The LAUSD is regulated by the California Education Code and governed by the State Board of Education. SCH No July 2011

IV. Environmental Impact Analysis L. Public Services 3. s a. Introduction This section analyzes the potential impacts of the Proposed Project relative to public schools that serve the Project Site. Public schools in the are under the jurisdiction of the Los Angeles Unified District ( LAUSD ). This section evaluates whether available public school facilities serving the Project Site are sufficient to accommodate the students projected to be generated by the Proposed Project. Information presented in this section is largely based on information received from the LAUSD (see Appendix IV.L-1 to this Draft EIR). Based on this information, facilities serving the Project Site were identified and a determination was made as to whether these facilities are adequate to meet the future demand associated with occupancy of the Project Site. b. Environmental Setting (1) Regulatory Framework (a) Federal Level Education is mostly regulated at the state and local levels. However, the federal government is involved in providing funding for specialized programs (e.g., school lunches/breakfasts) and these monies are not used for school construction or general educational purposes. (b) State Level (i) California Education Code The LAUSD is regulated by the California Education Code and governed by the State Board of Education. Page IV.L-47 2. WORKING DRAFT - Not for Public Review

(ii) Assembly Bill 2926 Traditionally, the State has passed legislation for the funding of local public schools and provided the majority of monies to fund education in the State. To assist in providing facilities to serve students generated from new development projects, the State passed Assembly Bill 2926 in 1986, allowing school districts to collect impact fees from developers of new residential, commercial, and industrial developments. Development impact fees are also referenced in the 1987 Leroy Greene Lease-Purchase Act, which requires school districts to contribute a matching share of the costs for the construction, modernization, or reconstruction of school facilities. Subsequent legislation has modified the fee structure and general guidelines. (iii) Senate Bill 50, and California Education Code Section 17620 Senate Bill 50 ( SB 50 ), the Leroy F. Greene Facilities Act of 1998, was signed into law on August 27, 1998. It placed a $9.2 billion State bond measure (Proposition 1A), which included grants for modernization of existing schools and construction of new schools, on the ballot at the November 3, 1998 election. Proposition 1A was approved by voters, thereby enabling SB 50 to become fully operative. Under SB 50, a program for funding school facilities largely based on matching funds was created. Its construction grant provides funding on a 50/50 State and local match basis, while its modernization grant provides funding on a 60/40 basis. Districts unable to provide some, or all, of the local match requirement meet financial hardship provisions and are potentially eligible for additional State funding. 34 SB 50 (codified as California Education Code Section 17620), states that the governing board of any school district is authorized to levy a fee, charge, dedication, or other requirement against any construction within the boundaries of the district, for the purpose of funding the construction or reconstruction of school facilities. Section 65995 of the Government Code sets a maximum level of fees a developer may be required to pay to mitigate a project s impacts on school facilities under SB 50 and Section 17620 of the California Education Code. The maximum fees apply to zone changes, general plan amendments, zoning permits, and subdivisions. Under the provisions of Section 65995(h) of the Government code, payment of these fees provides full and complete mitigation of school facilities impacts, notwithstanding any contrary provisions in CEQA or other State or local laws. 34 State of California, Office of Public Construction, Facility Program Handbook, February 2006. Page IV.L-48

(c) Regional Level The LAUSD s operations are largely funded by local property tax revenue that is first accrued in a common statewide pool with similar property tax revenue throughout the State, and then allocated to each school district on the basis of average daily attendance. In addition, State law permits school districts to charge development fees to fund capital acquisition and improvements to school facilities, based on documented justification that residential and non-residential developments generate students. Pursuant to Section 65995.5 7 of the California Government Code, the LAUSD has imposed Level 2 residential developer fees at the current rate of $3.87 per square-foot of new residential construction, $0.47 per square foot of commercial/industrial space, and $0.09 per square-foot of parking structure construction within the boundaries of the LAUSD (effective October 23, 2009 through October 23, 2010). 35 (d) Local Level As stated above, the State is primarily responsible for funding local school districts, and in this case, the LAUSD. As the LAUSD provides education to students in many cities and county areas, in addition to the, its oversight is largely a regional/county level issue. Public schools operate under the policy direction of elected governing district school boards (elected from the local area) as well as by local propositions which directly impact the funding of facility construction and maintenance. (i) West Los Angeles Community Plan The most recent update to the West Los Angeles Community Plan ( Community Plan ) was adopted in July 1999 as one of 35 community plans that comprise the City s General Plan Land Use Element. The West Los Angeles Community Planning Area encompasses approximately 7.06 square miles and primarily contains a broad mix of land uses, including low density, single-family residential land uses with a mix of small and large multi-family residential uses, as well as commercial and industrial land uses. All development within the Community Plan Area is subject to the planning guidelines of the adopted Community Plan. The overarching school goal of the Community Plan with regard to schools is for public schools that provide a quality education for all of the City s children, including those with special needs, and adequate school facilities to 35 Developer fees obtained from LAUSD, Developer Fee Program Office, October 27, 2009. Page IV.L-49

serve every neighborhood in the City. To this end, the Community Plan includes the following specific policies: 1. Encourage compatibility between school locations, site layout and architectural design, and Community character; 2. design should buffer classrooms from noise sources; 3. Expansion of existing school facilities should be considered prior to acquisition of new sites; 4. Explore creative alternatives for providing new school sites in the City, where appropriate; and 5. Encourage the siting of community facilities (libraries, parks, schools and auditoriums) together. There are six elementary schools and one senior high school within the Community Plan Area. 36 For further discussion regarding the applicable goals and policies of the Community Plan, see Section IV.I (Land Use Planning) of this Draft EIR. (2) Existing Conditions (a) Overview of the Los Angeles Unified District As mentioned above, the Project Site is located within the boundaries of the LAUSD, which is the second largest public school district in the nation in terms of enrollment. The LAUSD serves the, as well as all or portions of 32 other cities in the County and numerous unincorporated areas of the County. The LAUSD s boundaries encompass an area of about 710 square miles. Approximately two-thirds (or 66 percent) of the LAUSD s land area, and approximately 87 percent of the population residing in its boundaries, are within the. The LAUSD provides kindergarten through high school (K-12) education, as well as adult and special education programs, to approximately 678,441 students in 1,044 schools, and 208 36 West Los Angeles Community Plan, available at http://cityplanning.lacity.org/, accessed July 28, 2010. Page IV.L-50

