Clarendon Street Apartments Development Project
Section 4.6 Utilities and Service Systems
4.6 UTILITIES AND SERVICE SYSTEMS
This section evaluates the Proposed Project’s potential impacts to utilities and service systems,
specifically as related to water supply availability. As discussed in the Revised Initial Study for
the Proposed Project, potential impacts associated with the following areas of utilities and
service systems would not result in significant impacts: wastewater collection and treatment,
solid waste, and stormwater conveyance facilities. Therefore, these issues are not addressed
further in this Draft Environmental Impact Report (DEIR). The Revised Initial Study also
concluded that the Proposed Project would not result in significant impacts associated with
water supply; however, due to ongoing multiple-year drought conditions in the Project area,
the issue of water supply is addressed in this DEIR.
The Proposed Project would require approximately 54,672 gallons of water per day, or 61.2
acre-feet per year (AFY). Present water use on the Project site is approximately 7,373 gallons per
day, or 8.3 AFY. As such, the Project would increase on-site water use by approximately
47,299.4 gallons per day, or 52.9 AFY. These water use rates are based on City of Los Angeles
CEQA Thresholds Guidelines 2006 (Exhibit M.2-12, Sewage Generation Factors), which
provides estimates of wastewater generation based on land use. Water supply requirements are
then calculated as 120 percent of wastewater generation.
4.6.1
Setting
a. Water Supply. The Project site is located in the Woodland Hills community of the
City of Los Angeles, which receives its water supply via the Los Angeles Department of Water
and Power (LADWP). Information on water supply to this area is provided in the LADWP’s
current Urban Water Management Plan (UWMP), dated 2010 (LADWP 2010). As discussed
below under “Regulatory Setting”, per the California Urban Water Management Planning Act,
UWMPs should be updated every five years; as stated on LADWP’s website, the 2015 UWMP
will build upon progress achieved from the 2010 UWMP, which will continue to serve as the
City of Los Angeles’ master plan for water supply management until the updated plan is
available. Water supply provided by the LADWP comprises the following sources:
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Los Angeles Aqueducts (LAA)
Local groundwater
Metropolitan Water District (MWD)
Recycled water (LADWP, 2010)
Los Angeles Aqueduct. Water delivered via the LAA makes up approximately 37
percent of LADWP’s total supply. This water is delivered from the Eastern Sierra watershed
using an entirely gravity-fed system, and is therefore considered to have an energy intensity of
zero. The supply available via the LAA varies depending on climate, as well as environmental
enhancement efforts such as those ongoing in the Owens Valley and Mono Basin. If less water is
available via the LAA, the LADWP typically increases the amount of water purchased from
MWD in order to meet total annual demand in the service area. (LADWP 2010)
Local Groundwater. Locally produced groundwater comprises approximately 12
percent of LADWP’s total supply. The City owns water rights in multiple local groundwater
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Section 4.6 Utilities and Service Systems
basins, including the San Fernando, Sylmar, Eagle Rock, Central, and West Coast Basins. At this
time LADWP does not exercise its pumping rights in the Eagle Rock or West Coast Basins. All
of these groundwater basins are adjudicated by decree through Superior Court Judgments,
limiting groundwater pumping to safe yield amounts. This ensures that the basins aren’t
affected by future overdraft conditions, or recover from previous overdraft. (LADWP 2010)
Metropolitan Water District. The City of Los Angeles is an MWD member agency, and
purchases water from the MWD to supplement supplies from local groundwater, LAA
deliveries, and recycled water (described below). The quantity of MWD water purchased by
LADWP can vary on an annual basis depending on other available supplies; MWD water
currently comprises approximately 52 percent of LADWP’s total supply. MWD is the largest
water wholesaler for domestic and municipal uses in California. Operating solely as a
wholesaler, MWD owns and operates the Colorado River Aqueduct (CRA), is a contractor for
water from the California State Water Project (SWP), manages and owns in-basin surface
storage facilities, stores groundwater within the basin via contracts, engages in groundwater
storage outside the basin, and conducts water transfers to provide additional supplies for its
member agencies. LADWP’s 2010 Urban Water Management Plan (UWMP) projects how
reliance on MWD water will be reduced by half by 2035 through conservation and development
of other water supplies. (LADWP, 2010)
Recycled Water. Recycled water currently comprises approximately one percent of
LADWP’s total supply. Currently, LADWP receives recycled water from three wastewater
treatment plants operated by the Bureau of Sanitation (BOS): Los Angeles Glendale (LAG)
Treatment Plant, Donald C. Tillman (DCT) Treatment Plant, and the Terminal Island Treatment
Plant (TITP). LADWP also directly receives a small portion of recycled water from the West
Basin Municipal Water District (WBMWD), which provides additional treatment of wastewater
from the Hyperion Treatment Plant (HTP) in El Segundo. (LADWP, 2010)
b. Regulatory Setting.
