1. INTRODUCTION 2 REGULATORY FRAMEWORK. a. City of Los Angeles General Plan Framework

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1 IV.K.1 POLICE PROTECTION 1. INTRODUCTION This section describes existing City of Los Angeles Police Department (LAPD) police protection facilities and services in the Project area, and analyzes the ability of these facilities and services to serve the proposed project without substantially reducing existing service levels. This section is based, in part, on information provided by the LAPD, which is included as Appendix IV.K.1 of this. For analyses of Project impacts on emergency preparedness and existing emergency response plans, see Sections IV.F, Hazards/Hazardous Materials and IV.K.2, Fire Protection, of this. 2 REGULATORY FRAMEWORK a. City of Los Angeles General Plan Framework The City of Los Angeles General Plan Framework, originally adopted in December 1996 and readopted in August 2001, the Framework Element is intended to provide a comprehensive vision or strategy for long term growth within the City and guide subsequent amendments of the City's Community Plans, Specific Plans, zoning ordinances, and other local planning programs, although it does not supersede the more detailed Community and Specific Plans. 1 As stated in the Framework Element, primary police law enforcement services are provided by the LAPD and supplemental services are provided by the Los Angeles County Sheriff, the California Highway Patrol, the Federal Bureau of Investigation (FBI) and the Drug Enforcement Administration (DEA). Chapter 9 of the General Plan Framework addresses Infrastructure and Public Services. Within this chapter, Goal 9I states that every neighborhood should have the necessary police services, facilities, equipment, and manpower required to provide for the public safety needs of that neighborhood. 2 Related Objective 9.13 and Policy , which are meant to implement Goal 9I, requires the monitoring and reporting of police statistics and population projections for the purpose of evaluating existing and future needs. Objective 9.14 requires that adequate police services, facilities, equipment, and personnel be available to meet existing and future public needs. Objective 9.15 requires police services to provide adequate public safety in emergency situations by 1 City of Los Angeles General Plan, Citywide General Plan Framework Element, (2001). 2 City of Los Angeles General Plan Framework, 9 5. City of Los Angeles IV.K.1 1 Barlow Hospital Replacement and Master Plan Project

2 maintaining mutual assistance relationships with local law enforcement agencies, State law enforcement agencies, and the National Guard. b. Silver Lake Echo Park Elysian Park Community Plan The City of Los Angeles Silver Lake Echo Park Elysian Park Community Plan (Community Plan), adopted in 2004, contains goals, objectives, policies and programs to ensure adequate police protection facilities and services in the Community Plan Area (including at the project site). Chapter III of the Community Plan indicates that the LAPD s Central Bureau provides police protection services to the Community Plan area through two police stations (including the Northeast Police Station which serves the Project site). In Chapter III of the Community Plan, Goal 8 calls for a community with adequate police facilities and services to protect the community s residents from criminal activity, reduce the incidence of crime and provide other necessary law enforcement services; Objective 8 1 calls for providing adequate police facilities and personnel to correspond with population and service demand; Policy calls for coordination with the Police Department as part of project review to determine impacts on service demand; and the associated program indicates that the decision maker should include a finding which considers the impact of a proposed project on police service demand. Project compliance with this goal, objective, and policy is discussed in Section IV.H, Land Use, of this. c. City of Los Angeles COMPSTAT Program In 1994 the LAPD incorporated the use of Computer Statistics Unit (COMPSTAT). The LAPD Computer Statistics Unit (COMPSTAT) implements the General Plan Framework goal of assembling statistical population and crime data to determine necessary crime prevention actions. This system implements a multi layered approach to police protection services through statistical and geographical information system (GIS) analysis of growing trends in crime through a specialized crime control model. COMPSTAT has been proven to measurably reduce crime occurrences in Los Angeles communities through accurate and timely intelligence regarding emerging crime trends or patterns. 3 d. City of Los Angeles Crime Prevention Program The City of Los Angeles has adopted a program to aid crime prevention through environmental design (CPTED) called Design Out Crime. The Design Out Crime program introduces ways to deter crime by incorporating crime prevention features into the design of buildings and public spaces. 3 LAPD. COMPSTAT. (2011). City of Los Angeles IV.K.1 2 Barlow Hospital Replacement and Master Plan Project

