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IV. ENVIRONMENTAL IMPACT ANALYSIS K.2 PARKING City Market of Los Angeles Draft EIR IV.K.2 Parking State Clearinghouse No. 2013021046 Page IV.K.2-1 1. INTRODUCTION The information in this section is based primarily on the parking requirements of the Los Angeles Municipal Code (LAMC) and applicable adopted planning polices and ordinances pertaining to onsite parking of vehicles and bicycles, including the parking guidelines of the Downtown Design Guide, and the City’s adopted Bicycle Ordinance. 2. ENVIRONMENTAL SETTING A. Existing Conditions The Project Site is currently developed and occupied by approximately 59,000 square feet of commercial land uses included wholesale, warehouse, office and retail land uses. Parking for these uses is provided entirely on site. Because many structures on the site have been demolished and/or are no longer occupied, ample parking exists to serve the parking demand generated by the existing land uses. In addition to on-site parking areas, on-street meter parking is available on the roadways surrounding the Project Site. B. Regulatory Setting The parking requirements for the Project are established by the City of Los Angeles Planning and Zoning Code, Los Angeles Municipal Code (LAMC) Section 12.21(a)(4)(p), Exceptions for Central City Area. In addition to the LAMC requirements, several other planning policies and implementation goals have been drafted to address parking in the downtown area. The applicable code and policies pertaining to the provisions of on-site parking are discussed in further detail below. (1) Los Angeles Municipal Code a. Central City Exceptions LAMC Section 12.21(a)(4)(p), provides an exception to the standard code-parking requirements for the Central City Area. Pursuant to this exception, off-street parking requirements for residential uses require a minimum of one space for each dwelling unit, except where there are more than six dwelling units of more than three habitable rooms per unit on any lot, the ratio of parking spaces required for all such units shall be at least one and one quarter (1.25) parking spaces for each dwelling unit of more than three habitable rooms. For hotel uses Section 12.21(a)(4)(p) of the LAMC requires one space for each two individual guest rooms or suites of rooms for the first 20, one additional parking space for each four guest rooms or suites
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Page 1: IV. ENVIRONMENTAL IMPACT ANALYSIS K.2 PARKING Parking.pdf · City Market of Los Angeles Draft EIR IV.K.2 Parking State Clearinghouse No. 2013021046 Page IV.K.2-5 (a) Bicycle Parking

IV. ENVIRONMENTAL IMPACT ANALYSIS K.2 PARKING

City Market of Los Angeles Draft EIR IV.K.2 Parking State Clearinghouse No. 2013021046 Page IV.K.2-1

1. INTRODUCTION

The information in this section is based primarily on the parking requirements of the Los Angeles Municipal Code (LAMC) and applicable adopted planning polices and ordinances pertaining to onsite parking of vehicles and bicycles, including the parking guidelines of the Downtown Design Guide, and the City’s adopted Bicycle Ordinance.

2. ENVIRONMENTAL SETTING

A. Existing Conditions

The Project Site is currently developed and occupied by approximately 59,000 square feet of commercial land uses included wholesale, warehouse, office and retail land uses. Parking for these uses is provided entirely on site. Because many structures on the site have been demolished and/or are no longer occupied, ample parking exists to serve the parking demand generated by the existing land uses.

In addition to on-site parking areas, on-street meter parking is available on the roadways surrounding the Project Site.

B. Regulatory Setting

The parking requirements for the Project are established by the City of Los Angeles Planning and Zoning Code, Los Angeles Municipal Code (LAMC) Section 12.21(a)(4)(p), Exceptions for Central City Area. In addition to the LAMC requirements, several other planning policies and implementation goals have been drafted to address parking in the downtown area. The applicable code and policies pertaining to the provisions of on-site parking are discussed in further detail below.

(1) Los Angeles Municipal Code

a. Central City Exceptions

LAMC Section 12.21(a)(4)(p), provides an exception to the standard code-parking requirements for the Central City Area. Pursuant to this exception, off-street parking requirements for residential uses require a minimum of one space for each dwelling unit, except where there are more than six dwelling units of more than three habitable rooms per unit on any lot, the ratio of parking spaces required for all such units shall be at least one and one quarter (1.25) parking spaces for each dwelling unit of more than three habitable rooms.

For hotel uses Section 12.21(a)(4)(p) of the LAMC requires one space for each two individual guest rooms or suites of rooms for the first 20, one additional parking space for each four guest rooms or suites

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City of Los Angeles Department of City Planning ENV-2012-3003-EIR June 2015

City Market of Los Angeles Draft EIR IV.K.2 Parking State Clearinghouse No. 2013021046 Page IV.K.2-2

of rooms in excess of 20 but not exceeding 40, and one additional parking space for each six guest rooms or suites of rooms in excess of 40.

(2) Downtown Design Guide

The Downtown Design Guide, which supplement the LAMC, apply to all new development projects downtown, except that the provisions of an adopted Specific Plan, Streetscape Plan, Design For Development, or other regulations as determined by the reviewing agency, shall take precedence over these guidelines. Section 7, Circulation, Parking and Loading sets forth guidelines that pertain either directly or indirectly to the Project. The specific guidelines and policies identified in Section 7 of the Downtown Design Guide are addressed in the project consistency analysis under the Project Impacts subheading later in this Section.

