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Responses to comments and comments to Casden Sepulveda comments up to PH

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Responses to Letters in support, opposition, and general comments and concers for the Casden Sepulveda Project for CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR
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Attachment A
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Page 1: Responses to comments and comments to Casden Sepulveda comments up to PH

Attachment A

Page 2: Responses to comments and comments to Casden Sepulveda comments up to PH

11990 West San Vicente Boulevard, Suite 200

Los Angeles, CA 90049 Phone 310-469-6700 Fax 310-806-9801

December 19, 2012

Henry Chu, Hearing Officer Los Angeles Department of City Planning 200 North Spring Street, Room 750 Los Angeles, CA 90021

Re: Responses to Comments Received after the Draft EIR Review Period

Dear Mr. Chu:

CAJA Environmental Services (CAJA) reviewed all of the comment letters (see Attachment A) received after the close of the Draft EIR public review period to ensure that all CEQA related issues were addressed in the Draft EIR and/or Final EIR and to provide further clarification where needed. Responses to the comment letters are attached to this memo. As you will see, most comment letters are a single-page and raise the same or substantially similar comments to those raised during the Draft EIR public review period. For these comment letters, the commenter is referred to the relevant responses to comments in the Final EIR. A few letters (such as Murdock, Reznik, and Tippit) are lengthier, and for these comment letters, the individual comments have been delineated and numbered. Additionally, two Topical Responses were prepared to address recurring comments about “spot zoning” and “emergency response/access.” Based on our review of the comment letters, no additional CEQA-related issues were raised that have not already been addressed in the Draft EIR and Final EIR. If you have any questions regarding this issue or required additional information, do not hesitate to contact me at (310) 469-6700 or at [email protected]. Thank you. Sincerely, Kerrie Nicholson Senior Project Manager

Page 3: Responses to comments and comments to Casden Sepulveda comments up to PH

Topical Responses

1. Spot Zoning

Comments were submitted asserting that approval of the Development Project (and requested zone change) would constitute illegal “spot zoning.” First, this is simply wrong as a matter of California law because the requested zone change simply does not constitute “spot zoning.” As the Court recently held in Avenida San Juan Partnership v. City of San Clemente 201 Cal.App.4th 1256, 1268-1269, 135 Cal.Rptr.3d 570, 579 - 580 (Cal.App. 4 Dist., 2011):

The essence of spot zoning is irrational discrimination. Arcadia Development Co. v. City of Morgan Hill (2011) 197 Cal.App.4th 1526, 1536, 129 Cal.Rptr.3d 369 (Arcadia Development) described spot zoning: “Spot zoning occurs where a small parcel is restricted and given lesser rights than the surrounding property, as where a lot in the center of a business or commercial district is limited to uses for residential purposes thereby creating an ‘island’ in the middle of a larger area devoted to other uses.... Usually spot zoning involves a small parcel of land, the larger the property the more difficult it is to sustain an allegation of spot zoning...”

In the context of the Development Project, of course, precisely the opposite is the case. In the case of the Development Project, additional uses are being permitted on the parcel in question. As the California Supreme Court held in Wilkins v. City of San Bernardino, 29 Cal. 2d 332, 341 (1946), such determinations are “clearly within the discretion of the legislative body of the city.” Moreover, even “spot” zoning, which discriminates against a small parcel (which is not the case for the Development Project), is not, in and of itself illegal. Discriminatory “spot” zoning is only impermissible if it constitutes “arbitrary or unreasonable discrimination” Case v. City of Los Angeles, 142 Cal. App. 2d 66, 69 (1956) and “every intendment is in favor of validity of the action of the legislative authority, which will not be overthrown unless plaintiff produces evidence establishing physical facts justifying, or rather requiring, the conclusion that the ordinance is, as a matter of law, unreasonable and invalid.” Robinson v. City of Los Angeles, 146 Cal. App. 2d 810, 815 (citing Wilkins, supra, 29 Cal. 2d at 338 (1946). As the Court held in Viso v. State of California 92 Cal.App.3d 15, 22 (1979) “even where a small island is created in the midst of less restrictive zoning, the zoning may be upheld where rational reason in the public benefit exists for such a classification.” See also Wilkins v. City of San Bernardino, 29 Cal. 2d 332 (1946) (holding that illegality only arises when an agency improperly limits the use of the “island.” In sum, impermissible spot zoning only occurs when: (a) a small parcel of land in the middle of a much larger zoned area has its zoning modified such that it has more land use restrictions than those applicable in the immediately surrounding area, and (b) such discriminatory zoning is shown to be an act of arbitrary or unreasonable discrimination by the zoning authority. Impermissible spot zoning does not result when, as here, a zone change to a parcel adds a permitted use on that parcel at the parcel owner’s request. A commenter argues the less restrictive zoning will result in a greater degree of profit and that “spot zoning could have the impact of creating or hastening a domino effect on the remaining industrial/manufacturing zoned properties.” Aside from the fact that the Project Applicant’s request for a zone change does not constitute discriminatory zoning, the fact that a landowner may profit from a use certainly does not make the zoning change illegal. Moreover, the assertion that the zoning change “could have” an impact is purely speculative. The commenter has failed to submit any facts to justify this claim. Indeed, the facts are to the contrary, because the record shows that there is virtually no ongoing industrial/manufacturing activity in the area already and that the uses in the area are consistent with the residential/commercial uses proposed for the Development Project. Moreover, the proposed use is consistent with the well recognized need for residential and commercial development along transit corridors such as the Expo Line and, indeed, this area is undergoing up-zoning as part of the City’s Transit Station Plans for the Expo Line that call for “the establishment of new development regulations that better support transit ridership, such as allowing some increased development intensity near stations where appropriate…” Although the term “spot zoning” has, on occasion, been used to reflect a situation where a parcel was allowed a greater use than neighboring uses, we are not aware of any cases where such zoning was found illegal. See e.g.

Page 4: Responses to comments and comments to Casden Sepulveda comments up to PH

Case v. City of Los Angeles (1956) 142 Cal. App. 2d 66, 69 (“It may be true that to continue the zoning restrictions upon defendant's property would confer benefits on neighboring owners, including plaintiffs, and enhance the value of their properties, but the existence of such benefits does not generate interests protected by the Constitution against diminution by governmental authorities in the proper exercise of police power. The city in the exercise of its police power has the right to modify its zoning regulations from time to time”); Robinson v. City of Los Angeles (1956) 146 Cal. App. 2d 810 (the court upheld a zone change from agricultural to light industrial land uses over neighbors' objections); Ferris v. City of Alhambra (1961) 189 Cal. App. 2d 517 (the court allowed a rezoning from single-family residential to commercial land uses, despite the objections of the vast majority of residential neighbors). In Scrutton v. Sacramento County 275 Cal.App.2d 412, 420, 79 Cal.Rptr. 872, 878 (Cal.App. 1969) the Court used the term “spot” zoning to apply to a situation where the locality allowed increased uses on a piece of property. However, it held that “that kind of zoning is valid when long-term changes in the neighborhood have created conditions compatible with the proposed new use. (Wilkins v. City of San Bernardino, 29 Cal.2d 332, 340, 175 P.2d 542; 420 Skalko v. City of Sunnyvale, 14 Cal.2d 213, 216, 93 P.2d 93; 1 Anderson, op. cit., s 5.06, pp. 248 - 252.) The very basis for the action - neighborhood change - provides the reclassification with a practical assurance of stability.” As noted above, long-term changes in the neighborhood have created conditions compatible with the proposed new use. For all of the above reasons, the requested zone change does not constitute illegal “spot” zoning.

2. Emergency Response/Access

Comments were submitted regarding the ability of the Los Angeles Fire Department (LAFD) and the Los Angeles Police Department (LAPD) to respond to emergency calls within the traffic study area of the Development Project, considering that several of the study intersections currently operate at poor levels of service (LOS), and traffic generated by the Development Project would result in significant and unavoidable LOS impacts at 22 of the study intersections. First, it should be noted that the assessment of environmental impacts related to fire and police services provided by the LAFD and the LAPD (respectively) is not limited to the issue of emergency access. As discussed in Section IV.M (Public Services) of the Draft EIR, environmental impacts are assessed considering a number of factors (such as fire flow, response distance, response times, service ratios, emergency access, compliance with Fire Code and other building standards, security and safety features incorporated into the project, review of the project by the LAFD and LAPD, and payment of applicable fees by the applicant) and based on all these factors, would a project require new or expanded facilities to maintain acceptable service levels, the construction of which could result in environmental impacts. This assessment in the Draft EIR prepared for the Development Project determined that no new or expanded facilities would be required as a result of the Development Project in order for the LAFD and the LAPD to maintain adequate service levels. Although the Development Project would add traffic to the study area, the Development Project’s traffic would not cause traffic flow to “freeze,” not allowing any vehicles, emergency or otherwise, to move through the study area. Traffic congestion is commonplace in the City of Los Angeles, and the LAFD and LAPD are familiar with the tactics needed to maneuver through traffic congestion during an emergency response, with the use of sirens, lights, traffic signals, and use of alternate routes during peak traffic hours. The LAFD and LAPD would continue to implement these tactics during the operation of the Development Project. The current challenges facing the City in light of recent budget cuts are complex and continue to evolve. City officials are committed to developing interim solutions to ensure that the LAFD is able to meet mandated performance standards set forth in the Los Angeles Fire Code. CEQA does not shift financial responsibility for the provision of adequate fire and emergency response services to a project applicant. The City has a constitutional obligation to provide adequate fire protection and emergency services. As such, the City must continue to perform its obligations. The Development Project would generate a significant amount of General Fund revenues to the City in the form of sales and property taxes. The City could use these added revenues to help offset the LAFD budget cuts, although the ultimate use of these revenues is at the discretion of the City and not the Project Applicant. Nonetheless, as discussed previously, the assessment of Development Project impacts related to services provided by the LAFD and LAPD were found to be less than significant in the Draft EIR.

