable rooms, and 175 square feet for each unit having more than three habitable rooms.97 Section 12.21 of the LAMC also identifies what areas of a project qualify as usable open space for the purposes of meeting the project’s open space requirements. Usable open space is defined as areas designed and intended to be used for active or passive recreation and may consist of private and/or common areas as further defined and regulated in Section 12.21. Common open space (i.e., areas that are readily accessible to all residents of the site) must constitute at least 50 percent of the total required usable open space. Common open space areas can incorporate recreational amenities such as swimming pools, spas, children’s play areas, and sitting areas. A minimum of 25 percent of the common open space area must be planted with ground cover, shrubs, or trees. In addition, indoor recreation amenities cannot constitute more than 25 percent of the total required usable open space. Private open space is defined as areas which are contiguous to and immediately accessible from an individual dwelling unit and which contain a minimum of 50 square feet, of which no more than 50 square feet per dwelling unit is counted toward the total required usable open space. Private open space may not have a dimension of less than 6 feet in any direction.

In addition, Section 17.12 of the LAMC, authorized under the Quimby Act, requires developers of residential subdivisions to set aside and dedicate land for park and recreational uses and/or pay in-lieu fees for park improvements. The area of land within a subdivision that is required to be dedicated is determined by the maximum density permitted by the zone within which the development is located. The proposed project is requesting a zone change to the Boyle Heights Mixed-Use Specific Plan Zone, which would be permitted to develop a maximum density of 60 to 70 dwelling units per acre. Thus, based on the provisions set forth in LAMC Section 17.12, 24.7 percent or approximately

97 Per LAMC Section 12.03, for the purpose of applying the open space requirements of Section 12.21 G, a kitchen shall not be considered a habitable room.



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16.5 acres of the gross subdivision area would be required to be dedicated to park and recreational uses.

If the developer does not meet the full dedication requirement, fees for park improvements may be paid to the DRP in lieu of the dedication of all or a portion of all the land. The in-lieu fees are calculated per dwelling unit to be constructed based on the zoning of the project site and must be paid prior to the issuance of building permits. These fees are adjusted annually. As the project involves a zone change to newly defined zone, the in lieu fee shall be established by DRP.

Section 17.12 of the LAMC allows recreation areas developed on a subdivision for use by the particular subdivision’s residents to be credited against the project’s land dedication requirement. High intensity recreational areas that qualify under this provision of Section 17.12 include, in part, swimming pools and spas (when the spas are an integral part of a pool complex), tennis and basketball courts, and children’s play areas with playground equipment comparable in type and quality to those found in City parks. Low intensity recreational areas include landscaped open areas, picnic grounds and athletic fields. Furthermore, the recreational areas proposed as part of a project must meet the following standards in order to be credited against the requirement for land dedication: (1) each facility is available for use by all residents of a subdivision; and (2) the area and the facilities satisfy the park and recreation needs of a subdivision so as to reduce that project’s need for public park and recreation facilities. Importantly, the recreational facilities must be privately owned and maintained and the use of the facilities must be restricted for park and recreational purposes by recorded covenants that run with the land.

(d) Boyle Heights Community Plan

As further described in Section IV.G, Land Use, of this Draft EIR, the Boyle Heights Community Plan (Community Plan) was originally adopted on November 10, 1998. The Community Plan sets forth objectives, policies, and programs to meet the needs of the Boyle Heights community through the year 2010. The intent of the Community Plan is to promote an arrangement of land uses, circulation, and services that will encourage and contribute to the economic, social, and physical health, safety, welfare, and convenience of the people who live and work in the community.

The Community Plan provides a number of objectives and policies regarding recreation and park facilities. In particular, objectives and policies of the Community Plan regarding recreation and park facilities include the following:



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(i) Objectives

1. To provide adequate recreation and park facilities which meet the needs of the residents in the community.

2. To conserve, maintain and better utilize existing recreation and park facilities which promote the recreational experience.

(ii) Policies

Preserve and improve the existing recreation and park facilities and park space.