other facilities. 37 The LAUSD also employs about 71,851 personnel, a little under half (46.2 percent) of whom are classroom teachers. 38 Of the LAUSD s total K-12 enrollment of 678,441 students, about 43 percent were enrolled in elementary schools (grades K-5 or 6); about 18 percent were enrolled in middle schools (grades 6 or 7-8); about 24 percent were enrolled in high schools (grades 9-12); and the remaining 15 percent were enrolled in magnet schools, primary centers, special education schools, and other special district programs. 39 The enrollment capacities of specific schools serving the Project Site are discussed in detail below. (b) Open Enrollment Policy The open enrollment policy is a State-mandated policy that enables students anywhere in the LAUSD to apply to any regular, grade-appropriate LAUSD school with designated open enrollment seats. The number of open enrollment seats is determined annually. Each individual school is assessed based on the principal s knowledge of new housing and other demographic trends in the attendance area. Open enrollment seats are granted through an application process that is completed before the school year begins. Students living in a particular school s attendance area are not displaced by a student requesting an open enrollment transfer to that school. 40 (c) LAUSD s Serving the Project Site Currently, the LAUSD is divided into eight local districts, each with its own superintendent, in order to provide for more local control and accountability for academic performance. The Project Site is located within LAUSD Local District 3, in an area under the supervision of County Board of Supervisor District 4. Additionally, the Project Site is located in an LAUSD Middle Attendance Option Area, which means that parents may choose to send their children to one of several middle schools serving the Project Site. 37 38 39 40 LAUSD, Fingertip Facts 2009-2010 (Revised), available at: http://notebook.lausd.net/pls/ptl/docs/page/ca_lausd/lausdnet/offices/communications/09-10engfingertip%20factsrev-2.pdf,accessed August 16, 2010. Ibid. Ibid. News Release, Los Angeles Unified District, Office of Communications, April 17, 2000. Page IV.L-51

In its written correspondence, the LAUSD has indicated that the following LAUSD schools, as depicted on Figure IV.L-3 on page IV.L-53, provide educational services to the Project Site. 41 A summary of the current enrollment and capacity of these schools can be found in Table IV.L-5 Current Capacity and Resident Enrollment In LAUSD s Serving the Project Site, on page IV.L-54. Westwood Charter Elementary (#7740). Westwood Charter Elementary ( Westwood Elementary ) provides educational service for kindergarten through fifth grade. Opened in 1924, the school is located at 2050 Selby Avenue, Los Angeles CA 90025. Although part of the LAUSD system, the school has received charter-school status, allowing it greater flexibility in governance and developing curriculum. The school maintains 31 classrooms and has 35 credentialed teachers. Each classroom has one full-time teacher and one part-time teacher s assistant. 42 The Westwood Elementary has a current capacity of 784 students, and a current resident enrollment of 792 students, resulting in a shortage of eight seats at the school. 43 Emerson Middle (#8123). Emerson Middle provides educational services for sixth through eighth grade. Opened in 1935, the school is located at 1650 Selby Avenue, Los Angeles, CA 90025. The current school faculty consists of 3 certified management faculty members, 53 certified teachers and 5 certified faculty members assigned to other responsibilities. 44 The majority (61 percent) of the faculty assigned to Emerson Middle has over six years of experience with the LAUSD. Emerson Middle has a current capacity of 1,607 students, and a current resident enrollment of 712 students, resulting in an excess of 895 seats at the school. 45 Webster Middle (#8481). Webster Middle provides educational services for sixth through eighth grade. Opened in 1954, the school is located at 11330 West Graham Place Los Angeles, CA 90064. The current school faculty 41 42 43 44 45 Written correspondence from Rena Perez, Director, LAUSD Master Planning & Demographics, dated February 20, 2009. Westwood Charter, About Us, Faculty, available at: http://www.westwoodcharter.org/node/20, accessed August 16, 2010. Written correspondence from Rena Perez, Director, LAUSD Master Planning & Demographics, dated February 20, 2009. LAUSD, Profile Page, Emerson Middle, available at: http://search.lausd.k12.ca.us/cgibin/fccgi.exe?w3exec=school.profile.content&which=8123, accessed August 16, 2010. Written correspondence from Rena Perez, Director, LAUSD Master Planning & Demographics, dated February 20, 2009. Page IV.L-52