(3) Downtown Parking Management Ordinance Implementation Project

The Downtown Parking Management Ordinance Implementation Project (“Implementation Project”) encompasses the 15 districts or subareas that make up the core of Downtown and adjacent neighborhoods and is intended to guide the development of new parking policies and programs for Downtown Los Angeles. The Implementation Project was initiated through a coordinated effort by and among the City of Los Angeles Community Redevelopment Agency (CRA/LA), the Department of Transportation (LADOT), the Department of City Planning, and included significant funding support from the Los Angeles County Metropolitan Transportation Authority (MTA).

The objective of the Implementation Project is to create a broader “parking policy framework” that will supersede the peripheral parking mandate as currently written and adopted in the 1980’s. This framework includes programs and initiatives to better manage on-street and off-street parking resources. The Implementation Project focuses on on-street parking, off-street parking, transit and other alternative modes, and parking management organization issues. It focuses on developing a comprehensive transportation program that best uses parking resources while improving access to and mobility in Downtown Los Angeles. Based upon their relative accessibility, land uses, and parking supply the downtown districts would be subject to three levels of parking requirements.

1. Historic Transit Core – These areas have the highest transit accessibility parking and would require the least amount of parking.

2. Multimodal Destination Districts – These areas also have high transit accessibility but tend to have more parking needs than the historic core districts. The parking requirement would be higher than in the historic core districts.

3. Adjacent Neighborhoods – These districts have less transit access than the rest of the downtown, and generally require more parking.

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City of Los Angeles Department of City Planning ENV-2012-3003-EIR June 2015

City Market of Los Angeles Draft EIR IV.K.2 Parking State Clearinghouse No. 2013021046 Page IV.K.2-3

As shown in Figure IV.K.2-1, P Downtown Parking Management Ordinance Implementation Project – Downtown Parking Overlay Zones, the Project Site is located within the Multimodal Destination District. The parking provisions identified for the Multimodal Destination District are summarized in Table IV.K.2-1, Downtown Parking Overlay Ordinance Approach, below.

Table IV.K.2-1 Downtown Parking Overlay Ordinance Approach

Land Uses Neighborhoods and Multimodal Destination Districts

Parking Approach

Freestanding Parking Permitted. No restrictions on use, subject to traffic impact analysis of impact of added parking. Requires CUP.

Replacement of existing parking resources when development occurs

Replacement of existing parking on a site is permitted but up to discretion of the developer. Exception is that covenants that have been sold to other property owners must be replaced. LA/CRA may negotiate replacement parking as part of voluntary conditions.

Commercial development

Office: Minimum is 0.6 spaces per 1,000 square feet. Bundling of office space and parking prohibited; cash out of parking subsidies required. Warehouse: Minimum is 0.3 spaces per 1,000 square feet. Retail and restaurant greater than 7,500 square feet: 1 space per 1,000 square feet (destination-oriented). No minimum for retail or restaurant less than 5,000 square feet.

Residential development

Residential: Minimum is 0.5 spaces per unit for studio units and 1.0 space per unit for all other units. Bundling of rent and parking spaces prohibited. Guestroom: Minimum is ½ per room for first 20, 1/6 per room for next 20 rooms, and 1/8 per room for remainder.

Source: Downtown Parking Management Ordinance Implementation Project (Table 2), May 2007.

(4) Bicycle Ordinance

In January 2013, the City of Los Angeles City Council adopted the Bicycle Ordinance (Ordinance No. 182,386), establishing citywide standards for bicycle parking requirements in new developments. The Bicycle Ordinace became effective in March 2013. The following summarizes the provisions of the Bicycle Ordinance that are applicable to the Project:

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Figure IV.K.2-1Downtown Parking Management Ordinance Implementation Project

Downtown Parking Overlay Zones

Source: Downtown Parking Management Ordinance Implementation Project, May 2007. [Map by City of Los Angeles Department of City Planning, GIS Division, January 2006.

Project Site

NOT TO SCALE

Metro Blue LineMetro Gold LineMetro Gold Line ExtensionMetro Red LineProposed Expo LineMetro LinkMetro Rapid BusMetro stopsMetrolink stopsBus stops

Adjacent NeighborhoodsMultimodal Destination DistrictsHistoric Transit Core

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(a) Bicycle Parking and Shower Facilities.

Parking spaces for bicycles and facilities for employee showers and lockers shall be provided for new development and additions that increase the floor area of a building as follows:

Residential

For all residential buildings containing more than three dwelling units or more than five guest rooms, long-  and short-term bicycle parking shall be provided. Long-term bicycle parking shall be provided at a rate of one per dwelling unit or guest room. In addition, short-term bicycle parking shall be provided at a rate of one per ten dwelling units or guest rooms. In such cases, a minimum of two short-term bicycle parking spaces shall be provided.

Commercial, Institutional, and Industrial Uses

For all commercial, institutional, and industrial uses that require automobile parking under Subsections 12.21.A.4(c), (d), (e), and (f), short- and long-term bicycle parking shall be provided as per Table 12.21.A.16(a)(2). For uses listed in Table 12.21.A.16(a)(2) a minimum of 2 short-term and 2 long-term bicycle parking spaces shall be provided. After the first 100 bicycle parking spaces are provided for uses listed in Table 12.21.A.16(a)(2), additional spaces may be provided at the minimum required by the Los Angeles Green Building Code Article 99.05.106.4.

