2048 N. Holly Drive (ENV-2024-2732-CE)

2025110089

City of Los Angeles

NOE - Notice of Exemption

11/4/2025

11/4/2025

Bryant Wu

City of Los Angeles, Department of City Planning

City Planning Associate

Lead/Public Agency

200 N Spring Street, Room 621
Los Angeles, CA 90012

(213) 202-5435

bryant.wu@lacity.org

James Woodson

JRW Consulting

Representative

Parties Undertaking Project

PO Box 35481
Los Angeles, CA 90035

(310) 922-2190

james.woodson@jrwconsultingservices.com

PROJECT LOCATION: 2048 N. Holly Drive

NAME OF APPLICANT / OWNER: 2048 Holly Dr., LLC / David Hu

Categorical Exemption

Section 15332 – Class 32

The City has considered whether the proposed Project is subject to any of the five (5) exceptions that would prohibit the use of a Class 32 Categorical Exemption as set forth in State CEQA Guidelines Section 15300.2. The five (5) exceptions to this Exemption are: (a) Cumulative Impacts; (b) Significant Effect; (c) Scenic Highways; (d) Hazardous Waste Sites; and (e) Historical Resources. While the subject site is located within a Hillside Area, BOE Special Grading Area (Map A-13372) Liquefaction Area, and a Fault Zone, specific Regulatory Compliance Measures (RCMs) in the City of Los Angeles regulate the grading and construction of projects in these particular types of “sensitive” locations and will reduce any potential impacts to less than significant. RCMs include: • RCM RC-GEO-2 (Hillside Grading Area): The grading plan shall conform with the City's Landform Grading Manual guidelines, subject to approval by the Advisory Agency and the Department of Building and Safety's Grading Division. Appropriate erosion control and drainage devices shall be provided to the satisfaction of the Building and Safety Department. These measures include interceptor terraces, berms, vee-channels, and inlet and outlet structures, as specified by Section 91.7013 of the Building Code, including planting fast-growing annual and perennial grasses in areas where construction is not immediately planned. • RCM RC-GEO-3 (Landslide Area): Prior to the issuance of grading or building permits, the applicant shall submit a geotechnical report, prepared by a registered civil engineer or certified engineering geologist, to the Department of Building and Safety, for review and approval. The geotechnical report shall assess potential consequences of any landslide and soil displacement, estimation of settlement, lateral movement or reduction in foundation soil-bearing capacity, and discuss mitigation measures that may include building design consideration. Building design considerations shall include, but are not limited to: • ground stabilization • selection of appropriate foundation type and depths • selection of appropriate structural systems to accommodate anticipated displacements or any combination of these measures The project shall comply with the conditions contained within the Department of Building and Safety’s Geology and Soils Report Approval Letter for the proposed project, and as it may be subsequently amended or modified. • Regulatory Compliance Measure RC-GEO-4 (Liquefaction Area): The project shall comply with the Uniform Building Code Chapter 18. Division1 Section 1804.5 Liquefaction Potential and Soil Strength Loss. Prior to the issuance of grading or building permits, the applicant shall submit a geotechnical report, prepared by a registered civil engineer or certified engineering geologist, to the Department of Building and Safety, for review and approval. The geotechnical report shall assess potential consequences of any liquefaction and soil strength loss, estimation of settlement, lateral movement or reduction in foundation soil-bearing capacity, and discuss mitigation measures that may include building design consideration. Building design considerations shall include, but are not limited to: • ground stabilization • selection of appropriate foundation type and depths • selection of appropriate structural systems to accommodate anticipated displacements or any combination of these measures. The project shall comply with the conditions contained within the Department of Building and Safety’s Geology and Soils Report Approval Letter for the proposed project, and as I may be subsequently amended or modified. These RCMs have been historically proven to work to the satisfaction of the City Engineer to reduce any impacts from the specific environment the project is located. The project shall comply with the conditions contained within the Department of Building and Safety’s Geology and Soils Report Approval Letter for the proposed project, and as it may be subsequently amended or modified. (a) Cumulative Impacts. All exemptions for these classes are inapplicable when the cumulative impact of successive projects of the same type in the same place, over time is significant. The project is for the subdivision of one (1) lot into five (5) lots for the construction, use, and maintenance of five (5) single-family dwellings. Lot 1 will consist of approximately 2,237 square-feet of lot area and contain approximately 1,983 square-feet of floor area. Lot 2 will consist of approximately 1,336 square-feet of lot area and will contain approximately 1,972 square-feet of floor area. Lot 3 will consist of approximately 1,336 square-feet of lot area and will contain approximately 1,882 square-feet of floor area. Lot 4 will consist of approximately 1,594 square-feet of lot area and will contain approximately 1,952 square-feet of floor area. Lot 5 will consist of approximately 3,735 square-feet