SAN VICENTE BLV WILSHIRE BLVD ROBERTSON BLVD BEVERWIL DR 18T ERS FF LOS ANGELES COUNTY CREEK W JE 405 WESTWOOD HOLMBY HILLS RANCHO PARK CENTURY CITY 10 LIB 2 BEVERLY BLVD 3RD ST BURTON WY CANON DR BEVERLY DR DOHENY DR BEVERLY DR CADILLAC AVE CATTARAUGUS AVE CASTLE HEIGHTS AVE WASHINGTON BLVD 187 ELEVADO AVE CENTURY PK E AVENUE OF THE STARS PICO BLVD MANNING AVE MOTOR AVE SUNSET BLVD SANTA MONICA BLVD CENTURY PK W HILGARD AVE LITTLE SANTA MONICA BLVD 2 OLYMPIC BLVD WESTWOOD BLVD WEST LOS ANGELES 1 OVERLAND AVE VETERAN AVE SEPULVEDA BLVD NATIONAL BLVD 3 PROJECT SITE Legend 1 Westwood Charter Elementary (#7740). 2050 Selby SOUTH Avenue, Los Angeles ROBERTSON CA 90025. 2 Emerson Middle (#8123). 1650 Selby Avenue, Los Angeles, CA 90025. 3 Webster Middle (#8481). 11330 West Graham Place Los Angeles, CA 90064. 4 University High (#8886). 11800 Texas Avenue, Los Angeles, CA 90025. Figure IV.L-3 Los Angeles Unified District s Serving the Project Site SAWTELLE BLVD GATEWAY BLVD PICO BLVD GAYLEY AVE B ELLAGIO RD SEPULVEDA BLVD BUNDY DR W SUNSET BLVD SAN VICENTE BLVD BARRINGTON AVE MONTANA AVE Page IV.L-53 4 SAWTELLE BUNDY DR OHIO AVE IDAHO AVE 26TH ST 0 0.5 1 Mile Source: Thomas Guide and Matrix Environmental, 2010.

Table IV.L-5 Current Capacity and Resident Enrollment In Los Angeles Unified District s Serving the Project Site s Grades 2008-2009 2008-2009 Resident Enrollment a Capacity (+) Under/ (-) Over Capacity Westwood Elementary K-5 792 784-8 Emerson Middle 6-8 712 1,607 +895 Webster Middle 6-8 931 1,621 +690 University High 9-12 699 2,217 +1,518 a Eligible resident enrollment (i.e., residing in the attendance boundary), not actual enrollment. Source: Written correspondence from Rena Perez, Director, LAUSD Master Planning & Demographics, dated February 20, 2009. consists of 4 certified management faculty members, 53 certified teachers and 5 certified faculty members assigned to other responsibilities. 46 Over a third (47 percent) of the faculty assigned to Webster Middle has over six years of experience with the LAUSD. 47 Webster Middle has a current capacity of 1,621 students, and a current resident enrollment of 931 students, resulting in an excess of 690 seats at the school. 48 University Senior High (#8886). University Senior High provides educational services for ninth through twelfth grade. Opened in 1922, the school is located at 11800 Texas Avenue, Los Angeles, CA 90025. The current school faculty consists of 5 certified management faculty members, 103 certified 46 47 48 LAUSD, Profile Page, Webster Middle Profile, available at: http://search.lausd.k12.ca.us/cgi-bin/fccgi.exe?w3exec=school.profile.content&which=8481, accessed August 16, 2010. Ibid. Written correspondence from Rena Perez, Director, LAUSD Master Planning & Demographics, dated February 20, 2009. Page IV.L-54

teachers and 8 certified faculty members assigned to other tasks. 49 A little over half (58 percent) of the faculty assigned to University Senior High have over six years of experience with the LAUSD. 50 University high has a current capacity of 2,271 students, and a current resident enrollment of 699 students, resulting in an excess of 1,518 seats at the school. 51 Based on LAUSD forecasts, all four LAUSD schools serving the Project Site would experience an increase in student enrollment by the 2013-2014 school year. Table IV.L-6, Estimated Future Capacities and Resident Enrollment in Los Angeles Unified District s Serving the Project Site, on page IV.L-56 details the projected school enrollments and capacities for the 2013-2014 school year, based on written correspondence from the LAUSD. While Project buildout would occur during the 2014-2015 school year, future school capacity determinations are based on LAUSD s five-year projections as this constitutes the best available information (i.e., the LAUSD does not forecast beyond a five-year time frame). Thus, the 2013-2014 school year forecast is used for analyzing impacts at Project buildout as it represents the LAUSD s forecast closest to the Project s buildout year. The LAUSD is undergoing a multi-year capital improvement program to relieve school overcrowding throughout the LAUSD. Details regarding new school construction are outlined in the 2010 LAUSD New Construction Strategic Execution Plan. The Project Site is located within the Central Project Development Region. In its correspondence, the LAUSD has indicated that it does not have any new schools planned to relieve any overcrowding at schools serving the Project Site. (d) Beverly Hills Unified District Additionally, the Project Site is in the vicinity of the Beverly Hills Unified District ( BHUSD ). While the BHUSD accepts students from outside the district through its permit program, potential non-district students are approved on a case-by-case basis and according to specific criteria. Further, telephone communication with the BHUSD Permit Office in June 2009 confirmed that this permit program is being significantly downsized 49 50 51 LAUSD, Profile Page, University High Profile, available at: http://search.lausd.k12.ca.us/cgi-bin/fccgi.exe?w3exec=school.profile.content&which=8886, accessed August 16, 2010. Ibid. Written correspondence from Rena Perez, Director, LAUSD Master Planning & Demographics, dated February 20, 2009. Page IV.L-55