3. ENVIRONMENTAL IMPACTS

A. Thresholds of Significance

(1) Appendix G of the CEQA Guidelines

Appendix G of the CEQA Guidelines does not provide any guidance with respect to establishing a threshold of significance for parking.

(2) LA CEQA Thresholds Guide

Pursuant to the screening criteria of the LA CEQA Thresholds Guide further study in an EIR is warranted if a project’s parking supply is less than that required by Code, including the LAMC, a Transportation Specific Plan (TSP), or Interim Control Ordinance (ICO), prior to applying for a variance, an exemption, or amendment if any apply to the Project.

For purposes of this analysis, the Project would be considered to have a significant impact with regard to parking if the parking requirements of the Los Angeles Municipal Code (LAMC), and/or other planning policies that address parking in the project area are not met, or if the anticipated parking demand, as estimated through an appropriate analysis for the project, is not met by the supply of available on-site parking spaces.

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City of Los Angeles Department of City Planning ENV-2012-3003-EIR June 2015

City Market of Los Angeles Draft EIR IV.K.2 Parking State Clearinghouse No. 2013021046 Page IV.K.2-6

B. Project Impacts

(1) Construction Impacts

Construction activities in urban areas have the potential to increase demands for off-street parking which could also adversely impact traffic and circulation patterns in local neighborhoods. Construction of the Project is anticipated to be built out over a 20-year period and would involve the development of approximately 1,699,173 square feet over approximately 10-acres on four development blocks. Due to the size of the Project Site and the configuration of existing buildings and vacant areas, it is anticipated that construction parking and staging of vehicles would be accommodated on site and would not impact adjacent properties or adversely affect the on-street parking supply on local street segments. As the project is built out, and vacant or underutilized areas are replaced by new development, the availability of on-site parking for construction workers would likely become more limited. As such, a project-specific Construction Parking Plan would need to be prepared and implemented by the Applicant to coordinate designated parking areas for construction workers. The Construction Parking Plan would designate parking locations for construction workers within the Project Site or provide parking at alternative locations in the project vicinity. The implementation of a Construction Parking Plan would ensure construction workers would be able to park in a designated area and would not adversely affect the availability of on-street parking in the adjoining neighborhood. With mitigation, parking impacts during construction would be reduced to less-than-significant levels.

(2) Operational Impacts

As discussed in Section II, Project Description, one of the stated project objectives is to establish uniform development standards and criteria for the mix of land uses, bulk/height, parking and loading, architectural features, landscape treatment, signage, lighting, and sustainability, that promote the long-term development of the Project Site within the larger neighborhood context. As shown in Figure II-10, Below Grade Plan, in Section II, Project Description, on-site parking would largely be provided in subterranean parking garages beneath each development site and at the podium level above the ground floor retail spaces. The proposed location of project driveways to access the parking garages is shown in Figure IV.K-15 in Section IV.K.1, Transportation and Traffic.

As shown in Table IV.K.2-2, below, the parking program for the entire unified development would include approximately 3,671 parking spaces, with approximately 2,428 spaces on Block 1, 1,049 spaces on Block 2, 83 spaces on Block 3, and 111 spaces on Block 4. A summary of the parking supply by block is presented in Table IV.K.2-2, Parking Summary by Block, on page IV.K.2-7.

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City of Los Angeles Department of City Planning ENV-2012-3003-EIR June 2015

City Market of Los Angeles Draft EIR IV.K.2 Parking State Clearinghouse No. 2013021046 Page IV.K.2-7

Table IV.K.2-2 Proposed Parking Summary by Block

Block Parking Supply Block 1 2,428 Block 2 1,049 Block 3 83 Block 4 111

TOTAL 3,671 Source: The Mobility Group, October 7, 2013

a. Los Angeles Municipal Code

As discussed under the Environmental Setting Section above, the parking requirements for the Project are controlled by LAMC Section 12.21.4. The Project Site is located within the Los Angeles Enterprise Zone: Central Los Angeles Portion, which allows for reduced parking rates per LAMC Section 12.21A.4(x)(3)6. LAMC Section 12.21A(p)(1) also provides an exception for the Central City Area for reduced residential and hotel parking requirements. The appropriate rates were used as applicable in calculating the amount of code required parking necessary for the proposed land uses. A summary of the proposed parking by land use type in relation to the LAMC parking requirements is presented in Table IV.K.2-3, Proposed Parking Summary by Land Use, on page IV.K.2-8. As shown in Table IV.K.2-3, the Project would provide sufficient parking to meet the parking code requirements for the individual land uses being proposed. The LAMC would require a total of 3,080 total parking spaces for the proposed land uses. The Project proposes to provide approximately 3,671 spaces. Since the Project will provide 591 more spaces than is required, the Project will provide enough parking spaces to meet the City Code.