Page 5: Responses to comments and comments to Casden Sepulveda comments up to PH

Response to Comment Letter Adams

This comment letter expresses support for the Development Project.

Response to Comment Letter Alpern A

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan, traffic impacts, and “spot zoning” are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4, Alpern A-2, and Alpern A-11 in the Final EIR. Also, the commenter is referred to Topical Response 1 for more information related to “spot zoning.”

Response to Comment Letter Alpern B

This comment letter includes statements about the Sierra Club.

Response to Comment Letter Anawalt

The commenter’s statements about traffic impacts and size of the Development Project are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Alpern A-2 and Alpern A-3 in the Final EIR. Although it is acknowledged that the loading/unloading and truck staging activities described by the commenter do occur, it is important to note that the existing two-way left-turn lane adjacent to the Development Project site and the Anawalt Lumber Company facility is intended to be used to accommodate left turns into and out of the land uses and developments along Sepulveda Boulevard (where it is impractical or infeasible to provide separate left-turn lanes for each individual use), and is not designated as or designed to be used as a staging or loading zone. Therefore, the current and historical (non-permitted) use by Anawalt Lumber Company of this lane as a staging/loading area simply because prohibition of such illegal use has not been enforced should not preclude the use of this lane for its intended purpose as a left-turn lane for the Development Project or other adjacent uses, and is not a justification for the restriction of the Development Project’s commercial driveway (on Sepulveda Boulevard) to right turn entry/exits only. Additionally, it should be noted that the traffic study prepared for the Development Project identified northbound left-turns from Sepulveda Boulevard into the Development Project site (using the existing two-way left-turn lane), and that this vehicular access assumption was reviewed and found to be acceptable by LADOT.

Response to Comment Letter Aston

This comment letter expresses support for the Development Project.

Response to Comment Letter Bacal

The commenter’s statements about the Expo Line crossing and Development Project impacts related to traffic, air quality health impacts, and size/character are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Macdonald-1, Alpern A-2, City Council (Paul Koretz) B-4, and City Council (Paul Koretz) B-11 in the Final EIR. Regarding the ability of emergency service vehicles to maneuver congested roadways, the commenter is referred to Topical Response 2.

Response to Comment Letter Beck

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan, traffic impacts, and “spot zoning” are similar to statements made during the public review period

Page 6: Responses to comments and comments to Casden Sepulveda comments up to PH

for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4, Alpern A-2, and Alpern A-11 in the Final EIR.

Response to Comment Letter Bell

The commenters’s statements about traffic impacts, cumulative traffic impacts, and air quality impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Alpern A-2, Logan-1, and Beber-21 in the Final EIR.

Response to Comment Letter Bergelson

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan, traffic impacts, and “spot zoning” are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4, Alpern A-2, and Alpern A-11 in the Final EIR. Also, the commenter is referred to Topical Response 1 for more information related to “spot zoning.”

Response to Comment Letter Boyarsky

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Branfman

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Broide

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan, traffic impacts, “spot zoning,” a “Westside Transit Center,” and air quality health risks are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4, Alpern A-2, Alpern A-11, Alpern A-6, Alpern A-7, and City Council (Paul Koretz) B-4 in the Final EIR. Also, the commenter is referred to Topical Response 1 for more information related to “spot zoning.”

Response to Comment Letter Bruins

The commenter’s statements about bicycle/pedestrian access and safety near the Development Project site are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments City Council (Paul Koretz) B-22, Alpern A-10, and Commins-3 in the Final EIR.

Response to Comment Letter Brundige

The commenter’s statements about Development Project traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Response to Comment Alpern A-2 in the Final EIR.

Response to Comment Letter Burns

The commenter’s statements about consistency of the Development Project with the West Los Angeles Community Plan, traffic impacts, pedestrian circulation/safety, and health impacts are similar to statements made during the

Page 7: Responses to comments and comments to Casden Sepulveda comments up to PH

public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4, Alpern A-2, City Council (Paul Koretz) B-22, City Council (Paul Koretz) B-4, and City Council (Paul Koretz) B-17 in the Final EIR.

Response to Comment Letter Caplan

The commenter’s statements about the size of the Development Project and traffic and parking impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Alpern A-3, Alpern A-2, and Emerson B03.

Response to Comment Letter Cohon

The commenter’s statements about the size of the Development Project and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Alpern A-3and Alpern A-2.

Response to Comment Letter Cosidine

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan, traffic impacts, and “spot zoning” are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4, Alpern A-2, and Alpern A-11 in the Final EIR. Also, the commenter is referred to Topical Response 1 for more information related to “spot zoning.”

Response to Comment Letter Cuadra

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Day

This comment letter expresses support for the Development Project.

Response to Comment Letter DeAscentis

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Dorfman

The commenter’s statements about Development Project impacts related to visual character, traffic, setbacks, parking, and construction-related noise and air quality are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Alpern A-3, Alpern A-2, Commins-3, Emerson B-3, Beber-31, and Beber-22 in the Final EIR. Regarding construction-related traffic impacts, this issue was addressed in Section IV.N (Transportation/Traffic) of the Draft EIR. As discussed, no significant impacts would occur.

Response to Comment Letter Elizalde

This comment letter expresses opposition to the Development Project.

Page 8: Responses to comments and comments to Casden Sepulveda comments up to PH

Response to Comment Letter Epstein

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Eveloff

The commenter asserts that the Final EIR for the Development Project contains “substantive flaws,” but the commenter does not provide any supporting evidence or analysis to support this assumption.

Response to Comment Letter Feinberg

This comment letter expresses support for the Development Project.

Response to Comment Letter Feit

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Ferraro

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Freedman

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Fry

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Gallagher

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Garven

Parking impacts of the Development Project are addressed in the Draft EIR and Final EIR. The commenter is referred to Response to Comment Emerson B-3.

Response to Comment Letter Goldfarb

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Goldstone

This comment letter expresses opposition to the Development Project.

Page 9: Responses to comments and comments to Casden Sepulveda comments up to PH

Response to Comment Letter Goodman, Roger

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Goodman, Ruth

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Guagliano

The commenter’s statements about the Expo Line crossing and Development Project impacts related to traffic, air quality health impacts, and size/character are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Macdonald-1, Alpern A-2, City Council (Paul Koretz) B-4, and City Council (Paul Koretz) B-11 in the Final EIR. Regarding the ability of emergency service vehicles to maneuver congested roadways, the commenter is referred to Topical Response 2.

Response to Comment Letter Gurzeler

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Handal

The commenter’s statements about “spot zoning” and infrastructure impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Response to Comment Alpern-11 and Response to Comment Letter Tippit B in the Final EIR. Also, the commenter is referred to Topical Response 1 for more information related to “spot zoning.”

Response to Comment Letter Hays

The commenter’s statements about the Development Project’s consistency with the West Los Angeles Community Plan, and industrial zoning-related policies and impacts related to visual character are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4, City Council (Paul Koretz) B-16, and City Council (Paul Koretz) B-11 in the Final EIR. Consistency of the Development Project with the General Plan is included in Section IV.I (Land Use and Planning) in the Draft EIR. Impacts were found to be significant and unavoidable.

Response to Comment Letter Healy

The commenter’s statements about “cut-through” traffic, alternatives, air quality health risks, and size of the Development Project are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Abarbanel-5, City Council (Paul Koretz) B-6, City Council (Paul Koretz) B-4, and Alpern A-3. The commenter should note that Veteran Avenue through the study area is generally designated as a Secondary or Collector roadway (except for the discontinuous portions between Pico Boulevard and National Boulevard, where it is a local street), and is therefore identified as a facility to accommodate greater traffic volumes (and as such, no “residential street” impact analyses are appropriate, despite the development of residences along this roadway). The traffic study prepared for the Development Project also assumed that some project traffic would utilize this roadway (the market/local retail component), so the potential utilization of this street by project traffic was not ignored. Similarly, while Tennessee Avenue does provide an alternate and parallel route to Pico Boulevard, it only

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does so between Sepulveda Boulevard and Beverly Glen Boulevard (it terminates at the Fox Studios property), and due to the fact that its intersections with such major cross streets at Westwood Boulevard and Beverly Glen Boulevard are not signalized (making crossing those streets or even making left-turns onto those streets difficult and time consuming due to heavy north-south traffic on those roadways, Tennessee Avenue is not expected to be a significant cut-through traffic route, especially for project-related traffic.

Response to Comment Letter Horwitz

The commenter’s statements about traffic impacts and Development Project access are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Alpern A-2 and Kassan-30.

Response to Comment Letter Iu

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Jacobs

This comment letter expresses support for the Development Project.