Table IV.L-6 Estimated Future Capacities and Resident Enrollment in Los Angeles Unified District s Serving the Project Site s 2013-2014 Enrollment 2013-2014 Capacity a (+) Under/(-)Over Capacity Westwood Elementary (Grades 1-5) 875 726-149 Emerson Middle (Grades 6-8) 641 1,449 +808 Webster Middle (Grades 6-8) 682 1,278 +596 University Senior High (Grades 9-12) 822 2,039 +1,217 a The capacity the school will have after shifting to a 2-semester (1-TRK) calendar and implementing operational goals such as full-day kindergarten and class-size reduction Source: Written correspondence from Rena Perez, Director, LAUSD Master Planning & Demographics, dated February 20, 2009. over the coming academic school years (i.e., approximately 0.4 percent of the next academic year s student body will consist of new permitted non-district students). Therefore, the restrictive nature of this program, in addition to the BHUSD actively reducing the number of non-district students admitted, would severely limit the number of potential non-resident students eligible to attend schools within the BHUSD. As such, Proposed Project-related impacts are conservatively analyzed in terms of the LAUSD schools serving the Project Site, as it is anticipated that by buildout of the Proposed Project (2015) it would be unlikely that any Proposed Project-generated students would be eligible to attend BHUSD. (e) Charter s As mentioned above, Westwood Elementary operates as a charter school under the jurisdiction of the LAUSD. As the school is under the jurisdiction of the LAUSD, it is mandated by the State under the Open Enrollment Policy to accept students living within the school s district. Thus, it has been included in the discussion of potential impacts to LAUSD schools. For a more detailed discussion of Westwood Elementary, please refer to the discussion of LAUSD schools above. No other charter schools are located within the vicinity of the Project Site. Page IV.L-56

(f) Magnet s There are no magnet schools located within the vicinity of the Project site. (g) Private s In addition to publicly available schools, there are also a number of private schools in the vicinity of the Project area that could potentially serve as alternatives to LAUSD schools, should residents of the Proposed Project elect this option. Particularly, there are twelve (12) private schools, ranging from kindergarten through twelfth grades, in the vicinity of the Project Site. Private schools operate under their enrollment criteria, and are not required to accept students beyond their facility s capacity (as public schools are required to do under the State s Open Enrollment Policy). Regarding private schools in the Project vicinity, it is important to note that since the anticipated selling prices for the on-site residential units would require higher income residents, to the extent that school age children are present, there is the distinct possibility that these students would attend private schools rather than the public schools that serve the Project area. To provide a conservative analysis of the Proposed Project s potential impacts, it is assumed that all students generated by the Proposed Project would attend the LAUSD public schools serving the Project Site. However, to provide a more complete depiction of the education setting in the vicinity of the Project Site, a brief description of the following are the private schools in the vicinity of the Project Site is included below. Creative Center for Children, located at 10547 Santa Monica Boulevard, Los Angeles; Montessori Discovery Garden, located at 10551 Holman Avenue, Los Angeles; Westwood Presbyterian, located at 10822 Wilshire Boulevard, Los Angeles; Westwood United Methodists Pre-, located at 10822 Wilshire Boulevard, Los Angeles; Good Shepherd Catholic, located at 148 S. Linden Drive, Beverly Hills; Castle Height Elementary, located at 9755 Cattaraugus Avenue, Los Angeles; Redeemer Baptist, located at 1072 National Boulevard, Los Angeles; Notre Dame Academy Elementary located at 2911 Overland Avenue, Los Angeles; Page IV.L-57

St. Timothy s, located at 10479 Pico Boulevard Los Angeles; Le Lycee Francais De Los Angeles (Century City Campus), located at 10361 Pico Boulevard; Le Lycee Francais De Los Angeles (Campus 55), located at 3055 Overland Avenue; Le Lycee Francais De Los Angeles (Raymond and Esther High Campus), located at 10309 National Boulevard; St. Paul Apostle, located at 1536 Selby Avenue; and Page Private, located at 419 Robertson Boulevard, Beverly Hills. c. Environmental Impacts (1) Methodology Utilizing information supplied by the LAUSD, the existing conditions of the public schools serving the Project Site were assessed. Student generation as a result of the Proposed Project was then forecasted based on the Project s characteristics and LAUSD student generation factors. This methodology assumed that the numbers of new students generated by the Proposed Project are directly related to the type and amount of proposed residential and commercial construction. LAUSD s residential student generation rates vary by whether the residential unit is a for-sale dwelling unit (owner-occupied) or an apartment (renter-occupied). This analysis assumes all residential units under the Proposed Project would be owner-occupied. Further, as mentioned above, this analysis assumes that all students generated by the Proposed Project would be new students to the area and would attend the LAUSD public schools serving the Project Site. (2) Thresholds of Significance (a) CEQA Thresholds Guide The LA CEQA Thresholds Guide (2006) states that the determination of the significance of impacts related to schools shall be made on a case-by-case basis, considering the following factors: The population increase resulting from the project, based on the increase in residential units or square footage of non-residential floor area; Page IV.L-58

The demand for school services anticipated at the time of project buildout compared to the expected level of service available, and to consider as applicable, scheduled improvements to LAUSD services (facilities, equipment and personnel) and the project s proportional contribution to the demand; Whether (and the degree to which) accommodation of the increased demand would require construction of new facilities, a major reorganization of students or classrooms, major revisions to the school calendar (such as year-round sessions), or other actions which would create a temporary or permanent impact on the school(s); and Whether the project includes features that would reduce the demand for school services (e.g., on-site school facilities or direct support to LAUSD). Each of these factors is applicable to the Proposed Project and as such is used to determine if the Proposed Project would have significant impacts with regard to the provision of school services. (3) Project Impacts The Proposed Project would either remove the Existing Hotel and construct two 49- story mixed-use buildings (Option A) or rehabilitate the Existing Hotel ( Rehabilitated Building ) and construct two 46-story mixed-use buildings west of the Rehabilitated Building (Option B). (a) Construction Impacts Option A and Option B The Proposed Project under both Option A and Option B is anticipated to generate temporary construction-related jobs between the start of construction and Project buildout in 2015. Project construction is not anticipated to result in adverse impacts to LAUSD school facilities and overall capacity levels due to the temporary nature of construction related activities. As construction workers are not anticipated to change their place of residence as a result of working at the Project Site, there would be no increase in student enrollment at the local schools serving the Project Site. Therefore, construction-related impacts associated with public schools under both Option A and Option B would be less than significant. Additionally, on-site construction activities, as well as construction traffic (e.g., worker travel, hauling activities, and the delivery of construction materials), would not affect existing school traffic, pedestrian routes, or transportation safety in the Project vicinity as there are no schools adjacent to the Project Site. The closest school to the Project Site is Beverly Hills High, located approximately ¼-mile northeast of the Project Site. Construction staging and construction-related vehicle parking would occur on-site, and Page IV.L-59