As a mixed-use unified development, the Project proposes to provide on-site parking in accordance with the programming and arrangement of the proposed land uses and building types for each development Block. As such, parking for some uses may not be provided on the same development Block that the land use is located on. As shown in Table IV.K.2-2, Proposed Parking Summary By Block, the Project will provide enough parking to meet LAMC parking code requirements for all blocks except Block 2, where the proposed supply of 1,049 would be 149 less than required by the LAMC. However, the Project would provide 675 more spaces than required by the LAMC in Block 1, and would exceed the LAMC parking requirements overall. This arrangement is consistent with the provisions of LAMC Section 12.21 A.(4)(g), which states that:

“the automobile parking spaces required shall be provided either on the same lot as the use for which they are intended to serve or on another lot located within 750 feet of the lot; said distance shall be measured horizontally along the streets between the two lots, except that where the parking area is located adjacent to an alley, public walk or private easement which is easily usable for pedestrian travel between the parking area and the use it is to serve, the 750-foot distance may be measured along said alley, walk or easement.”

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City of Los Angeles Department of City Planning ENV-2012-3003-EIR June 2015

City Market of Los Angeles Draft EIR IV.K.2 Parking State Clearinghouse No. 2013021046 Page IV.K.2-8

Table IV.K.2-3 Proposed Parking Summary by Land Use

Land Use Quantity (sf) Parking Requirement

Spaces Required

Spaces Proposed

Education Education areas Assembly (500 Seats)

Subtotal

312,112

312,112

2 spaces / 1,000 sf a

1 space / 5 seats

624 100 724

725

Retail/Entertainment Retail Wholesale Grocery Specialty Retail Restaurant (Quality Sit-Down) Restaurant (High Turnover) Restaurant (Fast Food) Cinema (744 seats) Nightclub

Subtotal

60,069 15,346 25,810 12,939 27,413 26,430 4,186

37,180 15,489

224,862

2 spaces / 1,000 sf a 2 spaces / 1,000 sf a 2 spaces / 1,000 sf a 2 spaces / 1,000 sf a 2 spaces / 1,000 sf a 2 spaces / 1,000 sf a 2 spaces / 1,000 sf a 1 space / 5 seats b

2 spaces / 1,000 sf a

120 31 52 26 55 53 8

149 31

525

662

Residential (Multi-family) Lofts 1 Bedrooms 2 Bedrooms 3 Bedrooms

Subtotal

68

526 263 88

945

1 space / Dwelling Unit c 1 space / Dwelling Unit d 1 space / Dwelling Unit d

1.25 space / Dwelling Unit d

68

526 263 110 967

1,168

Hotel Rooms 1-20 Rooms 21-40 Rooms 41 +

Subtotal

20 20

170 210

1 space / 2 rooms c 1 space / 4 rooms c 1 space / 6 rooms c

10 5

28 43

111

Office General Office Medical Office

Subtotal

217,377 77,264

294,641

2 spaces / 1,000 sf a 5 spaces / 1,000 sf e

435 386 821

1,005

TOTAL 1,699,173 3,080 3,671 Notes: a LAMC Enterprise Zone Exception: Section 12.21A.4(x)(3)(6). b LAMC Section 12.21A.4(e). c LAMC Enterprise Zone Exception: Section 12.21A.4(p)(2). d LAMC Enterprise Zone Exception: Section 12.21A.4(p)(1). e LAMC Enterprise Zone Exception: Section 12.21A.4(d)(3). Source: The Mobility Group, 2013.

Since the Project’s parking supply will considerably exceed the LAMC parking requirements, and the location of the parking areas would conform to the provisions of the code, no significant parking impacts with respect to compliance with the LAMC would occur.

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City of Los Angeles Department of City Planning ENV-2012-3003-EIR June 2015

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(b) Downtown Design Guide

The Project would be substantially consistent with the policies and provisions of the Downtown Design Guide as it pertains to parking. Table IV.K.2-4 provides a Project consistency/conformity analysis for the parking-related guidelines and policies of the Downtown Design Guide. In general, the project would be in substantial compliance with the intent of the Guide.

Table IV.K.2-4 Project Consistency Analysis with the Downtown Design Guidelines

Policy/Guideline Project Consistency Analysis A. All Parking and Access Locate parking, loading and vehicular circulation to minimize its visibility. 1. Parking required for a project shall be integrated into the project it serves. Public parking may be either a freestanding structure or integrated into a project, provided it is clearly signed as public parking.

Consistent. The Project proposes to meet or exceed the minimum amount of code-required parking spaces on site. Parking will be provided within four development Blocks that comprise the Project Site. The proposed parking structures will be available to the general public, as the project includes a number of public retail, entertainment and commercial office land uses.

2. Except for the minimum ground-level frontage required for access to parking and loading, no parking or loading shall be visible on the ground floor of any building façade that faces a street.

Consistent. The Project does not propose any parking to be provided on the ground floor for the proposed new uses. Currently the site is improved with several at-grade parking areas that are clearly visible at the street level. These parking areas will remain in use to serve the existing and proposed new development; however, they will eventually be phased out and replaced with new structures. Loading areas will be located interior to the project site and alleys and will not face the public view.

3. Parking, loading or circulation located above the ground floor shall be 1) lined by habitable floor area along all street frontages or, 2) if the project sponsor demonstrates that it is not feasible to line the parking with habitable space above the ground floor, integrated into the design of the building façade.