Federal. The federal Clean Water Act (CWA) establishes regulatory requirements for
potable water supplies, including raw and treated water quality criteria. The City is required to
monitor water quality and conform to the regulatory requirements of the CWA.
The federal Safe Drinking Water Act (SDWA) establishes standards for contaminants in drinking
water supplies. Maximum contaminant levels and treatment techniques are established for each
of the contaminants. The listed contaminants include metals, nitrates, asbestos, total dissolved
solids, and microbes.
State.
Executive Order B-29-15. On April 1, 2015, Governor Brown issued Executive Order B-2915, which ordered the SWRCB to impose restrictions to achieve a statewide 25 percent reduction
in potable urban water usage through February 28, 2016. Executive Order B-29-15 states,
“…these restrictions will require water suppliers to California’s cities and towns to reduce
usage as compared to the amount used in 2013” (SWRCB, 2015). The SWRCB has proposed the
following schedule for the development of emergency regulations to implement the new
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prohibitions and restrictions on water use, as well as the 25 percent statewide reduction in
potable urban water use contained in Executive Order B-29-15:
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April 1, 2015 - Governor issues Drought Executive Order;
April 7, 2015 - Notice announcing release of draft regulatory framework and
request for public comment (Mayor Garcetti’s Executive Directive No. 5 calls
for individual residents to achieve a 20 percent reduction in water use by
January 2017)
April 17, 2015 - Notice announcing release of draft regulations for informal
public comment
April 28, 2015 - Emergency rulemaking formal notice
May 5 or 6, 2015 - Board hearing and adoption. (SWRCB, 2015)
Safe Water Drinking Act (1976). California enacted its own Safe Water Drinking Act. The
California Department of Health Services (DHS) has been granted primary enforcement
responsibility for the SDWA. Title 22 of the California Administrative Code establishes DHS
authority and stipulates drinking water quality and monitoring standards. These standards are
equal to or more stringent than federal standards.
California Urban Water Management Planning Act (first effective on January, 1984) requires
urban water suppliers to prepare and adopt an updated UWMP every five years. The UWMP is
to forecast future water demands and water supplies under average and dry year conditions,
identify future water supply projects such as recycled water, provide a summary of water
conservation best management practices (BMPs), and provide a single and multi-dry year
management strategy.
Senate Bill 610 (2001). Senate Bill 610 (Costa) was signed into law in 2001. This law
requires cities and counties to develop a Water Supply Assessment (WSA) when considering
approval of development projects that meet certain thresholds of scale, in order to determine
whether projected water supplies can meet the Project’s anticipated water demand. The
Proposed Project does not require a WSA pursuant to SB 610 because it includes fewer than 500
residential units and less than 250,000 square feet of commercial floor area.
Local.
City of Los Angeles General Plan, Public Services and Facilities Element. This Element of the
Los Angeles General Plan identifies the following policies relative to water supply.
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Policy PS/F 3.1: Increase the supply of water though the development of new sources,
such as recycled water, gray water, and rainwater harvesting.
Policy PS/F 3.2: Support the increased production, distribution and use of recycled
water, gray water, and rainwater harvesting to provide for groundwater recharge,
seawater intrusion barrier injection, irrigation, industrial processes and other beneficial
uses.
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Section 4.6 Utilities and Service Systems
The Project is required to comply with Los Angeles Landscape Ordinance No. 170,978, which
includes mandatory water conservation requirements enforced as a condition of issuing
building permits. In addition, the Proposed Project is required to comply with Ordinance No.
172,075 (requiring low-flow showerheads, water closets, and urinals), 163,532 (requiring
reduction in large turf areas), 181,480 (City of Los Angeles Green Building Code), and 183,608
(Emergency Water Conservation Plan). A summary of applicable mandatory water
conservation requirements is included below.
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A management plan for the system, as specified by the Department of City Planning,
emphasizing water conservation, shall be included with all irrigation systems
documentation, and if an automatic controller is used, a copy of the plan shall be
permanently affixed to the controller or to a surface immediately adjacent to it.
To the extent feasible, the Project shall use water conserving plants and techniques in
landscape design, and especially water conserving native plants; this includes
employing water-conserving design and techniques utilizing native plants in
appropriate microclimates.
All irrigation systems shall be zoned to take into account prevailing winds, degree of
slope, type of soil, orientation of the site, season, insolation, type of vegetation to be
irrigated, type of irrigation application equipment and such other design information as
the Department may require and to minimize irrigation of any unplanted surface, and to
minimize drainage of water onto any paved surface. These design constraints, and any
others that may be specific to the site, shall be clearly indicated on all irrigation
documents.
All ground water recharge areas shall be approved by the City Engineer.
Adequate backflow protection shall be installed in each irrigation system.