thus, not on or near school property. Further, the Project Applicant would implement a Construction Staging and Traffic Management Plan ( CSTMP ), as discussed in Section IV.M (Transportation/Traffic) of this Draft EIR, which would approved by the Los Angeles Department of Transportation and other appropriate agencies to maintain pedestrian and vehicular safety, and to avoid substantial inconvenience to pedestrians. The CSTMP would include design features that include scheduling construction deliveries during offpeak hours to the extent feasible and properly redirecting pedestrians in the event of a sidewalk closure. With implementation of the CSTMP, which is a standard City requirement that is part of the building permitting and reviewing process, impacts associated with Project construction on school pedestrian routes would be less than significant under both Option A and Option B. (b) Operational Impacts Option A and Option B The Proposed Project under Option A would remove the Existing Hotel and construct 293 condominium units, 240 hotel rooms, 114,000 square feet of office space, and 106,000 square feet of retail space (all net new construction). Option B contains two development scenarios, the Option B With Office Scenario and the Option B Without Office Scenario. As the student generation rate for residential land uses is notably higher than the student generation rate for office land uses, the Option B Without Office Scenario would generate more students than the Option B With Office Scenario. Therefore, for a conservative analysis, the Option B Without Office Scenario is analyzed to determine the conservative scenario for Option B s student generation. The Project under Option B Without Office would construct 353 condominium units, 394 hotel rooms (resulting in a net reduction in the number of hotel rooms on-site due to the conversion of some hotel rooms in the Rehabilitated Building to condominiums), and 93,840 square feet of retail space. No office space would be developed under the Option B Without Office Scenario. Table IV.L-7, Estimated Student Generation from Option A and Option B, on page IV.L-61 estimates the approximate number of students that would be generated as a result of the Proposed Project under both Option A and Option B. As stated therein, Option A would result in net increase of 42 elementary school students, 22 middle school students, and 22 high school students for a total of 86 students. The Option B Without Office Scenario would result in a net increase of 48 elementary school students, 25 middle school students, and 25 high school students for a total of 98 students. It should be noted that new employees associated with the hotel uses (including the various guest amenities) and the ground-level retail, restaurant, and cafe spaces under both Option A and Option B would generally include hotel and retail managers, desk clerks, bellhops, valets, housekeeping and janitorial staff, administrative staff, maintenance staff, restaurant staff, and retail sales clerks and cashiers. These positions, many of which are part-time, Page IV.L-60

Table IV.L-7 Estimated Student Generation from Option A and Option B Land Use Type Net Change in Size Option Option A B Elementary Students Generated a Option A Option B Middle Students Generated b Option A Option B High Students Generated c Option A Option B Total Students Generated Option Option A B Residential Condominiums Office Hotel Retail 293 DU 353 DU 41 49 22 26 22 26 85 101 114,00 0 sf 0 sf 4 0 2 0 2 0 8 0 (419,8 (250,32 84) sf 4) sf (5) (3) (3) (2) (3) (2) (11) (7) 106,00 93,840 0 sf sf 2 2 1 1 1 1 4 4 Net Total 42 48 22 25 22 25 86 98 a b c Elementary Generation Rates: Residential 0.1400/unit, Office 0.0366/1,000 sf, Hotel 0.0118/1,000 sf, Retail 0.0234/1,000 sf. Middle Generation Rates: Residential 0.0739/unit, Office 0.0193/1,000 sf, Hotel 0.0063/1,000 sf, Retail 0.0123/1,000 sf. High Generation Rates: Residential 0.0737/unit, Office 0.0192/1,000 sf, Hotel 0.0062/1,000 sf, Retail 0.0123/1,000 sf. Source: LAUSD, Commercial/Industrial Development Fee Justification Study, February 25, 2008, Tables 9 and10, pages 17 and 18. are typically filled by persons already residing in the vicinity of the workplace who generally do not relocate their households due to such employment opportunities. Nonetheless, in order to provide a conservative analysis, these uses are included in the estimate of the Proposed Project s student population provided in Table IV.L-6 on page IV.L-56. Although complete buildout of the Proposed Project would occur in 2015 (i.e., during the 2014-2015 school year), the future enrollments at the schools serving the project site are provided based upon the most recent LAUSD school projections (i.e., the 2013-2014 school year). As noted above, the LAUSD does not currently have any plans to construct additional schools or make improvements to existing schools that would increase student capacity at schools that serve the Project Site. While it is likely that some of the students generated by the Proposed Project would already reside in areas served by LAUSD and would already be enrolled in LAUSD schools, or would attend private schools, for a conservative analysis, it is assumed that all additional (new) students generated by the Proposed Project under both Option A and Option B would be new to LAUSD. The Project Site is located approximately equidistant from both Emerson and Webster Middle s. Since the Project Site is located within a LAUSD Middle Attendance Option Area, it is possible that all middle school students at the Project Site Page IV.L-61