Consistent. The proposed Development Regulations provide guidelines and standards to ensure parking areas above the ground floor are lined by active habitable floor area and/or integrated into the design of the architecture and building to shield parking areas from the public view.

4. Where parking above the ground floor that is not lined with habitable space is permitted, a maximum of three parking levels fronting on a public street shall be allowed above the ground floor, provided they are integrated into the design of the building façade and at least one habitable floor is provided directly above the visible parking levels.

Not Consistent. The project proposes a ten story parking structure on Block 2 fronting San Pedro Street to serve the proposed commercial office and retail/entertainment land uses. While this stand alone structure is not consistent with this guideline, the parking areas will be screened from public view by architectural façade treatments, signage components, and/or green screens.

5. Drive-through aisles for fast food or similar use are not permitted.

Consistent. No drive-through isles are proposed.

Locate drop-off zones along the curb or within parking facilities to promote sidewalk/street wall continuity and reduce conflicts with pedestrians. 6. Drop-off, including residential, hotel and restaurant drop-off, shall be provided either 1) within the off-street

Consistent. Drop off zones for the residential and hotel uses would be provided off of San Julian

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Policy/Guideline Project Consistency Analysis parking facilities using the parking access or 2) along the required curb line where there is a full-time curbside parking lane, with no sidewalk narrowing. Exception: where there is no curbside parking lane and off-street drop-off is not feasible, a hotel may have a drop-off lane up to 80 feet long provided the required sidewalk width is maintained.

Street. The proposed Design Guidelines include provisions to ensure drop off areas are provided either within the off-street parking facilities using the parking access or along the required curb line where there is a full-time curbside parking lane, with no sidewalk narrowing.

Encourage the use of alternate modes of transportation by providing incentives for reduced automobile use. 7. No more than the minimum required parking may be provided unless provided for adjacent buildings that lack adequate parking.

Consistent. The Project proposes to meet the minimum code requirements and may provide a surplus to ensure the parking demand for the Project is met on site. Additional parking above the code-required minimum would be limited to that necessary to accommodate the Project’s anticipated demand and would not be intended to serve off-site uses.

8. Parking shall be sold or rented separately from residential units and commercial spaces (“unbundled”) in perpetuity. Parking that is required for residential use but is unused and all commercial parking should be made available as public parking during daytime and evenings.

Consistent. The parking for the proposed residential uses will be unbundled and will be leased separate and apart from the proposed residential land uses.

9. Provide at least one secure bicycle parking space for every two residential units. Provide secure bicycle parking within 200 yards of a building entrance for at least 10% of commercial and institutional building occupants.

Consistent. The Project will be consistent with this guideline. Based on the 949 residential dwelling units being proposed, the Project will be required to provide 475 bicycle parking spaces on-site. The Project includes secured bicycle parking areas for the residential and commercial land uses. All bicycle parking will be provided within 200 yards of the main building entrance it is intended to serve.

Limit the number and width of curb cuts and vehicular entries to promote street wall continuity and reduce conflicts with pedestrians. 10. Vehicular access shall be from an alley or mid-block on an east-west street where feasible.

Consistent. As shown in Figure IV.K-15, Project Site and Proposed Access Locations, in Section IV.K, Transportation and Traffic, access to parking would be provided on 9th, 11th and 12th Street, which are all east-west trending streets at 7 of the 14 access points. However, due to the long north-south trending shape of the approximate 10-acre Project Site, it is impractical and infeasible to provide all of the ingress/egress driveways from the east/west trending streets. Nevertheless the access plan is consistent with the use of accessways from east west streets.

11. Curb cuts and parking/loading entries into buildings shall be limited to the minimum number required and the minimum width permitted.

Consistent. The project will be consistent with this guideline and will conform to the LADOT guidelines for driveway entries and curb cuts.

12. Parking and loading access shall be shared where feasible.

Consistent. The project will provide shared access for parking and loading areas.

13. Parking and loading access shall be located a minimum of 25 feet from a primary building entrance, pedestrian paseo, or public outdoor gathering area. This

Not Consistent. Due to the size of the Project Site and the integration of a range of different land uses at varying heights and levels within the development,

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Policy/Guideline Project Consistency Analysis guideline shall not apply to a hotel porte cocheres. it is not practical to provide parking within 25 feet of

all land use building entrances. Parking will be integrated into the site to access public open spaces and building entrances in a manner that is convenient and ADA accessible.

14. Where a vehicular exit from a parking structure is located within 5 feet of the back of sidewalk, a visual/ audible alarm shall be installed to warn pedestrians and cyclists of exiting vehicles.

Consistent. The Project will be designed in conformance with this guideline.

B. Stand-Alone Parking Structures Architectural Treatment Parking structures should exhibit the same principles as good building design noted in previous sections. Providing an exterior screen comprised of high quality materials that screen the underlying concrete structure can elevate the building’s stature and contribute to the overall quality of Downtown’s built landscape.

Consistent. As provided in the Project Design Guidelines, parking structures would be designed to be integrated with the architectural character of the surrounding buildings with façade treatments, photovoltaic panels, signage elements, and green screens to minimize the appearance of concrete parking structures.