In addition to the acquisition of new parkland and expansion and improvement of existing parks, the Community Plan recognizes that joint use of public school facilities may help to achieve parkland goals, as will the use of open space along freeways. In addition to dedicated park and recreational facilities, open space frequently serves recreational purposes. Pursuant to the Community Plan, open space is broadly defined as follows:

“Land which is essentially free of structures and buildings or is natural in character and which functions in one or more of the following ways: (1) recreational and educational opportunities; (2) scenic, cultural, and historic values; (3) public health and safety; (4) preservation and creation of community identity; (5) right-of-way for utilities and transportation, facilities; and (6) preservation of natural resources as ecologically important areas.” 98

3. Environmental Impacts

a. Methodology

The methodology used to evaluate potential park and recreation impacts involves the following: (1) reviewing the existing parks and recreational facilities in the project vicinity; (2) projecting the future residential population associated with the project; and (3) evaluating the demand for park and recreation service anticipated at the time of project buildout compared to the expected level of service available, considering both DRP facilities as well as the project’s open space and recreational amenities. In addition, the analysis compares the project’s provision of recreational and open space areas to the standards set forth by the Quimby Act, the PRP, and the LAMC. To be consistent with the standards set forth in the aforementioned regulatory guidance documents, the analysis of

98 Boyle Heights Community Plan, November 10, 1998, pages III-7 and III-8.



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impacts is based, in part, on the acreage of park/open space available per 1,000 project residents. It is noted, however, that the PRP parkland standards are Citywide goals and do not constitute requirements for individual development projects.

b. Thresholds of Significance

Appendix G of the CEQA Guidelines provides sample questions that address impacts with regard to public facilities such as parks, as well as recreation. These questions are as follows:

Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, need for new or physically altered governmental facilities, the construction of which would cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:

Parks?

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?

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?

In the context of these questions, based on the City of Los Angeles CEQA Thresholds Guide (2006) and Appendix G of the CEQA Guidelines, the determination of significance for impacts to parks and recreation facilities is made on a case-by-case basis, considering the following factors:

The net population increase resulting from the proposed project.

The demand for recreational and park services anticipated at the time of project build-out compared to the expected level of service available. Consider, as applicable, scheduled improvements to recreation and park services (renovation, expansion, or addition) and the project’s proportional contribution to the demand.

Whether the project includes features that would reduce the demand for recreational and park services (e.g., on-site recreation facilities, land dedication or direct financial support to the Department of Recreation and Parks).



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Based on these factors, the proposed project would have a significant impact on parks and recreational services if:

The project generates a demand for park or recreational facilities that cannot be adequately accommodated by existing or planned facilities and services; or

Project construction interferes with existing park usage in a manner that would substantially reduce the service quality of the existing parks in the project area.

c. Project Design Features

The project would include a substantial amount of landscaped open space and recreational areas of different scales and styles. The goals of these open space areas are to: (1) provide safe recreational opportunities in an under-served community; (2) make available a mix of active and passive recreational uses; (3) ensure open sight lines; (4) facilitate access by a variety of users; (5) promote a high level of connectivity throughout the neighborhood; and (6) provide clearly delineated public and private boundaries to ensure a safe environment for residents, park users, and businesses.

The size and configuration of the new open space will create a cohesive and interconnected open space environment that will provide a variety of active and passive recreational opportunities that accommodate a wide variety of users. Specifically, the project would include a civic plaza, an expansive central park, active parks with recreational facilities, neighborhood greens, neighborhood playgrounds, and landscaped courtyards and pathways. All of the various parks will provide either active or passive recreational opportunities to the community. The passive areas within the neighborhood parks will offer shade trees, shade trellises, benches, small plaza spaces and places to sit and relax. Playground equipment, appropriate to a variety of age groups, will be constructed, as well as adequate shade and seating for supervising adults. Open space and recreational areas would be spread throughout the site, with the most expansive open space element centrally located and adjoining other nearby open space amenities, as shown in Figure II-6 in Section II, Project Description.

The surface drainage channel within the existing Mall would be replaced in the project with a state-of-the-art stormwater management system comprised of bio-swales, biofiltration and infiltration, native plantings and oaks. Known as the Arroyo Walk, this modern stormwater management system would move stormwater across the site through the bio-swales for infiltration, incorporating pedestrian pathways and natural plantings. This central park would serve as the central public gathering area for the project and include a linear water feature and a paved civic plaza space which will function as an outdoor community patio.