3 For example: housing units can be designed so as to allow neighbors to "self patrol" their environments; lighting and landscaping can be enhanced in parking lots to improve visibility; fences around housing developments can be designed in ways that avoid creating hiding places for criminals; signs can be removed from storefront windows to allow clear views in and out of the store; and vines or planted coverings can be placed on walls to deter graffiti. Such measures and others are set forth in a set of Design Out Crime guidelines which have been officially adopted by the City Council for distribution to developers, architects, urban planners and others involved in the design of building projects. The guidelines are also used by City agencies, such as the Housing Department, as criteria in evaluating projects worthy of City funding. The LAPD Crime Prevention Unit also consults with private developers to encourage the incorporation CPTED techniques into project design, and participates in the City s Permit Processing Network, an inter agency task force that reviews and comments on complex development projects during development review. 4 e. City of Los Angeles Charter and Administrative and Municipal Codes The law enforcement regulations, powers and duties of the LAPD are outlined in the City of Los Angeles Charter, City of Los Angeles Administrative Code, and the Los Angeles Municipal Code (LAMC). City of Los Angeles Charter Article V, Section 570 gives power and duty to the LAPD to enforce the penal provisions of the Charter, City ordinances, and State and federal law. The Charter also gives responsibility to the LAPD to act as peace officers and to protect lives and property in case of disaster or public calamity. Section of the Los Angeles Administrative Code requires the LAPD to adhere to the State of California standards described in Section of the California Penal Code, which charges the LAPD with the responsibility of enforcing all LAMC Chapter 5 regulations related to firearms, illegal hazardous waste disposal, and nuisances (such as excessive noise), and providing support to the Department of Building and Safety Code Enforcement inspectors and the Fire Department in the enforcement of the City s Fire, Building, and Health Codes. The LAPD is given the power and the duty to protect residents and property, and to review and enforce specific security related mitigation measures pertaining to new development. 4 Los Angeles Police Department. LAPD Design Out Website: Accessed October 24, City of Los Angeles IV.K.1 3 Barlow Hospital Replacement and Master Plan Project

4 3 EXISTING CONDITIONS a. Los Angeles Police Department i. Organization and Facilities On site police protection services are provided by the LAPD, which provides police protection within the jurisdictional boundaries of the City of Los Angeles. As a signatory to the Mutual Aid Operations Plan for Los Angeles County, LAPD may also exercise the option of calling for back up assistance from other local law enforcement agencies who are signatories to the Mutual Aid Operations Plan. In the vicinity of the project site, these other law enforcement agencies include the Los Angeles County Sheriff and the Glendale and Pasadena Police Departments. The LAPD is divided into four bureaus Central, West, Valley, and South which are in turn subdivided into 23 divisions and then into reporting districts. The Project site is located within LAPD s Central Bureau, Northeast Division, Reporting District (RD) 1185, and is provided primary police protection service by LAPD s Northeast Community Police Station. 5 The Central Bureau encompasses a 65 square mile territory with a population of approximately 900,000 residents. 6 The service boundaries of the Central Bureau are the Los Angeles City boundaries on the north and east, Florence Avenue to the south, and Griffith Park Boundary/Western Avenue to the west. The Central Bureau serves the downtown Los Angeles business district as well as the Eagle Rock, MacArthur Park, Dodger Station, Griffith Park, Boyle Heights, and Echo Park communities. It contains five divisions, including the Central, Hollenbeck, Newton, Rampart, and Northeast Divisions, each with a single community police station of the same name. The Northeast Division encompasses a 29 square mile territory with a population of approximately 250,000 residents. 7 Its service boundaries extend to the Los Angeles City boundaries on the north and east, the Harbor Freeway (SR 110) on the southeast and Sunset Boulevard on the southwest, and the Griffith Park Boundary/Western Avenue on the west. It contains a single police station, the Northeast Community Police Station located at 3353 San Fernando Road, approximately 4.2 miles north of the Project site. This station serves the communities of Atwater, Cypress Park, Eagle Rock, 5 Los Angeles Police Department. LAPD Website: Ibid. 7 Ibid. City of Los Angeles IV.K.1 4 Barlow Hospital Replacement and Master Plan Project