1. Parking structures shall have an external skin designed to improve the building’s appearance over the basic concrete structure of ramps, walls and columns. This can include heavy-gage metal screen, pre-cast concrete panels, laminated glass or photovoltaic panels.

Consistent. As provided in the Project Design Guidelines, parking structures would be designed to be integrated with the architectural character of the surrounding buildings with façade treatments, photovoltaic panels, signage elements, and green screens to minimize the appearance of concrete parking structures.

2. Parking structures should integrate sustainable design features such as photovoltaic panels (especially on the top parking deck), renewable materials with proven longevity, and stormwater treatment wherever possible.

Consistent. Sustainable design features such as photovoltaic panels, renewable materials with proven longevity will be integrated into the design of the Project. Stormwater treatment, retention and infiltration will be implemented in accordance with the LID Ordinance. (See Section IV.F, Hydrology)

3. Vertical circulation cores (elevator and stairs) shall be located on the primary pedestrian corners and be highlighted architecturally so visitors can easily find and access these entry points.

4. Treat the ground floor along public streets as specified in Section 4: on Retail Streets provide active ground floor uses along the street frontage of the garage; on all other streets the ground floor treatment should provide a low screening element that blocks views of parked vehicle bumpers and headlights from pedestrians using the adjacent sidewalk.

Consistent. The Project is substantially consistent with this guideline as the Project includes active ground floor uses along the street frontages of the Project. Any parking garages at the ground floor would provide a low screening element that blocks views of parked vehicle bumpers and headlights from pedestrians using the adjacent sidewalk.

5. Signage and wayfinding should be integrated with the architecture of the parking structure.

Consistent. The Project includes a signage plan that would provide for a unified program of way-finding and identity signage throughout the development.

6. Integrate the design of public art and lighting with the architecture of the structure to reinforce its unique identity. This is especially important for public parking structures to aid in visitors finding them upon arrival and getting oriented to Downtown.

Consistent. Public art, signage and lighting will be provided in a manner that promotes the Project’s unique identity as a vibrant mixed-use project with retail, hotel, commercial retail/entertainment, office, and educational/institutional land uses.

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Policy/Guideline Project Consistency Analysis 7. Interior garage lighting should not produce glaring sources towards adjacent residential units while providing safe and adequate lighting levels per code.

Consistent. As discussed in Section IV.A.1-1, Aesthetics (Views/Light and Glare), mitigation measures have been recommended to ensure Project lighting and illumination does not spill onto adjacent land uses. Lighting standards will be compliant with standard code provisions that regulate lighting levels.

Landscape Treatment 8. In most circumstances, streetscape and landscaping should complement the building design. If a parking structure is well-designed, it does not need to be screened by dense landscaping in an urban setting.

Consistent. The Project proposes a uniform landscape plan to link open space areas and pedestrian linkages throughout the development. The landscape plan will be designed to complement the building’s architectural and design elements.

9. However, where the Reviewing Agency determines that conformance with the architectural design standards and guidelines in 5.A. is not feasible, an unattractive parking structure may be screened with landscaping.

Consistent. This provision allows for the screening of parking structures with landscaping.

10. A “green screen” that is coordinated with the building design may be provided, along with the required streetscape improvements.

Consistent. The project will be consistent with this guideline as green screens may be integrated into the architecture of the proposed building facades and parking structures to minimize expansive blank walls and improve the aesthetics of the project.

11. Alternatively, an additional row of evergreen columnar trees may be provided in a minimum 8-foot wide setback and staggered with the street trees. In combination, the setback and street trees should screen the parking structure from view.

Consistent. This guideline provides additional options with respect to landscaping features to screen parking structures and will be considered during the final phases of the project design.

C. Alleys And Building Walls Facing Alleys Maintain and enhance alleys. 1. No existing alley shall be vacated unless 1) vehicular access to the project is provided only at the former intersection of the alley with the street; 2) vacating the alley will not result in the need for additional curb cuts for other parcels on the same block; and 3) an east-west pedestrian paseo at least 20 feet wide will be provided in the middle third of the block as part of the project.

Consistent. The Project proposes to vacate the mid-block alley between 11th Street and 12th Street on Block 2. The vacated alley will be maintained and will not require additional curb cuts for access. East west access will also be provided from the alley to San Pedro Street and San Julian Street at several points between 11th and 12 Street.

2. As a general rule, Downtown alleys shall not be gated. Existing gates shall be removed where feasible.

Consistent. The Project does not propose to gate the alley.

Use alleys primarily for vehicular access, loading and service. 3. The primary purpose of most Downtown alleys is vehicular access and loading. The exceptions are “pedestrian-priority” alleys as designated as “pedestrian-priority” alleys by the Reviewing Agency. Pedestrian-priority alleys typically are located in the City Markets district.

Consistent. The Project is within the City Market subarea and includes a pedestrian-priority alley on Block 2. This alley will be vacated but will remain a pedestrian oriented alley for the purposes of linking various land uses that are proposed as party of the Project’s mixed-use development.

4. Access to parking shall be from an alley where one exists or can be provided.

Consistent. As shown in Figure IV.K.1-15, the Project includes accessways from the alleys on Blocks 2, 3 and 4.