Response to Comment Letter Jacquard

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Jones

The commenter’s statements about the Expo Line crossing and Development Project impacts related to traffic, emergency services, air quality health impacts, and visual character are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Macdonald-1, Alpern A-2, Tippit B-3, City Council (Paul Koretz) B-4, and City Council (Paul Koretz) B-11 in the Final EIR. Regarding the ability of emergency service vehicles to maneuver congested roadways, the commenter is referred to Topical Response 2.

Response to Comment Letter Kassan

The commenter’s statements about alternatives to the Development Project and cut-through traffic are similar to statements made by the commenter during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to the responses prepared to Comment Letter Kassan in the Final EIR.

Response to Comment Letter Lacter

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Laskin

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Page 11: Responses to comments and comments to Casden Sepulveda comments up to PH

Response to Comment Letter Lawrence

This comment letter expresses support for the Development Project.

Response to Comment Letter Leeb

This comment letter expresses support for the Development Project.

Response to Comment Letter Leslie

This comment letter expresses support for the Development Project.

Response to Comment Letter LeVasseur

The commenter’s statements about the Expo Line crossing and Development Project impacts related to traffic, emergency services, air quality health impacts, and visual character are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Macdonald-1, Alpern A-2, Tippit B-3, City Council (Paul Koretz) B-4, and City Council (Paul Koretz) B-11 in the Final EIR. Regarding the ability of emergency service vehicles to maneuver congested roadways, the commenter is referred to Topical Response 2.

Response to Comment Letter Plasterers Local Union 200

This comment letter expresses support for the Development Project.

Response to Comment Letter Luber

This comment letter expresses support for the Development Project.

Response to Comment Letter Maddack

This comment letter expresses opposition to the Development Project.

Response to Comment Letter McKinnon

This comment letter expresses opposition to the Development Project.

Response to Comment Letter McMillan

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Mercer

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan, traffic impacts, and “spot zoning” are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4, Alpern A-2, and Alpern A-11 in the Final EIR. Also, the commenter is referred to Topical Response 1 for more information related to “spot zoning.”

Response to Comment Letter Miller

This comment letter expresses support for the Development Project.

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Response to Comment Letter Mitchell

This comment letter expresses support for the Development Project.

Response to Comment Letter Mogerman A

The commenter’s statements about the Expo Line crossing and Development Project impacts related to traffic, emergency services, air quality health impacts, and visual character are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Macdonald-1, Alpern A-2, Tippit B-3, City Council (Paul Koretz) B-4, and City Council (Paul Koretz) B-11 in the Final EIR. Regarding the ability of emergency service vehicles to maneuver congested roadways, the commenter is referred to Topical Response 2.

Response to Comment Letter Mogerman B

The commenter’s statements about the Expo Line crossing, traffic impacts, and cumulative traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Comments Macdonald-1, Alpern A-2, and Logan-1.

Response to Comment Letter Murdock

Response to Comment Murdock-1

The commenter is referred to Responses to Comments Murdock-2 through Murdock-13 in this document.

Response to Comment Murdock-2

The first hearing for consideration of certifying the EIR and approving any portion of the Development Project will not be held until February 24, 2013, which is more than three months after the Final EIR was made available for public review.

Response to Comment Murdock-3

The commenter incorrectly states that the potential traffic impacts of the Development Project at the study intersections are based on the percentage of project-related traffic as compared to the existing or future “baseline” traffic at the intersection (or incremental increase in intersection traffic due to project-related trips). In actuality, as described in detail in the traffic study prepared for the Development Project, project impacts are based on changes to the Critical Movement Analysis (CMA) values (roughly equivalent to the intersection’s volume-to-capacity ratio, or “v/c”), and have fixed value thresholds depending on the LOS for the subject intersection. As such, higher intersection volumes represent higher v/c ratios and higher LOS at the intersection. Additionally, since the City’s “significance” thresholds decrease as the LOS increase, higher baseline traffic volumes, which as noted above produce higher LOS, result in lower thresholds of significance, increasing the likelihood that significant project-related impacts would occur. Therefore, contrary to the commenter’s assertion, the higher baseline intersection volumes used in the project traffic study produce a higher possibility of significant impacts, not a lesser possibility. Further, since the impacts are not based on a percentage of the total trips, but on project-related traffic increases in the v/c ratios at the intersection (which typically use a constant “capacity” denominator value), the project’s incremental impacts are not understated.

Response to Comment Murdock-4

The commenter is referred to Topical Response 1.

Page 13: Responses to comments and comments to Casden Sepulveda comments up to PH

Response to Comment Murdock-5

The commenter is referred to Topical Response 1. If the requested zoning and general plan amendment are not granted, then the Development Project would not be constructed.

Response to Comment Murdock-6

Page IV.I-6 of the Draft EIR does include the text stated by the commenter. A more detailed response to this comment is included as Response to Comment Murdock-3 in the Final EIR.

Response to Comment Murdock-7

The commenter is referred to Topical Response 1. The environmental impacts of the Development Project Applicant’s request to change the zoning and land use designation of the site from M2/PF and Light Industrial/Public Facilities (respectively) to C2 and Community Commercial (respectively) are addressed throughout the Draft EIR and Final EIR.

Response to Comment Murdock-8

This comment expresses an opinion about the language of the TIMP.

Response to Comment Murdock-9

This comment expresses an opinion about the interpretation of a goal of the 2008 RCP.

Response to Comment Murdock-10

As noted by the commenter, the air quality health risks associated with the Development Project are disclosed in the Draft EIR and Final EIR.

Response to Comment Murdock-11

No further response can be provided beyond Responses to Comments Murdock-11 and Murdock-12 in the Final EIR.

Response to Comment Murdock-12

The Development Project Applicant would be required to pay permit fees, other administrative fees, and taxes that would cover the cost of the City’s monitoring of the mitigation implementation for the Development Project. City budget restrictions would not affect monitoring of the Development Project’s mitigation or vice versa.

Response to Comment Murdock-13

The commenter’s statements about alternatives to the Development Project are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Kassan-34 through Kassan-45.

Response to Comment Letter Neff

The environmental impacts of the Development Project have been addressed in the Draft EIR and Final EIR.

Response to Comment Letter Nixon

This comment letter expresses opposition to the Development Project. No CEQA-related issues are raised in the letter.

Page 14: Responses to comments and comments to Casden Sepulveda comments up to PH

Response to Comment Letter Nuttle

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Olavarria, Irene

This comment letter expresses opposition to the Development Project. No CEQA-related issues are raised in the letter.

Response to Comment Letter Olavarria, Marcelo

This comment letter expresses opposition to the Development Project. No CEQA-related issues are raised in the letter.

Response to Comment Letter Orfirer

The commenter’s statements about the size of the Development Project and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Alpern A-3 and Alpern A-2 in the Final EIR.

Response to Comment Letter Pasic

This comment letter expresses opposition to the Development Project. No CEQA-related issues are raised in the letter.

Response to Comment Letter Pelz

The commenter’s statements about traffic impacts and the Expo Line crossing are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Response to Comment Alpern A-2 and Macdonald-1 in the Final EIR.

Response to Comment Letter Pincus

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Pollock

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan, traffic impacts, and “spot zoning” are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4, Alpern A-2, and Alpern A-11 in the Final EIR. Also, the commenter is referred to Topical Response 1 for more information related to “spot zoning.”

Response to Comment Letter Pope B

This comment letter expresses the commenter’s opinions regarding LADOT’s Traffic Study Policies and Procedures. Such comments are beyond the scope of influence of the Development Project. The traffic study and all supplemental analyses for the Development Project adhere to LADOT’s current traffic study and analysis and evaluation requirements.

Page 15: Responses to comments and comments to Casden Sepulveda comments up to PH

Response to Comment Letter Prochazka

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Pullitz

The commenter asserts that the EIR prepared for the Development Project is “insufficient,” but the commenter does not provide any supporting evidence or analysis to support this assumption. The Expo project was included as a related project in the Draft EIR for the Development Project and considered in the cumulative analysis throughout the document.

Response to Comment Letter Purcell

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Reznik

Response to Comment Reznik-1

The commenter is referred to Responses to Comments Reznik-2 through Reznik-11 in this document.

Response to Comment Reznik-2

The commenter’s statements about the age of the traffic study, the study area, and cut-through traffic are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Arbarbanel-4, Abarbenel-5, and Diamond-5 in the Final EIR. Based on these responses, the Final EIR did not fail to address traffic impacts of the Development Project, contrary to the assertion made by the commenter.

Response to Comment Reznik-3

The commenter’s statements about impacts associated with development of the Add Area are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Response to Comment City Council (Paul Koretz) B-11.

Response to Comment Reznik-4

The commenter is referred to Response to Comment Tippit B-3 in the Final EIR and Topical Response 2 in this document.

Response to Comment Reznik-5

The commenter’s statements about impacts associated with development of the Add Area are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Response to Comment City Council (Paul Koretz) B-11. As stated in the Draft EIR and repeated in Response to Comment City Council (Paul Koretz) B-11, most of the Add Area Project site is currently developed with a public storage facility and a County office building, both relatively new commercial/office structures. There is no reason to assume that either of these uses would be discontinued and demolished any time within the lifespan of the Development Project to allow for discretionary development of the Add Area Project site. Thus, no growth-inducing impacts would occur as a result of the Add Area Project. Based on this response, recirculation of the Draft EIR is not required, contrary to the assertion made by the commenter.