5 East Hollywood, Echo Park, Elysian Park, Solano Canyon, Elysian Valley, Franklin Hills, Garvanza, Glassell Park, Highland Park, Los Feliz, Mt. Washington, and Silverlake. The station, which is nearly 30 years old, is due for replacement, with construction of a new station expected to later in ii. Crime Rates The crime rate in a given area represents the number of crimes reported in that area over a given period of time, which affects the anticipated needs, projection for staff, and equipment for the LAPD. Generally, the crime rate in a given area increases as the level of activity or population intensifies. However, because of other factors, such as police presence, crime prevention measures, and ongoing legislation/funding for increased service, the potential for an increase in crime rate is not directly proportional to the increase in land use activity. Crimes committed in RD 1185, the Northeast Division, and Citywide are shown in Table IV.K.1 1, Los Angeles Police Department Crimes by Reporting Area for As shown therein, the Northeast Division reported 2,095 crimes in 2010, for a generation factor of approximately 12 crimes per 1,000 persons Division wide. There were a total of 85 calls for service in RD 1185 in a 12 month period during 2010, the most recent period for which data is available; five were emergency calls and 80 were non priority calls for service. 9 The predominant crime in the RD 85, the Northeast Division, and Citywide was burglary from vehicle. iii. Response Times Response time is another standard by which the adequacy of police service is evaluated. Response time is defined as the total time from when a call requesting assistance is made until the time the first unit responds to the scene. Calls for police assistance are prioritized based on the nature of the call. For example, a crime in progress may receive a higher priority than a call that is reporting a crime already committed. Also, the potential for harm to citizens is considered when a call is received. Currently, the LAPD s response time goal is seven minutes for high priority calls and 40 minutes for nonemergency calls. 10 The Northeast Division currently meets this response time 8 Ibid. 9 Correspondence from Charlie Beck, Chief of Police, Los Angeles Police Department, May Provided in Appendix IV.K Correspondence from Charlie Beck, Chief of Police, Los Angeles Police Department, May Provided in Appendix IV.K.1. City of Los Angeles IV.K.1 5 Barlow Hospital Replacement and Master Plan Project

6 Table IV.K.1 1 Los Angeles Police Department Crimes by Reporting Area for 2010 Types of Crimes RD 1185 Northeast Division Citywide Burglary 2 2.4% % 6, % Rape 0 0% 6 0.3% % Murder/Homicide 0 0% 8 0.4% % Robbery 0 0% % 4, % Aggravated Assault 5 5.8% % 4, % Grand Theft 3 3.5% % 6, % Burglary from Vehicle % % 10, % Theft From Person 0 0% % 10, % Other Theft % 0 0% % Other % 0 0% 0 0% Total Crimes % 2, % 43, % Source: Charlie Beck, Chief of Police, Los Angeles Police Department, communication with Impact Sciences, May (Provided in Appendix IV.K.1) goals, which are considered adequate for the Project area. 11 Moreover, unlike fire protection equipment, police units are often mobile, and as a result, the actual distance between a headquarters facility and the site of an incident is not as closely related to response time as is the number and distribution of squad cars patrolling a Division. The project site is located within Basic Car patrol area 11A95 which covers approximately 1.6 square miles (smaller than many), and the Project site is roughly in the center of the patrol area. 12 Hence, at least one squad car is usually within less than a mile of the Project site at all times and it is anticipated that existing emergency and nonemergency LAPD response times to the Project site are well within LAPD s response time goals. iv. Adequacy of Existing Police Protection Services The adequacy of police protection services for a given area is based on a combination of assessment factors, including officer to population ratio, type of land uses, response time, and available 11 Ibid. 12 Loss Angeles Police Department. Northeast Area Basic Car Map. LAPD Website: /inside_the_lapd/content_basicview/41960/central+bureau/northeast/11a95/1184/ Accessed October 24, 2011 City of Los Angeles IV.K.1 6 Barlow Hospital Replacement and Master Plan Project

7 equipment. According to the LAPD, police protection services in the Northeast Division are currently adequate to meet existing demand based on these factors. 13 b. Barlow Hospital Security Barlow Hospital currently employs staff security within the main hospital building, which operates 24 hours per day. Security personnel are responsible for patrolling the parking lots and grounds during business hours, and have the authority to detain suspicious persons until police arrive. 4. IMPACT ANALYSIS a. Methodology Potential Project impacts were evaluated according to the City of Los Angeles CEQA Thresholds Guide and based on consultation with the LAPD and the LAPD s website to determine the adequacy of existing and anticipated staffing, equipment, and facilities to meet the additional demand for police protection services resulting from development of the proposed Project. Although the LAPD does not maintain an internal minimum officer to population ratio standard, effects on the officer to population ratio and the net increase in reported incidents and calls for service were taken into consideration when determining the impact of the proposed Project on Police services. b. Significance Thresholds Appendix G of the State CEQA Guidelines identifies the following screening question addressing impacts to public services, including police protection services: XIV.a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection? The City of Los Angeles CEQA Thresholds Guide states that the determination of significance should be made on a case by case basis, considering the following factors: 13 Correspondence from Charlie Beck, Chief of Police, Los Angeles Police Department, May Provided in Appendix IV.K.1. City of Los Angeles IV.K.1 7 Barlow Hospital Replacement and Master Plan Project