5. Where there is no alley and the project includes Consistent. Blocks 1 is the only Block that does not

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Policy/Guideline Project Consistency Analysis frontage on an east-west street, parking access shall be located mid-block on the east-west street.

contain an alley. The Project will provide parking in subterranean parking garages on Block 1, which will be accessed from several mid-block driveways, one of San Julian Street, 3 on San Pedro Street and 2 points on 9th Street.

Provide access to utilities and mechanical equipment from alleys. 6. Electrical transformers shall be located to be accessed from an alley where one exists or can be provided. If located adjacent to a sidewalk, they shall be screened and incorporated into the building to read as a storefront or office.

Consistent. The Project has not been designed to this level of detail at this stage in the planning process. However, it is anticipated that the project will comply with this guideline to the satisfaction of the Department of Building and Safety.

Design building walls that face alleys to be attractive those who see them. 7. While they can be more simply designed than street-facing façades, building walls that face alleys nonetheless should be visually attractive.

Consistent. The Project is designed with frontages along the alley and interior building spaces.

8. Parking levels may be visible but should be designed to alleviate the horizontality and lack of articulation and to screen lighting from the public rights-of-way and surrounding residential units, as described in the prior discussion of free-standing parking structures.

Consistent. The Project has not been designed to this level of detail at this stage in the planning process. However, it is anticipated that the project will integrate the parking areas into the architecture of the buildings and provide screening components to block the light and glare from vehicles from impacting residential uses.

Ensure that residents are not adversely affected by the use of alleys for parking access, service and loading. Urban downtown environments typically experience higher ambient sound levels than, for example, suburban residential neighborhoods due to traffic on streets and alleys, street activity and commercial ground-floor uses. 9. Each home buyer and renter in the Downtown shall sign a statement acknowledging that: • Sound levels may be higher than in other locations due to traffic on streets and alleys, street activity, ground floor uses, vehicular loading, and trash collection; • There will be additional development all around them; • Alleys will be used as the primary access to all parking in the Downtown and for loading, utilities and trash collection.

Consistent. The Project will be required to ensure all renters sign a disclosure statement addressing the ambient noise levels commonly attributable to vehicles in alleys and parking structures. (See Section IV.H, Noise)

10. Residential units shall not be located on the ground floor adjacent to alleys in order to reduce light, glare, and noise concerns.

Consistent. The residential uses proposed on Blocks 1, 2 and 3 would be located above the ground floor level. The ground floor level would be developed with neighborhood serving retail uses and structured parking.

11. Residential units shall be designed to maintain interior sound levels, when windows are closed, at below 45 dB. Because the exterior sound level may exceed 60 dB, measures in addition to conventional construction are suggested to meet the interior standard, including: • Use of ¼” laminated or double glazing in windows • Installation of rubberized asphalt in the alleys. • Incorporate green elements in alleys.

Consistent. The Project will be required to ensure and acceptable indoor noise environmental for all residential use. An interior noise level of 45 dBA is a requirement for residential units and compliance with this standard will be verified at the time the certificate of occupancy is issued by the Department of Building and Safety. (See Section IV.H, Noise)

12. Subject to approval by BOE, install permeable paving to infiltrate storm water and eliminate standing

Consistent. The Project will be developed in accordance with all applicable LID Ordinance

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Policy/Guideline Project Consistency Analysis water. requirements with respect to stormwater retention,

infiltration and treatment. (See Section IV.F, Hydrology/Water Quality.

Source: Policies and Guidelines are from the Downtown Design Guide, June 16, 2009.

(c) Los Angeles Downtown Parking Management Ordinance Implementation Project

The Project would be consistent with the Los Angeles Downtown Parking Management Ordinance Implementation Project. The Implementation Project provides for reduced minimum parking requirements as compared to the rates provided by the LAMC. For residential development, the Implementation Project recommends a minimum of 0.5 spaces for studio units and 1 space per unit for all other units. This recommendation would reduce the code required parking for the residential units from 967 spaces (per the LAMC) to 911 spaces. With respect to the retail and entertainment uses, the recommendation of the Implementation Project would reduce the amount of code-required parking spaces from 525 spaces to 224 spaces. The amount of office parking would be reduced from 821 spaces to 176 spaces. The parking spaces for the education and hotel uses would be provided by the code as no reductions are identified in the Implementation Project for these land uses. In total, the Implementation Project would reduce the amount of code-required spaces of 3,080 to 2,078 spaces. However, the Project is proposing to provide parking to meet the anticipated market demand and is not seeking further parking reductions below the code minimum. Thus, the Project would thus be consistent with this policy and no impact would occur.

(d) Bicycle Parking

The Project will be developed in substantial compliance with the Bicycle Ordinance. The Project proposes to provide bicycle storage areas within the subterranean parking garages and at various locations on the street level. As stated previously, the Bicycle Ordinance amended the LAMC’s off street automobile parking requirements to allow the number of required parking spaces for all uses to be replaced by bicycle parking at a ratio of one automobile parking space for every four bicycle parking spaces provided. Based on the approximately 3,671 parking spaces proposed, the Project would be eligible to replace up to 734 parking spaces at a ratio of 4 bicycle parking spaces for each automobile parking space being replaced. While the Project maintains to provide parking to meet the code without this provision, it remains an option as the project is built out on a Block-by-Block basis.