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Response to Comment Reznik-6

The commenter’s statements about cut-through traffic are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Response to Comment Abarbanel-5. Cumulative impacts related to neighborhood intrusion (or cut-through traffic), bicycle, pedestrian, and vehicle safety, parking, transit, and in-street construction are addressed in the Draft EIR on page IV.N-127 in Section IV.N (Transportation/Traffic); impacts were found to be less than significant. The traffic impact analysis (including the analysis of impacts related to cut-through traffic; bicycle, pedestrian, and vehicle safety; parking; transit; and in-street construction) was conducted by an expert traffic engineer with decades of experience with assessing traffic impacts in the Los Angeles area. Regarding impacts associated with the Add Area Project, the commenter is referred to Response to Comment Reznik-5 in this document. Based on this response, recirculation of the Draft EIR is not required, contrary to the assertion made by the commenter.

Response to Comment Reznik-7

The commenter is referred to Response to Comment Reznik-6 in this document. Based on this response, recirculation of the Draft EIR is not required, contrary to the assertion made by the commenter.

Response to Comment Reznik-8

No significant cumulative impacts related to neighborhood intrusion have been identified, and no mitigation measures are required for this issue. CEQA does not require mitigation for impacts found to be less than significant (refer to Section 15126.4[a][3] of the CEQA Statute and Guidelines). Based on this response, recirculation of the Draft EIR is not required, contrary to the assertion made by the commenter.

Response to Comment Reznik-9

The commenter states that the traffic analysis for the Development Project contains no analysis of the haul route for the Development Project. Specifically, the commenter asserts that the Draft EIR failed to analyze how such trips would affect local traffic patterns during grading and excavation activities. However, the commenter fails to identify any substantial impacts that this aspect of the Development Project would have on local traffic. In fact, there is no basis for assuming that such trips would affect local traffic patterns. Note that the existing cement plant operation generates approximately 113 daily cement truck trips during off peak hours plus an additional 77 other truck trips during this period for a total of approximately 190 truck trips per day (refer to Appendix G to the Final EIR). These trips would cease with implementation of the Development Project and would be “replaced” with approximately 126 daily trips during the Development Project’s grading/excavation phase (see Attachment B), approximately 51 fewer daily trips than under the existing condition. Therefore, the hauling operations associated with the Development Project would not add any new trips, let alone cause a significant impact. In addition, there is no reason to believe that the traffic patterns to be followed by the hauling trucks would differ in any way that would significantly impact local traffic patterns. While the existing cement trucks may use local streets to get to and from construction projects, because the Development Project site is adjacent to the 405 Freeway, the Development Project’s haul trucks would most likely to travel along Exposition Boulevard, Sepulveda Boulevard, Pico Boulevard, and Sawtelle Boulevard to the 405 Freeway. Therefore, haul truck trips would not have any significant impact on local traffic patterns. Based on this response, recirculation of the Draft EIR is not required, contrary to the assertion made by the commenter.

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Response to Comment Reznik-10

The commenter is referred to Topical Response 2 in this document. Based on this response, recirculation of the Draft EIR is not required, contrary to the assertion made by the commenter.

Response to Comment Reznik-11

The commenter is referred to Responses to Comments Reznik-1 through Reznik-10.

Response to Comment Letter Riggins

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Rosenson

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Salnez

This comment letter expresses support for the Development Project.

Response to Comment Letter Santana, Joe

Regarding the ability of emergency service vehicles to maneuver congested roadways, the commenter is referred to Topical Response 2. Regarding bike lanes, the Development Project does not include closing of any traffic lanes to accommodate bike lanes.

Response to Comment Letter Santana, Martha

This comment letter expresses opposition to the Development Project. No CEQA-related issues are raised in the letter.

Response to Comment Letter Schecter

This comment letter expresses opposition to the Development Project. No CEQA-related issues are raised in the letter.

Response to Comment Letter Stevens

The commenter’s statements about the size of the Development Project, consistency with the West Los Angeles Community Plan, use of the site as industrial, cut-through traffic, site access, air quality health risks, and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Alpern A-3, Beber-4, Abarbanel-8, Abarbanel-5, Kassan-30, City Council (Paul Koretz) B-11, and Alpern A-2 in the Final EIR.

Response to Comment Letter Swimmer

This comment letter expresses opposition to the Development Project. No CEQA-related issues are raised in the letter.

Response to Comment Letter Teitelbaum

This comment letter expresses support for the Development Project.

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Response to Comment Letter Thomason

The commenter’s statements about the Expo Line crossing and Development Project impacts related to traffic, air quality health impacts, and visual character are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Macdonald-1, Alpern A-2, City Council (Paul Koretz) B-4, and City Council (Paul Koretz) B-11 in the Final EIR. Regarding the ability of emergency service vehicles to maneuver congested roadways, the commenter is referred to Topical Response 1.

Response to Comment Letter Tippit A

The commenter is referred to Response to Comment Letter Tippit B.

Response to Comment Letter Tippit B

Response to Comment Tippit B-1

This comment expresses opposition to the Development Project and touches on statements made previously by the commenter on the Draft EIR that were responded to in the Final EIR. The commenter asserts that “public hearings for this proposed development should not occur before the appeal of the Expo Phase 2 Light Rail Project to the California Supreme Court has concluded. The results of the Supreme Court's decision may have several potential impacts to the analysis of this project in the DEIR and FEIR and the assumptions and methodology used. Additionally, the description of the project as a transit-oriented development which is the premise for the project's size and density, has made many assumptions in the EIR (particularly in the traffic study and in the land use analysis) that are dependent on the light rail adjacency and overall light rail design and station placement. Some of these assumptions may be false based upon the outcome of the Expo Phase 2 Light Rail Project appeal." This comment fails to identify any specific assumptions that may be rendered false, any new significant impact or substantial increase in the severity of any environmental impact or any mitigation measure that may be impacted by the California Supreme Court’s decision regarding the Expo Phase 2 Light Rail Project. Additionally, the Expo Phase 2 project has been approved and work on the project is proceeding. Indeed, while the California Supreme Court recently denied a request to stay the project pending appeal. The Expo Phase 2 project is a reasonably foreseeable future project that may be considered in the EIR. Moreover, “the description of the project as a transit-oriented development” is irrelevant to the study of the environmental impacts of the project – which remain unchanged whatever title is given to the project. In addition, because the project is adjacent to various local bus routes it is a transit-oriented development regardless of the future of the Expo Phase 2 project. Finally, it is noted that for purposes of the baseline, the traffic study did not include the Expo Phase 2 project. Using those figures, the traffic study determined that there would be significant impacts at 27 intersections. For mitigation purposes, the traffic study did assume that the Expo Phase 2 project would be operational. However, there were still significant impacts at 27 intersections, and there were no additional feasible mitigation measures. Therefore, regardless of whether the Expo Phase 2 project is completed, there would be no significant difference in the traffic impacts.

Response to Comment Tippit B-2

The commenter’s statements about size of the Development Project and impacts are similar to statements made by the commenter during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comment Letters Tippit A and Tippit B in the Final EIR.

Response to Comment Tippit B-3

The commenter states that the EIR for the Development Project should not be certified for the reasons stated in the commenter letter. The commenter is referred to Responses to Comments Tippit B-4 through Tippit B-52.

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Response to Comment Tippit B-4

This comment is substantially the same as the statements made in Comments Tippit A-2 through Tippit A-6 on the Draft EIR. The commenter is referred to the responses to those comments in the Final EIR. In addition, the commenter is referred to Response to Comment Reznik-5 in this document.

Response to Comment Tippit B-5

This comment includes the same statements made in Comments Tippit A-7 through Tippit A-10 on the Draft EIR. The commenter is referred to the responses to those comments in the Final EIR. In addition, the commenter is referred to Response to Comment Reznik-5 in this document.

Response to Comment Tippit B-6

The commenter’s statements about traffic impacts and alternatives are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Alpern A-2 and City Council (Paul Koretz) B-6 in the Final EIR.

Response to Comment Tippit B-7

This comment expresses an opinion about responses to comments on the Draft EIR.

Response to Comment Tippit B-8

This comment includes the same statements made in Comment Tippit A-12 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-9

This comment includes the same statements made in Comment Tippit A-13 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-10

This comment expresses an opinion about the analysis of cut-through traffic in the Draft EIR and the Final EIR.

Response to Comment Tippit B-11

This comment is substantially the same as the statements made in Comment Tippit A-14 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-12

This comment includes the same statements made in Comment Tippit A-15 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-13

This comment is substantially the same as the statements made in Comment Tippit A-16 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR. (The requested analysis is in the Draft EIR.)

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Response to Comment Tippit B-14

This comment is substantially the same as the statements made in Comment Tippit A-17 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-15

Response to Comment Beber-20 states that the schools are within the traffic study area for the Development Project.

Response to Comment Tippit B-16

This comment includes the same statements made in Comment Tippit A-19 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-17

This comment includes the same statements made in Comment Tippit A-20 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-18

As stated in Response to Comment Beber-24 in the Final EIR, the mitigation measures suggested by the commenter were considered and were found to be substantially similar to SCQAMD Rule 403, included as Mitigation Measure C-3 in the Draft EIR on page IV.C-44 that reads as follows:

C-3. The Project Applicant shall implement appropriate dust control measures during each phase of development as required by SCAQMD Rule 403—Fugitive Dust. Examples of the types of dust control measures currently required and/or recommended include, but are not limited to, the following:

• Water active grading/excavation sites and unpaved surfaces at least three times daily.