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Three neighborhood and/or civic parks to be located along the northern boundary of the project site at Eighth Street are significant design features of the new open space. The project would redistribute the open space so that it is accessible and inviting to the surrounding neighborhood. The two tot-lots that would be improved as part of the project would provide a direct linkage between the project and the adjacent schools of Christopher Dena Elementary School located on Dacotah Street to the east of the site and the Garza Primary Center located on E. Hostetter Street to the west of the site. The tot-lots would provide active recreational opportunities as well as increase pedestrian participation in the development.

As discussed in detail in Section II, Project Description, of this Draft EIR, the proposed project includes approximately 10.5 acres of publicly available, privately funded and maintained, usable open space. This space would include a civic plaza, an expansive central park, active parks, neighborhood greens, and neighborhood playgrounds. Recreational areas would include amenities such as play equipment, athletic courts, seating, and open play areas. A public use easement would ensure access for the greater general public from dawn until dusk.

In addition, semi-private open space would be provided for each individual development within the site. Semi-private open space includes facilities such as pools, recreational rooms within residential buildings, roof decks, and courtyards. The required percentage of semi-private open space set forth in the Specific Plan is based on building types; each building type would have a minimum open space requirement that is measured as a percentage of the lot area and ranges from 15 percent to 30 percent (e.g., rowhouses would require at least 15 percent of the lot area to be dedicated to open space, podium buildings would require at least 25 percent, podium high-rise buildings would require at least 30 percent, etc.). Furthermore, the Specific Plan dictates how the minimum open space requirements can be achieved for each building type, for instance through yards, patios, roof decks, courtyards, etc. The final amount of semi-private open space provided on-site would vary depending on the building types ultimately selected for development, however, based on a conservative conceptual site plan and conceptual building arrangement presented in Figure II-6 and Figure II-7 in Section II, Project Description, the project is expected to include approximately 11 acres of semi-private open space. Such facilities would be available to the residents of each building/complex within which each facility is located. In total, the project’s public and semi-private open space/recreational areas would be approximately 21.5 acres.

Private open space may also be provided in the form of residential balconies accessible from individual dwelling units. Based on conservative assumptions, it is



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anticipated that at least 2.5 acres of private balconies would be provided.99 Such private spaces would be in addition to the open space requirements set forth in the Specific Plan and would provide for a total of approximately 24 acres of public, semi-private, and private recreational and open space on-site. Moreover, the project would provide approximately 10.4 acres of landscaped streetscape and approximately 7.8 acres of unfenced yard space.

The project’s open space and yard areas in relation to the building footprints and paved areas, including the amount of acreage devoted to each type of use, is illustrated in Figure IV.J-11 on page IV.J-103. Upon completion of the project, the total amount of open space at the ground level, including publicly accessible open space, unfenced yards, streetscape, interstitial spaces, paseos, and courtyards would be 37.25 acres, compared to 36.43 acres of comparable space that currently exists on the project site. However, the proposed project would reorganize the hierarchy of open space by eliminating the 8.2 acres of surface parking lots and much of the existing interstitial open space and yard space, and replacing these areas with enhanced streetscapes, a reorganized and improved park system, and courtyard spaces for each of the proposed new buildings. As such, the quality and usability of the on-site open spaces would be substantially improved.

Up to 25,000 square feet of civic uses would also be provided as part of the project. These uses would be located in the central northern portion of the site and would consist of community-serving or public facilities, potentially including a public library and community room.

d. Analysis of Project Impacts

(1) Impacts on Existing Facilities

As discussed in Section IV.I.3., Population, of this Draft EIR, the proposed project includes the development of up to 4,400 new dwelling units, which would introduce an estimated residential population of 10,127 persons (a net increase of 3,982 persons over current site conditions). The net population increase associated with the proposed development would generate additional demand for parks and recreational facilities. However, as discussed above, the project would provide approximately 24 acres of public, semi-private, and private open space with various substantial active and passive recreational amenities. Due to the size and availability of a wide range of amenities, it is anticipated that project residents would primarily utilize on-site open space to meet their recreational needs. Therefore, the use of off-site park and recreational facilities by project

99 Assumes that half of all residential units on-site have a 50-square-foot balcony.

Boyle Heights Mixed Use Community ProjectSource: Torti Gallas and Partners, Inc. 2011.