In addition to the above, the Bicycle Ordinance requires short-term and long-term bicycle parking spaces to be provided on-site based on the type of development being proposed. For all residential uses, bicycle parking shall be provided at a rate of one long-term bicycle space per dwelling unit and one short-term bicycle space per every ten dwelling units for residential uses. For commercial land uses, the bicycle

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parking requirements for specified land uses are identified in Table 12.21 A16(a)(2) of the LAMC. As summarized in Table IV.K.2-5, Required Bicycle Parking by Land Use, below, the Project would require a minimum of 868 short-term parking spaces and 1,429 long-term parking spaces in order to comply with the LAMC. The Project will comply with the provisions of the Bicycle Ordinance and will provide the required number of bicycle parking spaces based on the land uses provided. Therefore, impacts associated with bicycle parking would be less than significant.

Table IV.K.2-5 Required Bicycle Parking Summary by Land Use

Land Use Quantity (sf)

Short-Term Bicycle Parking

Long Term Bicycle Parking

Rate Spaces Rate Spaces Education Education areas Assembly (500 Seats)

Subtotal

312,112

312,112

1 space/500 sf

1 space/50 seats

624 10

634

1 spaces/1,000 sf 1 space/100 seats

312

5 317

Retail/Entertainment Retail Wholesale Grocery Specialty Retail Restaurant (Quality Sit-Down) Restaurant (High Turnover) Restaurant (Fast Food) Cinema (744 seats) Nightclub

Subtotal

60,069 15,346 25,810 12,939 27,413 26,430 4,186

37,180 15,489

224,862

1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf

1 space/10,000 sf 1 space/2,000 sf

30 8

13 6

14 13 2 4 8

98

1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf 1 space/2,000 sf

1 space/10,000 sf 1 space/2,000 sf

30 8

13 6

14 13 2 4 8

98 Residential (Multi-family) Lofts 1 Bedrooms 2 Bedrooms 3 Bedrooms

Subtotal

68

526 263 88

945

1 space / 10 DUs 1 space / 10 DUs 1 space / 10 DUs 1 space / 10 DUs

7

53 26 9

95

1 space / DU 1 space / DU 1 space / DU 1 space / DU

68

526 263 88

945 Hotel

Subtotal 210 210 1 space / 20 rooms 11 1 space / 20 rooms 11

Office General Office Medical Office

Subtotal

217,377 77,264

294,641

1 space/10,000 sf 1 space/10,000 sf

22 8

30

1 space/5,000 sf 1 space/5,000 sf

43 15 58

TOTAL 1,699,173 868 1,429 Source: The City of Los Angeles Bicycle Code (Ord. 182,386), Effective March 2013.

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4. CUMULATIVE IMPACTS

Development of the Project in conjunction with the related projects identified in Section III, Environmental Setting of this Draft EIR, would increase the parking demand in the Central City Community Planning area and Fashion District area in which the Project is located. The Project would meet the residential, office, educational, hotel and commercial retail/entertainment parking requirements as outlined in the analysis presented above. With mitigation, construction impacts would be reduced with respect to potential impacts associated with the loss of street parking during construction, and construction worker parking. The Project is anticipated to provide all of the Project’s parking demand on-site and thus would not contribute to increased demands for parking in the surrounding neighborhood.

Furthermore, development of each of the related projects would be subject to all applicable parking requirements as outlined by the LAMC and the City Planning Department Deputy Advisory Agency, and would be evaluated on a case by case basis considering the demand and availability for parking in the surrounding neighborhoods. Therefore, the Project’s parking impacts would not be cumulatively considerable and would therefore result in a less than significant cumulative impact with respect to parking.

5. PROJECT DESIGN FEATURES

PDF K.2-1: Parking for the Project will be provided in accordance with the LAMC requirements, except where otherwise stated within the Development Regulations. On-site parking will be located underground throughout the site and at the podium above the retail. Service and loading dock access will be accommodated by using existing alleys and internal ground level service streets.

6. REGULATORY COMPLIANCE MEASURES

CM K.2-1: Bicycle parking shall be provided in accordance with the Bicycle Ordinance (Ordinance No. 182,386) for all residential, commercial and institutional land uses.

7. MITIGATION MEASURES

MM K.2-1 No sidewalk in the pedestrian route along a public right-of-way shall be closed for construction unless an alternative pedestrian route is provided that is no more than 500’ greater in length than the closed route.

MM K.2-2 Prior to commencing construction on any one Block the Project Applicant shall develop a Construction Parking Plan identifying designated construction parking and equipment staging areas on-site. In the event a sufficient number of construction parking spaces cannot be accommodated on-site, the Applicant shall procure off-site parking at an alternative location in the Project vicinity to ensure an adequate supply of off-street parking spaces is available.

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Employees and subcontractors shall not be allowed to park on surrounding streets for the duration of all construction activities.

8. LEVEL OF SIGNIFICANCE AFTER MITIGATION

With mitigation, construction-related parking impacts would be mitigated to less than significant levels. For long-term operational parking, the Project would meet the minimum Code requirements for on-site parking, and therefore, the level of impact would be less than significant prior to mitigation. Thus, no operational parking mitigation measures are required.


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