• Cover stockpiles with tarps or apply non-toxic chemical soil binders.

• Limit vehicle speed on unpaved roads to 15 mph.

• Sweep daily (with water sweepers) all paved construction parking areas and staging areas.

• Provide daily clean-up of mud and dirt carried onto paved streets from the site.

• Install wheel washers for all exiting trucks, or wash off the tires or tracks of all trucks and equipment leaving the site.

• Suspend excavation and grading activity when winds (instantaneous gusts) exceed 15 mph over a 30-minute period or more.

• An information sign shall be posted at the entrance to each construction site that identifies the permitted construction hours and provides a telephone number to call and receive information about the construction project or to report complaints regarding excessive fugitive dust generation. Any reasonable complaints shall be rectified within 24 hours of their receipt.

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Response to Comment Tippit B-19

This comment includes the same statement made in Comment Tippit A-23 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-20

This comment includes the same statements made in Comment Tippit A-24 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-21

This comment includes the same statements made in Comment Tippit A-25 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-22

This comment includes the same statements made in Comment Tippit A-26 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-23

This comment is substantially the same as the statements made in Comment Tippit A-27 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-24

This comment is substantially the same as the statements made in Comment Tippit A-28 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-25

This comment includes the same statements made in Comment Tippit A-29 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-26

This comment is substantially the same as the statements made in Comment Tippit A-30 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-27

This comment is substantially the same as the statements made in Comment Tippit A-31 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-28

The commenter is referred to Response to Comment Tippit B-32.

Response to Comment Tippit B-29

This comment includes the same statements made in Comment Tippit A-34 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

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Response to Comment Tippit B-30

This comment expresses an opinion about the height of the buildings associated with the Development Project in relation to other tall buildings in the Development Project area that were identified in Appendix C of the Final EIR.

Response to Comment Tippit B-31

Potential impacts of the Development Project related to airport hazards were addressed on page IV.G-29 in Section IV.G (Hazards and Hazardous Materials) of the Draft EIR. The Draft EIR stated the following:

The airport nearest to the Development Project site is the Santa Monica Airport, which is located approximately 1.5 miles to the southwest. The site is not located within the boundaries of an airport land use plan and would not result in a safety hazard for people residing or working in the project area. The Development Project is also not located in the vicinity of a private airstrip. Therefore, no impact would occur.

Response to Comment Tippit B-32

This comment expresses an opinion about the sufficiency of the analysis of building heights in the Draft EIR and Final EIR.

Response to Comment Tippit B-33

This comment includes statements that are included in Comment Tippit A-35 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-34

This comment includes the same statements made in Comment Tippit A-36 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-35

This comment is substantially the same as the statements made in Comment Tippit A-37 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-36

This comment includes the same statements made in Comment Tippit A-38 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-37

This comment is substantially the same as the statements made in Comment Tippit A-39 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-38

This comment includes the same statements made in Comment Tippit A-40 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-39

This comment includes the same statements made in Comments Tippit A-41 through Tippit A-43 on the Draft EIR. The commenter is referred to the responses to those comments in the Final EIR.

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Response to Comment Tippit B-40

This comment includes the same statements made in Comment Tippit A-44 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-41

This comment is substantially the same as the statements made in Comments Tippit A-45 and Tippit A-46 on the Draft EIR. The commenter is referred to the responses to those comments in the Final EIR.

Response to Comment Tippit B-42

This comment includes the same statements made in Comment Tippit A-47 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-43

This comment is substantially the same as the statements made in Comments Tippit A-48 and Tippit A-49 on the Draft EIR. The commenter is referred to the responses to those comments in the Final EIR.

Response to Comment Tippit B-44

This comment is substantially the same as the statements made in Comments Tippit A-50 and Tippit A-51 on the Draft EIR. The commenter is referred to the responses to those comments in the Final EIR.

Response to Comment Tippit B-45

This comment is substantially the same as the statements made in Comment Tippit A-52 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-46

This comment is substantially the same as the statements made in Comment Tippit A-53 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-47

This comment includes the same statements made in Comment Tippit A-54 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-48

This comment includes the same statements made in Comment Tippit A-55 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-49

This comment includes the same statements made in Comment Tippit A-56 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

Response to Comment Tippit B-50

This comment includes the same statement made in Comment Tippit A-57 on the Draft EIR. The commenter is referred to the response to that comment in the Final EIR.

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Response to Comment Tippit B-51

This comment includes the same statements made in Comments Tippit A-58 and Tippit A-59 on the Draft EIR. The commenter is referred to the responses to those comments in the Final EIR.

Response to Comment Tippit B-52

The comment summarizes the all the comments. The commenter should note that there are no legal requirements regarding the deadline for comments on the Final EIR.

Response to Comment Letter Ugoretz

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Verdon

The commenters’s statements about consistency of the Development Project with the West Los Angeles Community Plan and traffic impacts are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Beber-4 and Alpern A-2 in the Final EIR.

Response to Comment Letter Walch, Nancy

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Walch, Richard

This comment letter expresses opposition to the Development Project.

Response to Comment Letter Wallace

The commenter’s statements about the Expo Line crossing and Development Project impacts related to traffic, air quality health impacts, and visual character are similar to statements made during the public review period for the Draft EIR and were responded to in the Final EIR. The commenter is referred to Responses to Comments Macdonald-1, Alpern A-2, City Council (Paul Koretz) B-4, and City Council (Paul Koretz) B-11 in the Final EIR. Regarding the ability of emergency service vehicles to maneuver congested roadways, the commenter is referred to Topical Response 1.

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ATTACHMENT  A      

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kerrie
Typewritten Text
ADAMS
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kerrie
Typewritten Text
ALPERN A
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From: <[email protected]> Date: Sat, Dec 8, 2012 at 8:33 AM Subject: Re: (Sierra Club in

support of Casden project as is?) Fwd: KORETZ, ROSENDAHL OPPOSE WESTSIDE HIGH

DENSITY PROJECT IN CURRENT FORM To: [email protected],

[email protected] Cc: [email protected], [email protected],

[email protected], [email protected], [email protected],

[email protected], [email protected], [email protected],

[email protected], [email protected], [email protected],

[email protected]

To Mr. Henry Chu and Mr. Michael LoGrande: I was a bit shocked and concerned to learn that the Sierra Club had taken any position in favor of the Casden/Sepulveda project, and so when I consulted with Darrell Clarke and Jerard Wright, co-chairs of the Sierra Club Transportation Committee (see below, and for which I occasionally attend their meetings as a member when I can) and learned there is no such position, I felt obliged to let you know of this. It is my hope that, after hearing how the Sierra Club "weighed in" on Wednesday, the Sierra Club does weigh in on this project and options for land use. It is my hope that the Sierra Club will offer advice as to what they are against, but more importantly what they are FOR, at this land parcel that has such vital transportation, planning and environmental importance to the entire West Los Angeles region. For the record, it needs to be fact-checked as to whether the Sierra Club "officials" or "leaders" who supported this project and testified on Wednesday are speaking for themselves or for a larger group of Sierra Club members. This is particularly concerning to me, after learning from Expo Authority officials they are NOT in communications with Casden while the Casden team reported last Wednesdy that they are. Last Monday night, the City of L.A. Planning had a visioning/planning meeting at the Henry Medina building at Exposition/Sepulveda, which drew a large crowd of individuals who opposed this project but did favor an industrial/commercial/parking approach to building at this site. It remains my contention that the Casden/Sepulveda project team has been frightfully less than honest in their description and work at outreach, but that if true outreach were conducted between the City, Metro, the Sierra Club and the community, we could derive a profitable, jobs-rich and much more eco- and transit-friendly project at this land parcel. Thank you, Ken Alpern

3222 Military Avenue

Los Angeles, CA 90034

 

kerrie
Typewritten Text
ALPERN B
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kerrie
Typewritten Text
ANAWALT
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From: Mark Aston <[email protected]> Date: Tue, Dec 4, 2012 at 9:57 PM Subject: Proposed

Casden project at Pico and Sepulveda To: [email protected] Cc: [email protected]

MARK ASTON

9626 Kirkside Street Los Angeles, CA 90035

December 4, 2012

Henry Chu, Hearing Officer Los Angeles Department of City Planning 200 North Spring Street, Room 750 Los Angeles, CA 90021

Dear Mr. Chu: I am a long-time resident of West Los Angeles. I currently reside in Beverlywood in Council District 5. I spend a considerable amount of time traveling along the Pico corridor for everything from groceries, entertainment, restaurants, and sports activities at Rancho Park. It would appear to me that a transit-orient development at Pico and Sepulveda would help tremendously to alleviate traffic in the area. The proposed Casden project at Pico and Sepulveda – the current site of a polluting cement plant – should be embraced by the city. The project will marry a transit hub, housing, and many other community amenities on one site. These are the sort of projects that will get people out of their cars and ease traffic in the region. This project will be an economic boom in an area of West L.A. that could use a shot in the arm. I wholeheartedly support this project and encourage you to do the same. Regards, Mark