8 The population increase resulting from the proposed project, based on the net increase of residential units or square footage of non residential floor area; The demand for police services anticipated at the time of project buildout compared to the expected level of service available. Consider, as applicable, scheduled improvements to LAPD services, (facilities, equipment, and officers) and the project s proportional contribution to the demand; and Whether the project includes security and/or design features that would reduce the demand for police services. Based on Appendix G of the State CEQA Guidelines and the City of Los Angeles CEQA Thresholds Guide, the proposed Project would have a significant impact on police services if: POL 1 POL 2 The Project would generate a substantial increase in demand for LAPD police protection services which would require the expansion of existing or development of new LAPD facilities to maintain the existing level of service. The Project would result in exceedance of LAPD response time goals during either Project construction or operation. c. Project Design Features The following project design features are proposed to reduce project impacts on police protection services. Private security will be continue to be provided for the replacement hospital upon its completion. Residential parking has been designed to minimize the Project residents potential exposure to vehicle crimes by providing secured parking. Parking for the residential uses in Parcels 1 12 will be provided in controlled access (gated), partially subterranean podium parking structure, and parking for the proposed townhomes on Parcel 13 will be provided in attached garages. Any off site road closures required during project construction will be limited to the closure of a single lane at a time, thus retaining access for emergency vehicles. City of Los Angeles IV.K.1 8 Barlow Hospital Replacement and Master Plan Project

9 All project construction worker shifts will not start between 7:15 AM and 9:45 AM or end between 3:15 PM and 6:45 PM. Therefore, construction workers will arrive and depart the project site during non peak hours. Per the Construction Traffic Analysis in Appendix IV.L of this, Construction Traffic Analysis, this will reduce project construction traffic impacts to less than significant levels. All parking for construction workers and construction equipment will either be on the project site or in leased off site parking areas. Any off site areas will either be within 750 feet of the construction site or connected to the site by a shuttle service. Therefore, there will be no construction worker or construction equipment parking on local streets. During Project construction, construction sites will be secured with fencing and locked entrances. Construction equipment, tools and materials will be secured by locking or placing them within sheds and/or other inaccessible areas while not in use. Construction sites will be lighted at night to deter theft and vandalism. Project design will address access control to proposed structures including parking areas, security lighting, landscaping planning and minimization of dead space to eliminate areas of concealment, and provision of security patrol throughout the Project site. The City s CPTED Design Out Crime Guidelines will be used for reference. All crime prevention features will be reviewed and approved by LAPD prior to the issuance of a building permit. Prior to the issuance of a building permit, the Los Angeles Police Department, Crime Prevention Unit, will have the opportunity to comment regarding security and crime prevention features. Upon completion of each building or facility, a diagram of each completed building or facility will be provided to the Los Angeles Police Department, Northeast Division Commanding Officer, and will show access routes, building locations, and any additional information to help facilitate police response. LAPD will also be provided with all project gate codes to facilitate emergency access. d. Project Impacts POL 1 Would the project generate a substantial increase in demand for LAPD police protection services which would require the expansion of existing or development of new LAPD facilities to maintain the existing level of service? City of Los Angeles IV.K.1 9 Barlow Hospital Replacement and Master Plan Project

10 POL 2 Would the project would result in exceedance of LAPD response time goals during either project construction or operation? i. Construction Impacts Construction activities associated with implementation of the proposed Project would occur in a variety of locations on the Project site, with buildout anticipated for the year Typically, crime and safety issues during construction include trespassing on the construction site, theft of building materials and construction equipment, malicious mischief, graffiti, and general vandalism. However, project construction activities would be temporary, and crime and safety issues associated with construction do not typically place undue demands on police protection services. Furthermore, proposed Project design features include the provision of fencing, security lighting, and other construction site security measures to deter criminal activity. For these reasons, Project construction is not anticipated to generate a substantial increase in demand for LAPD police protection services, and impacts would be less than significant. Construction activities can sometimes reduce police response times in and around a construction site through obstruction of existing roadways by construction vehicles, lane closures, and/or increased traffic congestion. A proposed project design feature requires any off site road closures required during construction to be limited to the closure of a single lane at a time, thus retaining access for emergency vehicles. Moreover, as is summarized in Section IV.N, Transportation, a mitigation measures requiring construction workers to arrive and depart the Project site during offpeak hours would be implemented for the Project and would reduce the potential for construction activities to adversely affect emergency response access and times. Therefore, construction impacts on police response times would be less than significant. ii. Operational Impacts As discussed in Section IV.J, Population, Housing and Employment, the proposed Project s 131,000 square feet of replacement hospital, administrative and skilled nursing uses, 888 new residential units, and 15,000 square feet of commercial uses would generate a net increase in on site daytime population of an estimated 2,494 persons. Assuming that all these persons represent new residents or employees to the area, which is a conservative assumption given that some of these employees and residents likely already live and/or work in the area, this increase in population would represent an approximately one percent increase in the existing Northeast Area service population and could potentially generate an estimated 24 additional crimes on an annual basis (based on the City of Los Angeles IV.K.1 10 Barlow Hospital Replacement and Master Plan Project