of lot area and will contain approximately 2,462 square-feet of floor area. Each dwelling will contain two (2) parking spaces within an attached garage or car port, for a total of 10 covered parking spaces. The project will have a height of 34-feet. The project site is developed with a duplex. The site contains eight (8) trees on-site, none of which are protected trees. There is one (1) tree in the right-of-way. The project proposes the removal of seven (7) on-site trees. The project also proposes the export of less than 1,000 cubic yards of earth. Staff conducted a ZIMAS Case Numbers Report using a 500-foot radius to assess the number of the same type of projects in the same place. At the time of writing this report, one other project of the same type is located within the 500-foot radius. The approved Preliminary Parcel Map is for a maximum of three (3) small lots. Thus, there is no cumulative impact of successive projects of the same type in the same place. (b) Significant Effect. A categorical exemption shall not be used for an activity where there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances. The project is for the subdivision of one (1) lot into five (5) lots for the construction, use, and maintenance of five (5) single-family dwellings. The project site is developed with a duplex. According to a Protected Tree Assessment Report prepared by Kevin Neiman, Certified Arborist #WE 9194, dated October 13, 2023, there are eight (8) trees on site, none of which are protected. The one (1) street tree in the public right-of-way is to be protected in place, whereas the remaining seven (7) are proposed for removal. Surrounding properties are developed with single- and multi-family residential uses. The lots to the north, east, south, and west are all zoned RD2-1XL and are developed with single- and multi-family residences that range in height from one- to two-stories. The size of the proposed project, which contains an approximate total of 10,251 square-feet of floor area on an approximately 10,238 square-foot lot, will result in a Floor Area Ratio (FAR) of approximately 2.15:1 on a site that is permitted to have a maximum FAR of 3:1.The project’s size and height is not unusual for the vicinity of the subject site, and is similar in scope to other existing residential uses in the area. The subject site is in a Very High Fire Hazard Severity Zone (VHFHSZ). This does not support an unusual circumstance as the City has thousands of similar developments of the same size and scale in VHFHSZ. Additionally, the existing regulatory compliance measures will ensure there is no potential for an impact. Such areas are subject to existing emergency plans and regulations that govern development in fire hazards areas: • Adopted emergency response plans and emergency evacuation plans applicable to the City of Los Angeles, include the City of Los Angeles Emergency Operations Plan and the Los Angeles County Operational Area Emergency Response Plan (OAERP). The OAERP defines responsibilities and provides guidance to agencies and jurisdictions within the County Operational Area on how to interface with the Operational Area Coordinator during emergencies and disasters. The City’s Emergency Operations Plan and Annexes identify roles, responsibilities and required actions for various City departments, particularly LAFD and the LAPD. In addition to their emergency response plans, both the City and County also designate Disaster Routes, which are freeway, highway or arterial routes pre-identified for use during emergencies. Disaster routes are not the same as evacuation routes. The Evacuation Annex of the City’s Emergency Operation Plan provides that “[p]rimary evacuation routes consist of the major interstates, highways, and primary arterials within the City and Los Angeles County.” Disaster routes are used to bring emergency personnel, equipment, and supplies to impacted areas, while evacuation routes are used to move an affected population out of an impacted area. The closest County-designated primary (i.e. freeway) Disaster Route to the project site is the Interstate 5. • Hillside Development Construction Traffic Management Plan. Developments in a hillside area are required to prepare a Construction Traffic Management Plan, subject to review and approval by the Department of Transportation (LADOT). A key feature of the construction management plan is ongoing coordination with the City and emergency service providers throughout the entire construction period to ensure adequate access is maintained to the project site and neighboring residences at all times. The construction management plan also requires the contractor to maintain access for land uses in proximity to the project site during construction, to minimize obstruction of through traffic lanes on surrounding public streets, and coordination of construction activity with related projects to further minimize construction traffic impacts. A Construction Traffic Management Plan is required for new land use development projects requiring a discretionary entitlement proposed in hillside communities on streets less than 24-feet wide (on any roadway segment used by the project for hauling materials and equipment). The Preliminary Referral Form for Baseline Hillside Ordinance completed by the Department of Building and Safety/Public Works on January 16, 2024 reports that the roadway width for Waverly Drive is 30 feet. Therefore, a Construction Traffic Management Plan is not required. • Fire, Building, and Zoning Code. Properties in VHFHSZs