Mark Aston

cc: Chris Koontz, Planning Deputy - Councilman Paul Koretz

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From:  Nancy  Bacal   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  8:46  PM  Subject:  Casden  Development  West  LA  To:  [email protected]        Casden-Sepulveda Development (Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB)        Mr.  Chu    All  of  the  streets  around  this  proposed  development  are  currently  gridlocked.    The  last  traffic  study  that  was  done  in  this  area  a  couple  of  years  ago  had  a  massive  increase  in  traffic,  more  than  the  streets  and  intersections  can  handle.    The  Metro  Expo  Line  train  will  bring  further  delays  to  traffic  in  this  area  with  the  "at  grade  crossings",  this  development  will  further  cause  massive  grid  lock  in  traffic  on  all  the  streets  both  East,  West  and  North  and  South.    When  someone  provides  2000+  Parking  Spaces,  they  expect  2000+  cars,  this  is  way  more  than  this  area  can  handle.    1. The Pico/Sepulveda intersection is already jammed as one of the few east west passages under the 405. Adding a major traffic generator there is ill conceived. 2. Sepulveda serves as an alternate to the 405, and carries a large amount of traffic to/from the National on/off-ramps. 3. Should Expo go in, traffic congestion at Pico/Sepulveda will block access to Expo from all directions. How will emergency services get through? 4. It is morally reprehensible to house men, women, children and seniors so close to a freeway where the poor air quality creates life-long and life-shortening health impacts. Studies show this is costing society millions in illness. 5. Projects along transit lines and around stations should be planned as part of outreach to impacted neighborhoods and through local community plan processes, not piecemealed in the absence of an approved Community Plan. 6. Projects along transit lines and around stations should be planned in harmony with the character of the community 7. The only purpose for placing tall buildings next to the freeway are super graphics and digital billboards, creating more visual blight  

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From:  Jeff  Beck   <[email protected]>  Date:  Thu,  Dec  6,  2012  at  4:14  PM  Subject:  Casden-­‐Sepulveda  Project  -­‐  public  hearings  needed  on  this  huge  development  project  at  Exposition  and  Sepulveda  To:  [email protected]      Dear Commissioner Chu:  The Casden-Sepulveda Development project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles. The project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many immitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.  As a resident living in Mar Vista, I oppose this project as proposed. I want to see local hearings where I and other stake-holders can evaluate the proposal and make important changes that we believe will affect the quality of our lives in our neighborhood. At the same time, we support the Expo Line and the station proposed at Exposition and Sepulveda.  Most Sincerely,      

   

Jeff  Beck  

3224  Purdue  Avenue  

Los  Angeles,  California  90066  

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From:  Andrea  Bell   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  9:36  PM  Subject:  RE:  Casden-­‐Sepulveda  Development  (Case  #CPC-­‐2008-­‐4604-­‐GPA-­‐ZC-­‐HD-­‐CUB-­‐DB-­‐SPR,  CEQA  #ENV-­‐2008-­‐3989-­‐EIR,  Related  Case  #VTT-­‐70805-­‐GB)  To:  [email protected],  [email protected]  Cc:  [email protected],  [email protected],  [email protected],  [email protected]      Dear  Mr.  Chu  and  Mr.  Rosenthal,    As  a  homeowner  and  parent  that  must  travel  two  -­‐  three  times  daily  from  Mar  Vista  north  into  Santa  Monica  I  am  deeply  concerned  about  this  project.    I  have  been  a  resident  of  California  for  more  than  30  years  and  the  traffic  has  gotten  to  the  point  where  it  is  unbearable.  With  the  number  of  construction  projects  planned  in  Playa  Vista,  the  new  Metro  line  construction,  the  Bundy  Village  complex  and  now  the  possible  Casden  development  I  don't  think  we  can  take  much  more.  Plus  I  understand  their  is  another  proposed  development  2  blocks  from  this  site.    To  take  my  son  to  school  is  4.3  miles  one  way.  That  should  take  a  little  over  10  minutes.  However,  on  a  regular  basis  due  to  the  gridlock  on  north  south  streets  such  as  Bundy/Centinella,  Walgrove,  Barrington,  Sepulveda  and  east  west  streets  such  as  Pico  and  Olympic,  it  frequently  take  30  minutes  and  quite  often  more.  Pico  and  Bundy  are  literally  parking  lots  every  afternoon.    This  is  not  proper  growth  and  development  planning.  And  if  this  goes  through  as  planned  even  more  cars  will  be  on  the  roads.  This    is  not  good  for  our  city.  It  exacerbates  the  gridlock  that  already  exists,  adds  to  the  air  pollution,  and  leaves  our  citizens  frazzled  trying  to  move  around  our  city.    The  existing  west/east    traffic  congestion  has  long  been  an  issue  and  yet  it  has  not  been  addressed.  How  are  we  supposed  to  move  around  the  city?  Many  people  I  know  refuse  to  travel  west  to  east  in  the  afternoon  due  to  the  extreme  driving  times.  To  get  from  the  20th  street  in  Santa  Monica  to  even  just  Fairfax  Ave  can  easily  be  more  than  an  hours  drive  at  the  end  of  the  day.  That  is  a  distance  of  only  6.5  miles  gentlemen.  WHy  make  it  even  worse?    Enough  is  enough.    Take  it  else  where  please.    SIncerely  yours,        Andrea  Bell    

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From: G.B. <[email protected]>

Date: Tue, Dec 4, 2012 at 7:44 AM

Subject: Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR,

CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB: Casden-Sepulveda Development:

Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related

Case #VTT-70805-GB:

To: [email protected], [email protected],

[email protected], [email protected],

[email protected] Cc: ken alpern md <[email protected]>, Elizabeth Pollock

<[email protected]>

In regards to the above captioned planning case, I very strongly endorse the CD11 Transportation Advisory Committee's motion to oppose any spot-zoning and land use changes for this project The CD11 Transportation Advisory Committee opposes the Casden-Sepulveda Development (Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB), and demands it not receive any approval of any zone change, tract map, or variance at the upcoming Planning Hearing on Wednesday, December 5th, 2012 (10:00 a.m., West Los Angeles Municipal Building Hearing Room, Room #200). The project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles, and therefore the project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit. re opposes any spot-zoning and land use changes for this project. Sincerely, Gordon Bergelson 11947 Beatrice Street Culver City, CA 90230  

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From: Karen Boyarsky <[email protected]> Date: Wed, Nov 28, 2012 at 7:00

PM Subject: Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-

SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB: To:

[email protected], [email protected], [email protected],

[email protected], [email protected], [email protected]

To Whom It May Concern:

I am an educator in Beverly Hills; I have lived on the 2100 block of Little Overland Avenue for

over twenty years. I am writing to you since I am unable to attend the meeting scheduled for

Wednesday, December 5th.

I run errands at the end of my work day, and make a point of shopping locally. It is not

uncommon for me to make three brief 15-minute stops in a single trip from my home.

Here is a typical example: should I run an errand that involves purchasing an item at Party City

near Sepulveda/Pico, one at Smart & Final on Pico/Cotner, and one at OSH near Bundy/Olympic,

the amount of time required to do so is currently greater than two hours. This breaks down to

30-45 minutes of actual parking/in-store time, and more than 60 minutes of driving time, all within an area covering less than 2 square miles.

It is unconscionable that the Casden-Sepulveda Development project plans to generate 538

residential apartments, 2,029 parking spaces, and a big-box store, a supermarket, and other retail

outlets on 6.5 acres within this 2-mile radius, where traffic is already often at a stand-

still. Perhaps a handful of the new residents will walk to "their own local shops," but what about

the thousands of families who live or commute nearby?

That this project seems to be on a "rushed" schedule indicates very clearly that the race to

develop the property is moving at a much greater speed than the current time required for

residents to travel around its boundaries! I would STRONGLY suggest that participants in this

proposed development attempt to run a couple of errands in the neighborhood, and reconsider

their plans. Traffic, safety, and quality of life are critical issues to those of us who live here. We

have experienced worsening traffic conditions in the past decade; this project will generate even

more density, and negatively impact our neighborhood. I ask you to oppose it.

SIncerely,

K. Boyarsky

2126 Overland Avenue

Member, OAC  

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From:  Judy  Branfman   <[email protected]>  Date:  Thu,  Dec  6,  2012  at  2:42  PM  Subject:  Casden-­‐Sepulveda  Project  -­‐  public  hearings  needed  on  this  huge  development  project  To:  Henry  Chu  <[email protected]>      To:  Mr.  Henry  Chu,  Member  of  L.A.  City  Planning  Commission    Re:  Casden-­‐Sepulveda  Project  -­‐  public  hearings  needed  on  this  huge  development  project  at  Exposition  and  Sepulveda    Dear  Commissioner  Chu:    The  Casden-­‐Sepulveda  Development  project  as  currently  defined  and  described  in  the  Final  EIR  is  in  gross  violation  of  the  Community  Plan  of  West  Los  Angeles.  The  project  should  not  receive  any  approval  of  zone  change,  tract  map,  or  variance  until  appropriate  changes  and  mitigations  are  implemented  to  make  it  conform  with  that  Community  Plan.  Specifically,  the  project  as  currently  defined  and  described  in  the  Final  EIR  presents  too  many  unmitigable  traffic  and  other  infrastructural  impacts  to  the  existing  Westside  (CD11  and  CD5)  traffic/infrastructure  deficit.  As  a  resident  of  Santa  Monica,  I  oppose  this  project  as  proposed.    There  is  no  doubt  that  there  should  be  numerous  local  hearings  where  I  and  other  stake-­‐holders  can  evaluate  the  proposal  and  make  important  changes  that  we  believe  will  affect  the  quality  of  life  on  the  Westside  of  LA.  At  the  same  time,  I  support  the  Expo  Line  and  the  station  proposed  at  Exposition  and  Sepulveda.      Sincerely,      