11 existing crime to population ratio within the Northeast Division of approximately 12 crimes per 1,000 residents). The Project related increase in service population and associated potential increase in crimes would generate additional demand for police protection services from the Northeast Community Police Station. This increase in service demand would not represent a substantial increase requiring new or expanded LAPDF facilities. The previously discussed Project design features, including private onsite security, controlled access parking,; Project design and security features such as security lighting, minimization of dead space, etc., consistent with LAPD s CPTED Design Out Crime guidelines; and Project site design review by LAPD. Conservatively assuming no excess capacity to provide additional police protection services currently exists at the Northeast Community Police Station, the Project would result in a demand for less than one additional police officer and squad car at the Northeast Station, and police officers are usually out on patrol rather than working at a station. Moreover, plans are in process to replace the existing station with a larger station in Finally, the Project would generate additional City tax revenues to fund police protection facilities and services. For these reasons, Project impacts related to demand for police protection services would be less than significant With respect to emergency access, the Project will increase rather than reduce vehicular access in the Project area by requiring widening of Stadium Way to comply with Bureau of Engineering half right of way cross section standard standards for a Secondary Highway. Project implementation would also increase access throughout the Project site, will not close or narrow existing off site streets, and will be consistent with all LAMC design, street cross sections, street turning radii, signage, and other applicable requirements (as implemented through development review by LAPD, Los Angeles Building Department, and other City Departments). In addition, a Project design feature is proposed that requires that the LAPD be provided with all building diagrams and Project gate codes after construction to ensure emergency access. Therefore, adequate emergency access would be provided and impacts would be less than significant. With respect to police emergency response times, the proposed Project would increase traffic on the local street network during operation which could potentially increase police response times. However, LAPD has indicated that existing police response times within the Northeast Division are within LAPD response time goals (i.e., the Project would not add to response times which already exceed LAPD goals). Also, because the Project site is located in the center of Basic Car patrol area City of Los Angeles IV.K.1 11 Barlow Hospital Replacement and Master Plan Project

12 11A95, and because this patrol area covers approximately 1.6 square miles (smaller than many), at least one squad car is usually within less than a mile of the Project site at all times. Furthermore, while the project would result in significant traffic congestion at several intersections during peak periods as discussed in Section IV.L, Transportation, the project would result in less than significant impact on congestion at the majority of intersections in the local street network such that multiple alternative routes would be available for LAPD to respond to emergency calls. Finally, the Project would not close or narrow existing off site streets. For these reasons, the project would not result in exceedance of LAPD response time goals and impacts would be less than significant. e. Mitigation Measures Project impacts on police protection services were determined to be less than significant and no mitigation is required. f. Level of Significance After Mitigation With the implementation of the proposed Project design features, Project impacts on police services would be less than significant and no mitigation measures are required. g. Cumulative Impacts Four of the related projects discussed in Section III, General Description of Environmental Setting, are proposed and/or planned within the LAPD s Northeast Division (i.e., related projects 10, 14, 19 and 21). Two of these projects are proposed residential uses and, based on the average household size in the Project Census tract, would add a total of approximately 465 residents within the Northeast Division. Considered together with the proposed Project s 2,494 residents would result in an increase in residential population within LAPD s Southwest service area. Project impacts on police protection services were determined to be less than significant, considered together with the related projects in the Northeast Division, would add a relatively small number of new residents to the service area. Moreover, the increase in demand associated with the proposed Project and related projects would be met by increases in law enforcement staffing and equipment as needed, which would be funded by increased revenues from the increased tax base and represented by the Project. In addition, each project would be subject to review by the LAPD to ensure that adequate access and security are provided as part of Project design and implementation. Therefore, the proposed project is not expected to result in a considerable contribution to cumulatively significant impacts on police protection services. City of Los Angeles IV.K.1 12 Barlow Hospital Replacement and Master Plan Project