must comply with the requirements of Fire Code Section 57.322, which requires brush clearance within 200 feet of any structure. LAFD performs microenvironment weather analysis to check for irregular weather patterns and changes, which alerts LAFD to conditions such as windy days combined with low humidity. LAFD uses a Burning Index to determine when to call a Red Flag Day. A Red Flag Day is when the potential for a fast-moving brush fire is extremely high, when wind speeds are 25 mph or more and the humidity is 15 percent or less. On those days, illegally parked cars in VHFHSZ areas may be towed if their presence would prevent roadway access needed by LAFD. LAFD also has a significant air response ready to deploy, including water-dropping helicopters, and the mission of LAFD Air Operations includes brush fire suppression. LAFD also has access to additional helicopters, fixed-wing aircraft, bulldozers, and fire engines through mutual aid agreements with the state, County, and other cities in the region. In addition to attacking wildfires from the sky, LAFD also has ground resources such as fire engines and trucks. Chapter 33 of the City’s Fire Code provides requirements designed to reduce risk of fire ignition during construction. These include, but are not limited to, prohibition of smoking except in areas approved by the LAFD, refueling of equipment in appropriate locations, preparation of a fire prevention program, and designation of fire watch personnel during occurrence of hazardous construction activities. The Fire Code (LAMC Section 57.4906.5.2) also requires the management of hazardous vegetation and fuel, as well as maintenance of defensible space in wildland-urban interface areas. The Fire Code also includes regulations that address building materials and construction methods for construction in VHFHSZs, that are intended to reduce exterior wildfire exposure. • Low Impact Development (LID) is a stormwater management strategy that seeks to mitigate the impacts of increases in runoff and stormwater pollution as close to its source as possible. LID comprises a set of site design approaches and Best Management Practices (BMPs) that promote the use of natural systems for infiltration, evapotranspiration, and use of stormwater. These LID practices can effectively remove nutrients, bacteria, and metals from stormwater while reducing the volume and intensity of stormwater flows. With respect to urban development and redevelopment projects, it can be applied onsite to mimic the site’s predevelopment drainage characteristics. Through the use of various infiltration techniques, LID is geared towards minimizing surface area that produces large amounts of runoff and does not allow water to infiltrate into the ground. Where infiltration is infeasible, the use of bioretention, rain gardens, vegetated rooftops, and rain barrels that will store, evaporate, detain, and/or treat runoff can be used. A preliminary LID review was completed by the Bureau of Sanitation through the LID Planning Case Referral Form no. 1432, dated January 12, 2024. According to the referral form, the project is required to provide calculations for capture and use, in accordance with Appendix F of the City of LA LID Handbook. If that is deemed infeasible, the project will be required to provide a biofiltration BMP, per the requirements of the LID Handbook. Additionally, an Owner’s Declaration of Biological Resources was signed on November 9, 2023 indicating that the project does not contain any of the applicable resources nor will it remove any biological resources. Thus, there are no unusual circumstances which may lead to a significant effect on the environment. (c) Scenic Highways. A categorical exemption shall not be used for a project which may result in damage to scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, within a highway officially designated as a state scenic highway. The only State Scenic Highway within the City of Los Angeles is the Topanga Canyon State Scenic Highway, State Route 27, which travels through a portion of Topanga State Park, located approximately 27 miles to the west of the site. Therefore, the project will not result in damage to any scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, within a highway officially designated as a state scenic highway, and this exception does not apply. (d) Hazardous Waste. A categorical exemption shall not be used for a project located on a site which is included on any list complied pursuant to Section 65962.5 of the Government Code. According to Envirostor, the State of California’s database of Hazardous Waste Sites, neither the Subject Site, nor any site in the vicinity, is identified as a hazardous waste site within 1,000 feet of the project site. (e) Historic Resources. A categorical exemption shall not be used for a project which may cause a substantial adverse change in the significance of a historical resource. The subject site has not been identified as a historic resource by local or state agencies, and the site has not been determined to be eligible for listing in the National Register of Historic Places, California Register of Historical Resources, the Los Angeles Historic-Cultural Monuments Register, and/or any local register; and was not found to be a potential historic resource based on the City’s HistoricPlacesLA website or SurveyLA, the citywide survey of Los Angeles. Based on this, the project will not result in a substantial adverse change to the significance of a historic resource and this exception does not apply.