could attend either Emerson Middle or Webster Middle. For a conservative analysis, the middle school students generated by the Proposed Project were counted towards the attendance numbers at both Emerson and Webster Middle s. As shown in Table IV.L-8, Option A and Option B Impacts on Los Angeles Unified District s, on page IV.L-64, with the exception of Westwood Elementary, all of the public schools serving the Project Site would have adequate capacity to accommodate the students generated by Option A and Option B. However, in the school year 2013-2014, Westwood Elementary would be over capacity by 191 students under Option A and 197 students under Option B. Thus, the Proposed Project would have a potentially significant impact to Westwood Elementary under both Option A and Option B. It should also be noted that while the Applicant intends to complete construction of the Proposed Project by 2015, it is at least possible that the Proposed Project might not be completed until as late as 2027. As noted in Section II (Project Description) of this Draft EIR, the Applicant requests approval of a Development Agreement ( DA ) which would confer on the Applicant a vested right to develop the Proposed Project throughout the term of the agreement. It is expected that the DA would be approved in 2012 and the terms of the agreement would be for a period of 15 years, thereby expiring in 2027. In the unlikely event that the Project buildout year was to be extended by 12 years to coincide with the anticipated expiration of the term of the DA in 2027, the conclusions regarding the Proposed Project s impacts to schools would not change. While it is not possible to say with certainty whether the Proposed Project would exceed available school seating capacity in 2027 since future school capacity projections are only available for the next five years, the LAUSD has experienced a consistent classroom capacity shortfall, and depending on future enrollment trends, this shortfall may continue. It should be noted that the 2010 LAUSD New Construction Strategic Execution Plan outlines the addition of approximately 167,000 new seats by the end of the year 2015, and the vast majority of these expansions will occur in areas currently experiencing overcrowding. 52 However, as discussed above, in its correspondence, the LAUSD has indicated that it does not have any new schools planned to relieve any overcrowding at schools serving the Project Site. Therefore, the conclusions regarding school impacts presented in this section for Option A, the Option B With Office Scenario, and the Option B Without Office Scenario would not change if the Project buildout year was to be extended to 2027. Specifically, impacts would be potentially significant and mitigation would be required. 52 Los Angeles Unified District, Strategic Execution Plan, January 2010 at: http://www.laschools.org/sepdocs/?tab=nc, accessed May 17, 2011. Page IV.L-62

d. Cumulative Impacts Option A and Option B IV.L Public Services A cumulative increase in the demand for school services is anticipated to occur with the development of future residential and non-residential projects, the Proposed Project itself under Option A or Option B, and more specifically, the future household growth within the school boundaries currently servicing the Project Site. There are a total of 155 related projects. Due to the various locations of the related projects and the local district boundaries determined by LAUSD, only 62 of the related projects would be located in the same boundaries as the schools serving the project site. 53 As shown in Table IV.L-8, these 62 related projects would generate approximately 535 elementary school students, 278 middle school students, and 277 high school students, for a total of 1,090 students. Similar to the Proposed Project under Option A or Option B, it is likely that some of the students generated by the related projects would already reside in areas served by the LAUSD and would already be enrolled in LAUSD schools, or would attend private schools in the Project vicinity. However, for a conservative analysis, it is assumed that all the students generated by the related projects would be new to the LAUSD. As discussed above, the Option A Scenario would generate a net increase of 42 elementary school students, 22 middle school students, and 22 high school students for a total of 86 students. When added to the students generated by the related projects (see Table IV.L-9, Estimated Related Project Student Generation, on page IV.L-64), the cumulative student generation under Option A would include 577 elementary school students, 300 middle school students, and 299 high school students, for a total of 1,176 students. The Option B Without Office Scenario would result in a net increase of 48 elementary school students, 25 middle school students, and 25 high school students for a total of 98 students. When added to the students generated by the related projects, the cumulative student generation under Option B would include 583 elementary school students, 303 middle school students, and 302 high school students, for a total of 1,188 students. As with the Project analysis above, cumulative middle school students were counted towards attendance at both Emerson and Webster Middle s. Similarly, although complete build-out of the Proposed Project would occur in 2015 (i.e., during the 2014-2015 school year), the future enrollments at the schools serving the project site are provided based upon the most recent (i.e., the 2013-2014 school year) LAUSD school projections. 53 Los Angeles Unified District, Finder, website: http://search.lausd.k12.ca.us/cgibin/fccgi.exe?w3exec=schfinder0, accessed August 16, 2010. Page IV.L-63

Table IV.L-8 Option A and Option B Impacts on Los Angeles Unified District s s 2013-2014 (+) Under/(-) Over Capacity a Project Net Students Generated (Option A) Project Net Students Generated (Option B) Resulting (+) Under/ (-) Over Capacity (Option A) Resulting (+) Under/ (-) Over Capacity (Option B) Westwood Elementary -149 42 48-191 -197 Emerson Middle +808 22 25 +786 +783 Webster Middle +596 22 25 +574 +571 University Senior +1,217 22 25 +1,195 +1,192 a Written correspondence from Rena Perez, Director, LAUSD Master Planning & Demographics, dated February 20, 2009. As shown in Table IV.L-10, Cumulative Impacts to LAUSD s, on page IV.L- 68, with the exception of Westwood Elementary, all public schools that would serve the proposed project and the related projects would have adequate capacity to accommodate the cumulative student generation. Westwood Elementary would already exceed its capacity in 2013-2014 school year and would further exceed its capacity with the cumulative student generation. Because the elementary school that would serve the Proposed Project and the related projects would not have adequate capacity to accommodate the cumulative student generation, new or expanded elementary schools may be needed, which could result in a potentially significant cumulative impact. However, Option A would generate only 42 (or 7.3 percent) of the 577 cumulative elementary school students who would attend Westwood Elementary. Similarly, Option B would generate only 48 (or 8.2 percent) of the 583 cumulative elementary school students who would attend Westwood Elementary. With respect to the middle schools and high school that would serve the Proposed Project and related projects, Emerson Middle, Webster Middle, and University Senior High would all have adequate capacity to accommodate the cumulative middle and high school students. Therefore, no new or expanded middle or high schools would be needed. Although the cumulative student generation of either Option A or Option B would exceed the capacity of the Westwood Elementary, as mandated by State law, the Leroy F. Greene Facilities Act of 1998, more commonly referred to as SB 50, sets a maximum level of fees a developer may be required to pay to mitigate a project s impact on Page IV.L-64