Judy  Branfman  

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Los Angeles County Bicycle Coalition 634 S. Spring St. Suite 821 Los Angeles, CA 90014 Phone 213.629.2142 Facsimile 213.629.2259 www.la-bike.org

Hearing Officer Attn: Henry Chu Los Angeles Department of City Planning 200 North Spring Street Los Angeles, California 90012

Casden West LA Expo/Sepulveda TOD Project CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR; ENV-2008-3989-EIR

To Whom It May Concern: The Los Angeles County Bicycle Coalition (LACBC) is envisions a better, more bikeable Los Angeles County realized through infrastructure and development projects that support bicycling for transportation in a compact urban environment. Los Angeles County voters agree with this vision and have repeatedly taxed themselves to pay for transportation projects, including 12 major rail projects approved in 2008 with the passage of Measure R. It is now incumbent upon each of the County’s cities to reorient their growth around this new transportation infrastructure by focusing new development at transportation nodes and ensuring that residents’ daily needs are accessible through short walking and biking trips in a supportive built environment. The Casden West LA project intends to construct such a transit-oriented development at the crossing of a new light rail line and two rapid bus lines on a currently underutilized industrial property. If designed well, this project could be a model for development near each of LA’s rail transit stations. The project is also at the intersection of two proposed bicycle facilities: a class I bike path along the Exposition right-of-way and class II bike lanes on Sepulveda Boulevard. Bicycle Parking This optimal location makes it incumbent upon the applicant to include a mobility hub in the proposed project as a community benefit and mitigation for additional traffic generated by the project. The provision of bicycle parking as a component of a mobility hub is in line with the pending Bicycle Parking Ordinance, which is expected to be approved and effective before the subject project proceeds with the next step in its entitlements. This new ordinance will allow up to 30 percent of the project’s automobile parking to be replaced with bicycle parking at a 4:1 ratio, in addition to a minimum amount of parking based on the number of dwelling units and commercial floor area. LACBC expects the applicant to comply with the Bicycle Parking Ordinance and make full use of its provisions to provide bicycle parking in lieu of automobile parking in the appropriate quantities. It is imperative to provide adequate quantities of both long-term and short-term bicycle parking in appropriate locations to serve the project’s various user groups. Generally, long-term bicycle parking for residents and employees should be provided in a secure bike room while short-term bicycle parking for guests and customers should be provided by bike racks located in a prominent

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and visible location near each building entrance. There is some flexibility in these standards for innovative parking solutions. For example, a staffed bicycle center could have both a keycard-controlled member section for long-term parking and valet in a public section for short-term parking during business hours. LACBC can advise on bicycle parking design. The applicant should note minimum quantities required by the Bicycle Parking Ordinance:

• Long-term: o Residential: 1 per dwelling unit o Office: 1 per 5,000 sq.ft. (min. 2) o Restaurant and general retail: 1 per 2,000 sq.ft. (min. 2)

• Short-term: o Residential: 1 per 10 dwelling units o Office: 1 per 10,000 sq.ft. (min. 2) o Restaurant and general retail: 1 per 2,000 sq.ft. (min. 2)

Please note that the 4:1 automobile parking swap is in addition to the above stated minimum bicycle parking requirements. The subject project has proposed a bike room to be located near the Expo Line station on Sepulveda. LACBC is encouraged by this gesture and supports this location. This proposed facility should be expanded to incorporate the appropriate bike storage capacity per the above discussion and operated as a staffed bike center for residents, employees, visitors, and transit users. Transportation Demand Management In Los Angeles there is widespread fear that transit will be used as an excuse to rampantly overdevelop rather than to grow sensibly and respectfully of existing communities. Projects can mitigate these concerns with sensitive treatment of parking, traffic, and other impacts associated with density. These concerns are rarely good reasons to reduce density. To the contrary, a certain level of density is a necessary component of compact, walkable and bikeable development. Therefore reducing density to mitigate traffic at the project level only aggravates this very same problem at the regional level. Instead, every tool in the toolbox should be used to promote dense development around transit while giving residents and visitors every incentive to use transit, walk, and bike for their daily trips. How effectively these tools are deployed is a key distinction between “transit-adjacent development” and “transit-oriented development.” LACBC believes, as supported by current research, that parking policy is one of the greatest determinants of whether people choose to drive or use alternative modes. We therefore recommend the following strategies to reduce traffic and parking impacts from the proposed project: Reduce Automobile Parking

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The current municipal codes require parking at ratios only appropriate for suburban areas without significant transit, walking, and bicycling mode share. However, in Los Angeles County, 24 percent of all trips are made by transit, walking, and bicycling. In a transit-rich location like that of the subject project, these mode shares are undoubtedly higher. Parking quantities for the subject project must reflect this urban context rather than suburban parking minimums. Research indicates that providing excessive quantities of parking encourages driving, while allowing pricing and other mechanisms to manage parking reduces demand. In the traffic-clogged Westside, it is absolutely critical that outdated parking standards not be allowed to cause more driving. Fortunately, the project is buffered on all sides from single-family residential, so concerns about potential parking spillover to neighborhood streets would be misplaced. LACBC encourages the applicant to utilize the Bicycle Parking Ordinance to reduce automobile parking by the maximum 30 percent allowed in transit-oriented developments. An unwillingness to do this would be a strong indication that the project is “transit-adjacent” rather than “transit-oriented.” Unbundle Parking from Lease Agreements The most effective strategy for reducing parking demand is to allow market mechanisms to allocate spaces. This approach effectively lowers the rent for car-free or one-car households, making it more likely that the project will attract those most likely to use transit and least likely to drive. This is an essential mitigation measure to reduce traffic generated by the subject project. In a mixed-use project with separated residential and commercial parking, the garage areas can be allocated with one secure space per dwelling unit in the private section and additional demand accommodated in the general public section. Provide Transit Passes to All Tenants Just as free parking encourages driving, free transit passes encourage transit use. The applicant should provide EZPasses to all residents and employees of the subject project so that they can avail themselves of both Metro and the two municipal bus lines that serve the project. Other TDM Strategies In addition to managing the parking supply and providing transit passes, the project can deploy strategies such as coordinating ridesharing, providing bike education, hosting car-sharing and bike-sharing, and other TDM services. These should be included as part of the mobility hub concept to create a one-stop resource for sustainable transportation. Additionally, the anchor tenants, proposed to be a full-service grocery store and a big box retail store, should provide free rides home within a certain radius of the project to enable people to walk, bike, or take transit without worrying about transporting large or bulky purchases. Impacts to Expo Bikeway As designed, the project proposes to take access from Sepulveda, Pico, and Exposition. LACBC is concerned about the number and locations of these three vehicle access points and their effect on the pedestrian environment along Pico and Sepulveda and the Expo Bikeway along Exposition

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Boulevard. The need for all of these access points should be reevaluated in the context of a parking supply that is reduced by 30 percent over current plans. It may be that all are deemed necessary, but this warrants further study. LACBC is particularly troubled by the proposal to take access across the Expo Bikeway. This will be a premier class I facility on the Westside and at-grade crossings are not to be taken lightly. After understanding the project’s access constraints, we do appreciate the desire for this access to alleviate the burden on Pico and Sepulveda. However, this crossing must be carefully controlled to preserve the functional integrity of the bikeway and protect the safety of those using it. To mitigate the driveway’s impact on the bikeway, LACBC insists that this driveway be controlled by a signal that is default green for the bikeway and only activated by a loop detector for entering and exiting vehicles. Additionally, right turn on red must be prohibited to avoid vehicles queuing on the bikeway while waiting for a gap to turn right. In closing, the proposed project has many promising attributes and several ways in which it could be improved. LACBC does not take a position on the height, land use composition, or other characteristics in as much as they do not impact the transportation function of the project. We look forward to working with the applicant to help the project reach its potential as a model walkable, bikeable, transit-oriented development. If you have any questions, I can be reached at (213) 629-2142 or [email protected]. Sincerely,

Eric Bruins Planning and Policy Director

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From: Elinor Olden Caplan <[email protected]> Date: Tue, Dec 11, 2012 at 2:50

PM Subject: The Casden Sepulveda Project To: [email protected]

Dear Mr. Chu,

I own an apartment building on Corinth Avenue just below Exposition Blvd.

I am writing this letter in opposition to the proposed Casden Sepulveda Project located at 11122 -

11150 Pico Blvd and 2431-2441 South Sepulveda Blvd.

The proposed buildings are much too large for this community and will result in a terrible traffic

congestion. Sawtelle, Pico and Sepulveda are already highly congested and an addition of a

project of this magnitude will greatly increase an already bad traffic situation. Further,

street parking in this area is already a problem and this project will only exasperate the parking

situation. Lastly, the project is not an attractive project and in my opinion will devalue the other

properties in the area.

Sincerely,

Elinor Olden Caplan

[email protected]  

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From: Ruth Cuadra <[email protected]> Date: Fri, Dec 7, 2012 at 12:24 PM Subject:

Casden-Sepulveda Project - public hearings needed on this huge development project at

Exposition and Sepulveda To: [email protected]

Dear Commissioner Chu:

The Casden-Sepulveda Development project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles. The project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.

