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In accordance with the CEQA Guidelines, the No Project/No Build Alternative for a development project on an identifiable property consists of the circumstance under which a proposed project does not proceed. Section 15126.6(e)(3)(B) of the CEQA Guidelines states in part, that, "in certain instances, the No Project Alternative means 'no build' wherein the existing environmental setting is maintained." Accordingly, Alternative 1, the No Project/No Build Alternative, assumes that the Project would not be approved, no new development would occur within the Project Site, and the existing environment would be maintained. Under Alternative 1, the existing commercial uses would continue to operate on the Project Site, and no new construction or building expansion would occur. Furthermore, no changes to the existing on-site parking or access would occur.

7 .1.1 Environmental Effects

Alternative 1 would avoid the Project's significant environmental impacts related to on-site noise and on-site and off-site vibration impacts during construction and its operational off-site mobile source noise impacts. As no changes to the existing conditions would occur, Alternative 1 would also eliminate the Project's remaining impacts that are already less-than-significant or less-than-significant with mitigation (i.e., geology and soils). However, impacts to surface water quality, surface water hydrology, and groundwater hydrology would be greater than the Project although still less than significant. Substantial evidence supporting these environmental impact conclusions is provided in Section V. Alternatives of the Draft EIR (pp. V-16 to V-28).

7.1.2 Finding

Overall, Alternative 1 would not meet any of the Project objectives or the proposed Project's underlying purpose to maximize the development potential on the Project Site through the development of a high quality commercial project that revitalizes the site and provides a variety of uses, including a private membership club with guestrooms, restaurants, bars, lounge and dining spaces, screening rooms, a supper club, and a rooftop pool, along with publicly-accessible retail space, a ground-floor restaurant with outdoor dining and live music, an art gallery, and creative office space. As such, the City rejects Alternative 1. The City finds that this alternative is not desirable because it retains an underdeveloped retail property in the heart of the Sunset Strip, which the City has identified in its General Plan as an international destination for nightlife, pedestrian friendly and entertainment uses. The City finds this alternative is not feasible because it fails to meet any of the project objectives, including "support the community's vision of the Sunset Strip as a high-quality international entertainment destination" and "add to the diversity of visitor-serving uses available on the Sunset Strip. In addition, the Project is focused on the development of a particular underutilized site, which is under the ownership of the Project Applicant, and given the built-out nature of the City, no equivalent and available alternate site exists. As such, the No Project Alternative is not considered a reasonable development alternative.

7.2 Alternative 2-Reduced Density/8-Story Alternative

The Reduced Density/8-Story Alternative would include the development of a multi-use, eight-story building on the Project Site through amendments to the General Plan, Sunset Specific Plan (SSP), and zoning designations to allow for additional height, density, and land uses. As with the Project, this alternative would also require associated requests for approval of demolition, development, administrative, and conditional use permits. Alternative 2 would include the development of a multi-use, eight-story building on the Project Site. The new building would be placed within the same building footprint as the Project and would include the same overall design features and architecture.

Similar to the Project, Alternative 2 would include retail and gallery uses on the ground floor, creative office space on the second to fourth floors, Arts Club space on a total of four above-ground floors and within one subterranean level, and a rooftop pool deck terrace with an emergency helipad. Ground level and rooftop space would be the same as for the Project. However, Alternative 2 would reduce the overall square footage of the Arts Club by relocating one of the floors dedicated to its use to one of the subterranean levels. More specifically, the 16,137 square feet of Arts Club uses proposed for Level 5, as shown in Table

11-1 in Section 11, Project Description, of the Draft EIR, consisting of fitness center/spa, screening rooms, holding bar and support area under the Project, would be relocated under Alternative 2 to a mezzanine level within Level 82, consisting of 15,742 square feet of subterranean Arts Club space, which could be sufficiently accommodated within the existing space and height capacity of Level 82. As a result, Alternative 2 would remove one level of Arts Club space from the aboveground levels and relocate it to the second subterranean level, providing a total of six below grade levels with a below grade mezzanine level.

The overall number of underground parking levels within the parking structure would not change and the number of parking spaces provided would be the same as the Project. In addition, this re-configuration in design would not require any expansion of the overall size or depth of the underground parking structure proposed by the Project.

Alt~rnative 2 would reduce the Project's nine-story, 141-foot tall building to an eight-story building with a maximum height of 127 feet (measured from the lowest point along Sunset Boulevard). Since Alternative 2 would relocate one of the Project's floor levels underground, Alternative 2 would reduce the Project's FAR to 5.7 but would still require an amendment to the SSP's allowable base FAR of 1.5 for the Project Site.

7.2.1 Environmental Effects

Alternative 2 would not eliminate the Project's significant and unavoidable impacts related to on-site construction noise impacts (both Project-level and cumulative conditions), and on-site construction vibration impacts (related to human annoyance). In addition, both: (1) Project-level off-site traffic noise during operation in comparison to existing conditions under Alternative 2; and (2) cumulative off site traffic noise during operation under Alternative 2 would each exceed the 5-dBA threshold, specifically along Hilldale Avenue (south of Sunset Boulevard), and this alternative's contribution to this impact would be the same as that of the Project since the peak-hour traffic volumes generated by Alternative 2 would be expected to be the same as those of the Project.

Alternative 2's impacts related to operation, including aesthetics/visual quality, views, light and glare; air quality; geology and soils; GHG emissions; hazards and hazardous materials; hydrology and water quality; land use; noise; public services (police protection and fire protection; traffic, access, and parking; and utilities and service systems (water consumption, wastewater generation, solid waste generation, and energy consumption) would be the same as those under the Project since Alternative 2 would essentially have the same amount of uses as the Project. However, these same impacts of the Project are already less than significant and would not be eliminated with this alternative. Shading would be slightly less than those of the Project and would also be less than significant

7.2.2 Finding