Table IV.L-9 Estimated Related Project Student Generation No. Land Use Size Westwood Elementary Students a Emerson Middle Students a Webster Middle Students a High Students a LA 13 Condominiums 4 du 1 -- -- -- LA 14 Condominiums 5 du 1 -- -- -- LA 15 Condominiums 5 du 1 -- -- -- LA 16 Shopping Center 11,085 sf -- -- -- -- Apartments (to be (36 du) (5) (3) (3) (3) removed) LA 17 Assisted Living 183 bed -- -- -- -- Skilled Nursing 22 du -- -- -- -- LA 18 Retail 7,872 sf -- -- -- -- Office 16,200 sf 1 -- -- -- LA 20 Private 425 students -- -- -- -- Specialty Retail 9,165 sf -- -- -- -- Condominiums 31 du 4 2 2 2 LA 21 Bedford Condominiums (Net Increase) 5 du (1) -- -- -- LA 22 Condominiums 15 du 2 1 1 1 LA 23 Apartments 39 du 5 3 3 3 Retail 11,327 sf -- -- -- -- LA 24 Condominiums 49 du 7 4 4 4 Office 41,000 sf 2 1 1 1 Specialty Retail 8,000 sf -- -- -- -- LA 25 Office 146,708 sf 5 3 3 3 LA 26 Army Reserve Medical Offices 1,500,000 sf 55 29 29 29 LA 27 Convenience Market 2,750 sf -- -- -- -- LA 28 Retail 15,000 sf -- -- -- -- Restaurant 2,993 sf -- -- -- -- Medical Office 74,000 sf 3 1 1 1 Theater 1,135 seats -- -- -- -- LA 30 Shopping Center 61,000 sf 1 1 1 1 Supermarket 54,000 sf 1 1 1 1 Apartments 350 du 49 26 26 26 Movie Theater (to be removed) (652 seats) -- -- -- -- Specialty Retail (to be removed) (24,000 sf) (1) -- -- -- Apartments (to be removed) (42 du) (6) (3) (3) (3) LA 31 Office 34,641 sf 1 1 1 1 LA 32 Hotel b 134 rooms 1 -- -- -- Condominiums 10 du 1 1 1 1 Retail 7,520 sf -- -- -- -- LA 33 Health/Fitness Center 36,052 sf 1 -- -- -- Page IV.L-65 4. WORKING DRAFT - Not for Public Review

Table IV.L-9 (Continued) Estimated Related Project Student Generation No. Land Use Size Westwood Elementary Students a Emerson Middle Students a Webster Middle Students a High Students a Office (to be removed) (36,052 sf) (1) (1) (1) (1) LA 34 Apartments 19 du 3 1 1 1 Retail 6,100 sf -- -- -- -- Retail (to be removed) (16,100 sf) -- -- -- -- LA 35 Hotel b 42 room -- -- -- -- LA 36 Condominiums 60 du 8 4 4 4 Apartments (to be removed) (34 du) (5) (3) (3) (3) LA 37 Condominiums 119 du 17 9 9 9 Hotel (to be removed) b (66 rooms) -- -- -- -- LA 38 Condominiums 64 du 9 5 5 5 LA 40 Apartments 19 du 3 1 1 1 LA 41 Condominiums 35 du 5 3 3 3 LA 42 Market 3,750 sf -- -- -- -- LA 43 Condominiums 18 du 3 1 1 1 Single Family Home (to be removed) (1 du) -- -- -- -- LA 44 Apartments 61 du 9 5 5 4 LA 45 Apartments 15 du 2 1 1 1 LA 46 Apartments 36 du 5 3 3 3 Retail 8,485 sf -- -- -- -- LA 47 Apartments 111 du 16 8 8 8 Retail 7,000 sf -- -- -- -- LA 48 Restaurant 2,070 sf -- -- -- -- LA 49 Apartments (net) 6 du 1 -- -- -- LA 50 Condominiums 22 du 3 2 2 2 LA 51 Office 25,000 sf 1 -- -- -- LA 52 Condominiums 16 du 2 1 1 1 LA 53 Shopping Center 358,881 sf 8 4 4 4 Condominiums 262 du 37 19 19 19 Office (to be removed) (289,460 sf) (11) (6) (6) (6) LA 54 Condominiums 483 du 68 36 36 36 Bank (to be removed) (9,150 sf) -- -- -- -- Office (to be removed) (6,700 sf) -- -- -- -- Restaurant (to be removed) (19,754 sf) -- -- -- -- LA 55 Condominiums 177 du 25 13 13 13 Retail 1,000 sf -- -- -- -- Private Club 20,000 sf -- -- -- -- LA 56 Discount Store (net) 49,600 sf 1 1 1 1 LA 57 Retail 28,000 sf -- -- -- -- Restaurant (to be removed) (2,000 sf) -- -- -- -- Page IV.L-66 3. WORKING DRAFT - Not for Public Review