0 600 Feet300

NFigure IV.J-11

Overview of Proposed Conditions Including Proposed Open Space

Page IV.J-103



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residents would be minimized. While project residents would be expected to utilize off-site community parks and recreational facilities to some degree, given the amount of park and open space amenities to be provided on-site, the project’s population of 10,127 residents would not cause or accelerate substantial physical deterioration of any off-site local or regional park or recreational facilities. In addition, off-site recreational facility use by employees and customers of the proposed project is expected to be minimal. Through the availability of on-site facilities, the project’s demand for park facilities is anticipated to be adequately met. Thus, the project would not substantially increase the use of off-site neighborhood and regional parks and recreational facilities, nor would it substantially increase demand for recreation programs.

(2) Consistency with Regulations

(a) Public Recreation Plan (PRP)

As discussed above, the PRP’s desired long-range standard for local parks for the City is 2 acres per 1,000 persons for neighborhood parks and 2 acres per 1,000 persons for community parks. However, the PRP also notes that these long-range standards may not be reached during the life of the plan, and therefore includes more attainable short- and intermediate-range standards of 1 acre per 1,000 persons for neighborhood parks and 1 acre per 1,000 persons for community parks. Currently, both Citywide park space and Community Plan Area park space are provided at an estimated rate of 0.70 acre per 1,000 residents.100 Therefore, neither the City nor the Community Plan Area meets the PRP’s desired short-, intermediate-, or long-range standards. However, as previously indicated, these standards are Citywide goals and are not intended to be requirements for individual development projects. Furthermore, the Citywide Community Needs Assessment states that since the time that the PRP was adopted in 1980, the distance many people are willing to travel to parks and recreational facilities has increased substantially.

Based on the estimated 10,127 residents to be generated by the project, the project would require approximately 20 acres of neighborhood parkland within a 0.5-mile radius to meet the PRP’s long-range standard or approximately 10 acres within a 1-mile radius to meet the PRP’s short- and intermediate-range standard. Of the approximately 24 acres of public, semi-private, and private open space to be provided by the project, approximately 10.5 acres would consist of publically available, privately funded and maintained open space, including a civic plaza, an expansive central park, active parks with recreational

100 Written communication, Jon Kirk Mukri and Michael Shull, City of Los Angeles Department of Recreation and Parks, July 18, 2008.



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facilities, neighborhood greens, neighborhood playgrounds, and landscaped courtyards and pathways and, thus, would be considered as neighborhood parkland. Also, there is an additional 11 acres of semi-private open space throughout the project that would be readily accessible to residents. These amenities essentially provide the residents with a neighborhood park that is customized to the type of residential development proposed. These facilities would serve residents of all ages within the immediate neighborhood (the residential unit) and would include both active and passive recreational amenities and, therefore, should also be included when considering the public open space at the project. Therefore, in total, the project would provide approximately 21.5 acres of neighborhood open space, thereby exceeding the approximately 20 acres needed to meet the PRP’s long-range standard. The proposed project would also meet the short- and intermediate-range standards for neighborhood parks. For comparison, based on the project’s net population increase of 3,982 residents, the project would require approximately 8 acres of neighborhood parkland within a 0.5-mile radius to meet the PRP’s long-range standard or approximately 4 acres within a 1-mile radius to meet the PRP’s short- and intermediate-range standard. The project would meet these standards.

Similarly, with regard to community parks, the project would need to provide approximately 20 acres of community parkland to meet the PRP’s long-range standard or approximately 10 acres to meet the short- and intermediate-range standard of the City. With the project’s common open space and recreational opportunities, the use of existing community parks in the area would be minimized. Nevertheless, residents of the proposed development may utilize off-site community parks and recreational facilities in addition to using the on-site recreation and open space amenities. Despite the project’s provision of approximately 10.5 acres of public open space, the project would fall short of DRP’s various community park standards. However, implementation of the mitigation measure specified below would ensure that through the provision of on-site recreational amenities and open space areas, payment of in-lieu fees, dedication of parkland, or a combination of these methods, the project would comply with the parks and recreational requirements set forth by State law.