Compliance with Emergency Water Conservation Plan, currently considered to be in
Stage II drought. Stage II drought restrictions include, but aren’t limited to:
o Limited watering days and times;
o Restrictions on hosing down hard surfaces, including vehicles;
o Operation of decorative water features, unless the water is recirculated.
Consistent with requirements of the California Urban Water Management Planning Act,
LADWP’s 2010 UWMP assesses water supply availability under normal-year (non-drought)
and dry-year (drought) conditions. These scenarios are modeled based on actual hydrologic
conditions during historic drought years. Table 4.6-1 provides an overview of the UWMP
analysis of water supply availability during multiple dry-year conditions, which is the most
conservative scenario assessed. These estimates represent LADWP’s service area reliability over
the years 2016 through 2020, modeling ongoing drought conditions in California.
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Table 4.6-1
Multiple Dry Years Water Supply and Demand
2016
2017
2018
2019
2020
Total Demand (AFY)
647,100
661.200
675,400
644,600
665,100
Existing/Planned Supplies (AFY)
200,480
215,520
168,200
221,680
289,730
MWD Water Purchases (AFY)
446,620
445,680
507,200
422,920
375,370
Total Supplies
647,100
661,200
675,400
644,600
665,100
Sources: LADWP, 2010 (Exhibit 11H)
As shown in Table 4.6-1, LADWP projects that adequate water supplies will be available to
meet demands within the LADWP service area even under the multiple dry-year scenario. Total
water demand identified in Table 4.6-1 is based on SCAG population projections, which expect
an increase from 4,100,260 in 2010 to 4,467,560 in 2035. As discussed in the Revised Initial Study
Section XIII(a), Population and Housing, the development of 335 residential units that would
occur under the Proposed Project would accommodate both existing housing demand and new
population. The level of population increase potentially associated with the Proposed Project
would not exceed the SCAG population projections; therefore, the population increase and
associated water demand increase is considered to be accounted for in the LADWP UWMP
projections. As such, there are sufficient supplies available to meet the needs of the Project
without resulting in significant adverse impacts to water supply.
The Public Services and Facilities Element works in conjunction with the Los Angeles County
Department of Public Works (DPW) Strategic Plan, which outlines service delivery goals for
public utilities, including water supply (Los Angeles County, 2015).
4.6.2
Impact Analysis
a. Methodology and Significance Thresholds. The analysis of potential impacts to
water supply is based on information provided in LADWP’s 2010 UWMP and involved
comparison of the Project’s water supply requirements to existing and projected water supplies.
As previously discussed, this analysis is specific to water supply availability, based on the
analysis provided in the Revised Initial Study for the Proposed Project.
The following threshold is based on Appendix G of the CEQA Guidelines.
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Have sufficient water supplies available to serve the project from existing entitlements
and resources, or are new or expanded entitlements needed?
The criterion above is also identified as one of the City of Los Angeles CEQA Thresholds; the
City Thresholds includes the following additional criterion relevant to water supply.
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Require or result in the construction of new water or wastewater treatment facilities, the
construction of which could cause significant environmental effects?
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Based on the significance criteria above, impacts associated with water supply would be
significant if sufficient water supplies are not available to the Project, if new or expanded
entitlements to a water supply become necessary as a result of the Project, or if new water
treatment facilities become necessary as a result of the Project.
b. Regulatory Compliance Measures and Project Design Features. The Project would
comply with all applicable regulatory standards. In particular, the Project would comply with
Los Angeles Landscape Ordinance No. 170,978 as outlined above. In addition, the Project would
comply with Ordinance No. 172,075 (requiring low-flow showerheads, water closets, and
urinals), 163,532 (requiring reduction in large turf areas), 181,480 (City of Los Angeles Green
Building Code), and 183,608 (Emergency Water Conservation Plan). The Project would also
comply with the City of Los Angeles Green Building Code and 2013 CALGreen Code. The
following Project Design Feature (PDF) is also proposed with regard to utilities:
PDF U-1
Water Reduction. The Proposed Project shall implement the
following PDF to reduce water use. This shall include, but is not
limited to:
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Use tankless water heaters;
Prepare site for reclaimed water use to accommodate the future
availability of recycled water as a source for Project irrigation
systems;
Set automatic irrigation systems to irrigate during early morning
or evening hours to minimize water loss due to evaporation and
reset to water less in cooler months and during rainfall season;
Use drip irrigation and soak hoses in lieu of sprinklers to lower
the amount of water lost to evaporation and overspray;
Recycle all water used in cooling systems to extent feasible; and
Perform regular preventive maintenance on all pumps, valves,
and piping, in the Project's water system to minimize water waste.
c. Project Impacts and Mitigation Measures.
Threshold:
Have sufficient water supplies available to serve the Project from existing
entitlements and resources, or are new or expanded entitlements needed?