Table IV.L-9 (Continued) Estimated Related Project Student Generation No. Land Use Size Westwood Elementary Students a Emerson Middle Students a Webster Middle Students a High Students a Auto Center (6,500 sf) -- -- -- -- LA 58 Live/Work 84 du 12 6 6 6 LA 59 Office 17,619 sf 1 -- -- -- LA 60 Condominiums 16 du 2 1 1 1 LA 61 Condominiums (net) 46 du 6 3 3 3 LA 62 Condominiums 147 du 21 11 11 11 Restaurant 7,000 sf -- -- -- -- Private Club 43,000 sf 1 -- -- -- Hotel (to be removed) b (297 rooms) (2) (1) (1) (1) LA 70 Condominiums 70 du 10 5 5 5 LA 71 Retail 28,000 sf 1 -- -- -- Condominiums 138 du 19 10 10 10 LA 72 Apartments 63 du 9 5 5 5 LA 73 Apartments 10 du 1 1 1 1 Retail 14,000 sf -- -- -- -- LA 74 Condominiums 94 du 13 7 7 7 LA 75 Condominiums 55 du 8 4 4 4 LA 76 Office 12,000 sf -- -- -- -- Apartments 30 du 4 2 2 2 LA 77 Apartments 48 du 7 4 4 4 Office 1,500 sf -- -- -- -- LA 78 Apartments (net) 7 du 1 1 1 1 LA 79 Apartments 45 du 6 3 3 3 Retail 7,950 sf 0 0 0 0 LA 82 Apartments 538 du 75 40 40 40 Retail (net) 89,956 sf 2 1 1 1 LA 84 Senior Housing 46 du -- -- -- -- Office 4,500 sf -- -- -- -- LA 86 Car Care Center 5,000 sf -- -- -- -- LA 87 Office 9,400 sf -- -- -- -- LA 88 Fast-Food Restaurant 1,000 sf -- -- -- -- Total Students Generated 535 278 278 277 Notes: Students generated under each project were rounded to the nearest whole number. a Generation Rates provided by Los Angeles Unified District, Commercial/Industrial Development Fee Justification Study, September 2002 and Los Angeles Unified District, Student Generation Rate Calculation, August 2006. b Assumes 500 sf per hotel room. Source: Crain & Associates, 2010 (related projects table) and Matrix Environmental, 2010 (calculations). Page IV.L-67 3. WORKING DRAFT - Not for Public Review

Table IV.L-10 Cumulative Impacts to LAUSD s Westwood Elementary Emerson Middle Webster Middle University Senior High 2013-2014 Projected (+) Under/(-) Over Capacity a Cumulative Students Resulting (-) Under/(+) Over Capacity Option A Option B Option A Option B -149 577 583-726 -732 +808 300 303 +508 +505 +596 300 303 +296 +293 +1,217 299 302 +918 +915 a Written correspondence from Rena Perez, Director, LAUSD Master Planning & Demographics, dated February 20, 2009. school facilities. As such, all future projects, in addition to the Project, would be required to pay school fees to the LAUSD to help reduce cumulative impacts that they may have on school services. Compliance with the provisions of SB 50 is deemed to provide full and complete mitigation of school facilities impacts. As discussed above, the potential exists for the Project buildout year to be extended by 12 years to coincide with the anticipated expiration of the term of the DA in 2027. In the unlikely event that this was to happen, the conclusions regarding cumulative impacts to schools would not change. While it is not possible to say with certainty whether the Proposed Project, the related projects, and additional future development through 2027 would exceed available school seating capacity in 2027 since future school capacity projections are only available for the next five years, the LAUSD has experienced a consistent classroom capacity shortfall, and depending on future enrollment trends, this shortfall may continue. It should be noted that the 2010 LAUSD New Construction Strategic Execution Plan outlines the addition of approximately 167,000 new seats by the end of the year 2015, and the vast majority of these expansions will occur in areas currently experiencing overcrowding. 49 However, in its correspondence, the LAUSD has 49 Los Angeles Unified District, Strategic Execution Plan, January 2010 at: http://www.laschools.org/sepdocs/?tab=nc, accessed May 17, 2011. Page IV.L-68 5. WORKING DRAFT - Not for Public Review

indicated that it does not have any new schools planned to relieve any overcrowding at schools serving the Project Site. Nonetheless, all future development projects through 2027 would be subject to be required to pay school fees to the LAUSD to help reduce cumulative impacts that they may have on school services and ensure that no significant impacts to school services would occur. Compliance with the provisions of SB 50, which is discussed above, is deemed to provide full and complete mitigation of school facilities impacts. Therefore, the conclusions regarding cumulative school impacts presented in this section for Option A, the Option B With Office Scenario, and the Option B Without Office Scenario would not change if the Project buildout year was to be extended to 2027. Therefore, with the full payment of all applicable school fees, the Project coupled with expected growth would reduce potential cumulative impacts to schools to less than significant levels under both Option A and Option B. e. Mitigation Measures Under the provisions of SB 50, a project s impacts on school facilities are fully mitigated via the payment of the requisite new school construction fees established pursuant to Government Code Section 65995. Accordingly, the following Mitigation Measure is required for both Option A and Option B to mitigate potentially significant impacts to LAUSD schools: L-4 The Project Applicant shall pay all applicable school fees mandated by SB 50 to the LAUSD to offset the impact of additional student enrollment at schools serving the Project area. f. Level of Significance After Mitigation While the Proposed Project under Option A or Option B would slightly increase the enrollment of Westwood Elementary, which is expected to already be operating over capacity by the 2013-2014 school year, Option A s 42 elementary students and Option B's 48 elementary students would not be expected to generate the specific need for a new or expanded school. Mandatory payment of school fees in conformance with SB 50 would address the Project s impact on schools. Furthermore, in accordance with SB 50, payment of school fees is deemed to provide full and complete mitigation to impacts on schools pursuant CEQA. Thus, after the incorporation of the above stated mandatory payment, included as Mitigation Measure L-4, Project impacts relative to schools will be reduced to a less than significant level under both Option A and Option B. Regarding cumulative impacts, similar to the Proposed Project under Option A or Option B, the applicants of the related commercial and residential projects would pay the Page IV.L-69 5. WORKING DRAFT - Not for Public Review