(b) City of Los Angeles Municipal Code (LAMC)

As previously discussed, Section 12.21 of the LAMC requires that all buildings containing six or more dwelling units on a lot provide a minimum square footage of usable open space per dwelling unit. As described above, in lieu of these provisions, the open space requirements of the Boyle Heights Mixed-Use Community Specific Plan would be implemented, and open space would be provided based on each of the building types ultimately developed on-site. These Specific Plan requirements would exceed the requirements set forth in Section 12.21 of the LAMC, as shown in Table IV.J-13 on page IV.J-106. Specifically, based on the LAMC requirements, the proposed dwelling unit types, and assumed unit sizes, the project would be required to provide a total of 679,000 square



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Table IV.J-13 LAMC Section 12.21—Open Space Required and Provided by the Project

Open Space Requirementa Quantity Requirement per Unit Total Required

Studios (<3 habitable rooms) 72 DU 100 sf per DU 7,200 sf

1 bedroom DU (3 habitable rooms) 1,712 DU 125 sf per DU 214,000 sf

2 & 3 bedroom DU (>3 habitable rooms) 2,616 DU 175 sf per DU 457,800 sf

Total Requiredb 679,000 sf (15.6 ac)

Open Space Proposed

Total Provided (acres) Landscaped Area

Common Open Spacec 10.48 ac Minimum 8 acres

Semi-Private Open Spaced 10.96 ac (no LAMC requirement)

Private Open Spacee 2.50 ac (no LAMC requirement)

Total Useable Open Space Provided 23.94 ac

Additional Open Space

Streetscape 10.37 ac (no LAMC requirement)

Unfenced Yard Space 7.84 ac (no LAMC requirement)

Additional Open Space Subtotal 18.21 ac

Grand Total Open Space Provided 42.15 ac

a Per LAMC Section 12.03, for the purpose of applying the open space requirements of Section 12.21

G, a kitchen shall not be considered a habitable room. Conservatively assumes that all units except studios have a separate living room and dining room.

b A more conservative assumption that all units would have three or more habitable rooms would yield an LAMC open space requirement of 770,000 square feet or 17.68 acres.

c May include central park, neighborhood parks, neighborhood playgrounds, plazas, etc. d Dictated by building type per the Specific Plan; total amount of semi-private open space will vary

based on the building types ultimately developed. May include recreation rooms (assumes that a 600-square-foot recreation room is provided for every 200 residential units), yards, patios, courtyards, paseos, roof gardens, etc.

e Includes private balconies. Assumes that half of all units on-site have a 50-square-foot balcony.

Source: Fifteen Group Land and Development, Torti Gallas and Partners, 2010.

feet (15.60 acres) of usable open space.101 In comparison, implementation of the Specific Plan would yield approximately 24 acres of usable open space within the project site. Thus, the proposed project would exceed the LAMC open space requirement.

101 A more conservative assumption that all units would have three or more habitable rooms would yield an LAMC open space requirement of 770,000 square feet or 17.68 acres.



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Additionally, per Section 12.21, at least 50 percent of the total required usable open space (i.e., 7.8 acres) must consist of common open space; the project would provide for approximately 10.5 acres, thus exceeding this requirement. Finally, LAMC requires that approximately 25 percent of the common open space (i.e., 3.9 acres) must be planted with ground cover, shrubs, and trees. The Specific Plan requires that a minimum of 25 percent of the open space easements, and 25 percent of the required open space by product type, be planted with ground cover, shrubs, and trees. Thus, the LAMC requirement would be exceeded by the Specific Plan.