Threshold:
Require or result in the construction of new water or wastewater
treatment facilities, the construction of which could cause significant
environmental effects?
Impact U-1
The Proposed Project would increase on-site water demand by
an estimated 52.9 acre-feet per year (AFY). Water would be
provided by the LADWP, which has sufficient water supplies
available through 2035, based on population projections in
LADWP’s 2010 Urban Water Management Plan (UWMP). The
Project would implement a PDF to minimize water supply
requirements. Impacts to water supply would therefore be less
than significant.
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As discussed in the introduction to this section, the Proposed Project would require
approximately 54,672 gallons of water per day, or 61.2 AFY; in comparison to existing land uses
on the Project site, this equates to an increase of approximately 47,299.4 gallons per day, or 52.9
AFY. Existing and projected water use rates on the Project site are identified in Table 4.6-2.
Table 4.6-2
Water Demand Comparison
Gallons per Day
Acre-Feet per Year
Existing Land Use
7,373
8.3
Proposed Land Use
54,672
61.2
Difference
+47,299
+52.9
As discussed in the Environmental Setting Section, 3.0, water for the Proposed Project would be
provided by the LADWP, which receives water via several sources, including the LAA, local
groundwater, MWD, and recycled water. Of these sources, MWD currently provides the largest
portion of LADWP water (approximately 52 percent), although this amount varies annually
depending on factors such as climate (drought) and the availability of other water sources.
LADWP’s 2010 UWMP projects future reliance on MWD water (and other sources) based on
anticipated population growth forecasts developed by the Southern California Association of
Governments (SCAG), as well as anticipated future water supply development through efforts
such as, but not limited to, area-wide conservation programs. For instance, as discussed in the
Regulatory Environment section above, the SWRCB is currently working toward a 25 percent
reduction in urban water usage through February 2016, in accordance with Executive Order B29-15 and LADWP is currently working toward a 20 percent reduction in water usage through
January 2017, in accordance with Mayor Garcetti’s Executive Directive No. 5.
Water supply would be required to meet fire flow requirements. The Project applicant was
required to apply for a Service Advisory Request (SAR/Fire Flow Request) with the City of Los
Angeles Fire Department (LAFD), as required for issuance of a Building Permit for the Project.
As part of the SAR, the Project applicant identified fire flow requirements. Improvements to
existing water infrastructure in the Project area are necessary to meet fire flow requirements,
and would be determined through coordination with the LAFD and the LADWP during
preparation and processing of the Building Permit. Upgrades to public water mains and fire
hydrants in the area may be necessary to meet existing needs for fire protection, regardless of
the proposed project.
Design of the Proposed Project would include water line connections to existing LADWP
infrastructure, in order to facilitate delivery of operational water; these improvements would be
included in the Proposed Project design and would be funded and implemented by the Project
proponent during the construction period. Existing water connections would be used as
practicable, or the Project proponent would coordinate with the City to disconnect services to
existing connections. As discussed above, there would be sufficient water supplies available
through LADWP’s existing and anticipated sources to serve the Proposed Project. Nonetheless,
the Project would include PDF U-1. No new or expanded water entitlements would be required
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as a result of the Project, and no new water treatment facilities would be necessary. Impacts to
water supply would be less than significant.
Mitigation Measure. No mitigation measures would be required.
Significance After Mitigation. Impacts would be less than significant without
mitigation.
d. Cumulative Impacts. As discussed in Section 3.0, Environmental Setting, cumulative
development in the City of Los Angeles would add both dwelling units and non-residential
development (offices, retail, restaurant, and mixed use) within two miles of the Project site. As
shown in Table 3-1, Cumulative Projects, planned and pending development in the Project area
would introduce 2,119 dwelling units and nearly 1.2 million square feet of non-residential
space. Projects in the cumulative scenario are subject to the same laws and regulations as the
Proposed Project with respect to water supply planning, and are also within the jurisdiction of
the LAWDP. As such, based on the analysis presented above, it is reasonably anticipated that
projects within the cumulative scenario would introduce water supply requirements that are
accounted for in the SCAG projections used in the LADWP UWMP projections. Water supply
for cumulative projects would be provided by the LADWP in compliance with the 2010 UWMP.
As described under Utilities, Section 4.6.1, Setting, the ongoing drought in California has led to
restrictions on water use in the Project area, increased incentives for water conservation, and the
potential for water rationing by MWD during summer months. If MWD implements water
rationing in the summer months, cumulative development within the City would be required to
comply with any additional restrictions on water use that the City implements, which may
include additional restrictions on landscape irrigation and promotion of non-potable water use,
such as grey water. Water rationing would be temporary in nature, as it would be restricted to
the summer months and to times of extreme emergency.
The Proposed Project would not result in significant adverse impacts to water supply and
would not substantially contribute to cumulative water supply impacts.
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