The project would also be subject to Section 17.12 of the LAMC, the City’s Quimby Act implementing ordinance. As described above, Section 17.12 requires the dedication of land for park and recreational purposes to the City and/or the payment of in-lieu fees. For the project’s proposed maximum density of 60 to 70 dwelling units per acre, approximately 24.7 percent or approximately 16.5 acres of the gross subdivision area would be required to be dedicated as parkland. Of the approximately 24 acres of open space to be provided by the project, approximately 10.5 acres would consist of publically available, privately maintained, usable open space for which a public use easement would ensure access for the greater general public from dawn until dusk. This provision would not fully meet the parkland dedication requirements; however, pursuant to the provisions of LAMC Section 17.12, the proposed project could instead pay in-lieu fees for any land dedication requirement shortfall and/or provide on-site improvements equivalent in value to said in-lieu fees. Additional new open space and recreational amenities provided as part of the project could be credited against the total parkland dedication requirement or the total in-lieu park fee requirement, as determined by the City. Thus, with the provision of on-site parks and recreational facilities and payment of in-lieu fees as necessary, impacts would be considered fully mitigated and, therefore, less than significant.

(c) Boyle Heights Community Plan

The project would also support the objectives and policies of the Community Plan through the provision of parks, recreational facilities, and open space on-site. Specifically, the project would include approximately 10.5 acres of privately maintained, publicly available, common useable open space. This space would include a civic plaza, an expansive central park, active parks, neighborhood greens, and neighborhood playgrounds. In addition, semi-private open space in the form of recreation rooms, yards, patios courtyards, and rooftop gardens accessible to project residents would comprise an additional 11 acres of open space, and private balconies would constitute another 2.5 acres of open space. As such, impacts with respect to consistency with the Boyle Heights Community Plan would be less than significant.



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4. Cumulative Impacts

Cumulative growth in the greater project area through 2030 includes specific known development projects as well as general ambient growth projected to occur, as described in Section III, Environmental Setting, of this EIR. As the DRP does not project service area information to the year 2030, this cumulative analysis is based on SCAG’s population, housing, and employment growth projections for the greater project vicinity for the year 2030 and those related projects that are not already accounted for therein. A number of the identified related projects and ambient growth projections for the project area fall within the service area of the DRP, which serves the project site and surrounding area. Such growth is estimated to result in an increase of approximately 66,894 residents within the DRP service area. In conjunction with the proposed project, this growth would cumulatively generate the need for additional parks and recreational services.

While the project in conjunction with future development projects would cumulatively generate the need for additional park and recreation facilities, future development projects would be required to comply with the park and recreation requirements of the PRP and LAMC Sections 12.21 and 17.12. Future development would also be subject to discretionary review by the City and required to implement mitigation measures to ensure that significant impacts to park and recreational services would not occur. Therefore, potential cumulative impacts on parks and recreation would be anticipated to be less than significant with incorporation of appropriate mitigation.

5. Project Design Features and Mitigation Measures

a. Project Design Features

Project Design Feature J.4-1: The Applicant shall provide park or recreation space according to the required percentage of semi-private open space set forth in the Specific Plan based on building types. Each building type shall have a minimum open space requirement that is measured as a percentage of the lot area and ranges from 15 percent to 30 percent (e.g., rowhouses would require at least 15 percent of the lot area to be dedicated to open space, podium buildings would require at least 25 percent, podium high-rise buildings would require at least 30 percent, etc. Furthermore, the Specific Plan dictates how the minimum open space requirements can be achieved for each building type, for instance through yards, patios, roof decks, courtyards, etc. Such facilities would be available to the residents of each building/complex within which each facility is located. In addition, Applicant shall provide approximately 10.5 acres of publicly available, privately funded and maintained, usable open space.



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b. Mitigation Measures

The following mitigation measure would ensure that project-related impacts on parks and recreational facilities would be less than significant.

Mitigation Measure J.4-1: Prior to the issuance of building permits for the residential uses, the Applicant shall do one or more of the following: (1) dedicate parkland to meet the requirements of Los Angeles Municipal Code Section 17.12; (2) pay the current in-lieu fees for any land dedication requirement shortfall; (3) provide on-site improvements equivalent in value to said in-lieu fees; and/or (4) comply with any applicable provision in the Development Agreement concerning the provision of parkland and recreational uses and credits for in-lieu fees as a result of the provision of improvements and dedicated open space easements that reflect the value of the land to be dedicated.

6. Level of Significance After Mitigation

Implementation of Mitigation Measure J.4-1 and Project Design Feature J.4-1 would ensure that potential project-related impacts associated with parks and recreational facilities would be less than significant.

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