As a resident living in Mar Vista, I oppose this project as proposed. Traffic is already impossible

for most of the day in the area of this porject. I want to see local hearings where I and other stake-

holders can evaluate the proposal and make important changes that we believe will affect the

quality of our lives in our neighborhood. At the same time, we support the Expo Line and the

station proposed at Exposition and Sepulveda

Sincerely,

Ruth Cuadra

3171 Purdue Ave., Los Angeles, 90066  

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From: Pamela Day <[email protected]>

Date: Mon, Dec 3, 2012 at 10:18 AM

Subject: CORRECTION: CD11 Transp. Adv. Comm. motion opposing the Casden/Sepulveda

project (Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR,

CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB)

To: [email protected], [email protected], [email protected],

[email protected], [email protected], [email protected],

[email protected], [email protected], [email protected],

[email protected], [email protected]

Please note that Mr. Alpern does not speak for us. Many of us do NOT oppose this project and

instead, support it. Please consider Mr. Alpern's voice as that of one individual and one that

does not speak for all of us.

--- Pamela Day Crimson Holdings 825 S. Barrington Ave Los Angeles, CA 90049 tel: 310-405-0901 ext. 101 On 2012-12-03 10:33, [email protected] wrote:

To the Honorable Mr. Henry Chu, the Honorable Mr. Michael LoGrande, the Honorable Councilmember Bill Rosendahl and the Honorable Councilmember Paul Koretz:

The grassroots CD11 Transportation Advisory Committee, which has members from both CD11 and CD5 to weigh in on and represent Westside neighborhood councils and neighborhood associations on transportation and related matters, approved the following motion 10-0-0 on November 19th, 2012:

The CD11 Transportation Advisory Committee opposes the Casden-Sepulveda Development (Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB), and demands it not receive any approval of any zone change, tract map, or variance at the upcoming Planning Hearing on Wednesday, December 5th, 2012 (10:00 a.m., West Los Angeles Municipal Building Hearing Room, Room #200). The project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles, and therefore the project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described

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in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit. The CD11 Transportation Advisory Committee therefore opposes any spot-zoning and land use changes for this project. Most Sincerely, Kenneth S. Alpern and David Ewing

Co-Chairs, CD11 Transportation Advisory Committee  

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From: Marsha Epstein <[email protected]>

Date: Thu, Dec 6, 2012 at 6:34 PM

Subject: Casden-Sepulveda Project

To: [email protected]

To: Mr. Henry Chu, Member of L.A. City Planning Commission Re: Casden-Sepulveda Project - public hearings needed on this huge development project at Exposition and Sepulveda Dear Commissioner Chu: The Casden-Sepulveda Development project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles. The project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit. As a resident living in Mar Vista, I oppose this project as proposed. I want to see local hearings where I and other stake-holders can evaluate the proposal and make important changes that we believe will affect the quality of our lives in our neighborhood. At the same time, we support the Expo Line and the station proposed at Exposition and Sepulveda. Sincerely, Marsha Epstein 3200 Butler Ave Los Angeles, CA 90066

 

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From: Miles Feinberg <[email protected]>

Date: Fri, Nov 30, 2012 at 5:28 PM

Subject: Casden West LA

To: [email protected]

Mr. Chu,

Please add me to the list of supporters for the Casden West LA project. I will not be at next

week’s hearing, but I think it’s my obligation to write you. As a life-long resident of Los Angeles,

I am sick and tired of the status-quo. Packed freeways, crowded boulevards, few walkers, few

bicycles and empty seats on public transit. Thankfully, this disappointing trend seems to be

changing. We are investing lots of money in transit like the Expo Line and Subway to the Sea,

and it appears that the powers that be have finally “gotten the memo.” Now that we have spent

the capital, we need to do everything we can to make sure there is real positive change to our

city. Bottom line, this project helps promote the use of the Expo Line by encouraging the

residents who live there and the workers who commute there to use public transit. From Santa

Monica to Downtown, the Expo Line connects our city in a way we have not seen before. I hope

to see transit-oriented developments like Casden’s built near all the stations. I think it is the right

thing to do for our city.

Miles Feinberg

17 28th Avenue

Los Angeles, CA  

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From: Elly Fry <[email protected]> Date: Thu, Dec 6, 2012 at 6:33 PM Subject: Casden-

Sepulveda development To: [email protected]

[email protected]

To: Mr. Henry Chu, Member of L.A. City Planning Commission

Re: Casden-Sepulveda Project - public hearings needed on this huge development project at Exposition and Sepulveda

Dear Commissioner Chu:

The Casden-Sepulveda Development project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles. The project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.

As a resident living in Mar Vista, I oppose this project as proposed. I want to see local hearings

where I and other stake-holders can evaluate the proposal and make important changes that we

believe will affect the quality of our lives in our neighborhood. At the same time, we support the

Expo Line and the station proposed at Exposition and Sepulveda.

Most Sincerely,

Eleanor Fry 2819 Stoner Ave. Los Angeles, CA 90064  

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From:  Joan  Gallagher   <[email protected]>  Date:  Thu,  Dec  6,  2012  at  2:40  PM  Subject:  Casden  -­‐  Sepulveda  project  To:  [email protected]            Dear Commissioner Chu:      While I applaud the idea of smart development, it appears this project violates the final EIR negatively impacting the surrounding community. Until which time there can be more public hearings on the project it should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with the Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.      Thank you.      Joan Gallagher    

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From: DGARVEN <[email protected]> Date: Tue, Dec 11, 2012 at 7:48 AM Subject: Re:

Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA

#ENV-2008-3989-EIR, Related Case #VTT-70805-GB To: 1-1Garven <[email protected]>

Sirs:

Please do not allow the Casden project to go ahead as planned. Please read the enlarged bold-faced type below (excerpted from a City Watch article dated today December 11th) regarding parking on the site. I couldn’t say it any better. It’s time to think ahead “out of the box.”

I’d also like to say that whatever form the development takes at Pico/Sepulveda it will increase traffic, Casden or any other project. But it’s something I’ve learned to live with because that’s expected here in LA where we love to build!, build!, build!, build!. Every week I travel north on Sepulveda about 8:30 AM and traffic is always stop and go from just north of National to just south of Pico.

But please read the article below --- Casden is NOT RIGHT for the area.

Dorothy Garven

3630 Inglewood Blvd. LA 90066

(310) 391-9840

Parking Meters Broken, Parking Promises Broken, Spirit NOT Broken in LA

Ken Alpern and Tom Ponton

11 Dec 2012

PARKING POLITICS - It’s difficult to avoid the conclusion that “it’s no use fighting City Hall”, but the advent of the Internet and Neighborhood Councils has allowed us to choose that very option—so it’s anyone’s guess as to whether fighting the unfair City law ticketing individuals who use parking

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spaces with broken meters, and fighting this City’s unenlightened parking policy, is either courage or naiveté at its best … or worst. Take, for instance, the latest vote by the City Council to reaffirm its practice of ticketing motorists who use broken meters—approved 12-1, with credit going to Jan Perry for doing the right thing and opposing this practice, which is quite likely in contradiction to state law. It is both disappointing but quite consistent with City Council history in its vote, which makes drivers the victims when parking meters are broken in a City which is as parking-poor as any major city on this planet. It is an outrageous rip-off of LA citizens who have to search for a parking space and when they finally find one, spend time maneuvering into it, gathering their belongings, locking the car, finding coins or credit card to pay, and then discover the meter is broken. At this point they are faced with risking a $63 ticket, or getting back in their car and driving around again looking for a “legal” space. This neither helps our traffic congestion nor our mobility problem, and most drivers are not even aware of this unfair practice—which contradicts attempts by state lawmakers to stop unfair ticketing practices in some cities. This practice may help LA City coffers a bit, but for every motorist nailed with this unfair tax, it’s one more guaranteed “no” vote for raising City sales taxes by a half-cent (also approved as a spring 2013 ballot measure by the benevolent and enlightened Herb Wesson and the LA City Council). The Times article mentions that the LADOT reported its old parking meters were commonly vandalized by fee-avoiding miscreant motorists, but that only five meters a month require repair now that they’re newer and take both credit cards and cash. Yet the same LADOT spokesman reports that ongoing tickets for broken meter violations generate $5 million a year … which averages out to $83,333 per broken meter during only 3 hours on average that the City reports each is broken. So the “real story” begs for elaboration and dissemination to the tax- and fee-burdened public. Of course, this is the same City of LA that continues to underserve its citizens’ parking needs: although there are many parking lots and spaces that the city already oversees, it’s evident that we don’t have enough parking infrastructure to meet our commuters’ and shoppers’ needs. It’s also evident that LA needs to emulate the neighboring cities of Santa Monica and Culver City, which have done quite well with large parking structures and lots that generate revenue and get people out of their cars and onto pedestrian-friendly commercial corridors. Our response: we use paradigms such as “transit, not parking” or use adjacent residential streets to access commercial corridor destinations. “Parking guru” and UCLA Professor Shoup may have been wrong when he overplayed the “transit, not parking” paradigm, but he is spot-on when he advocates using our parking meters and lots to more effectively generate revenue for the City of Los Angeles. Revenue that can and should go to public/private partnerships such as the Westside Regional Transportation Center concept, which is a vital project that should be built adjacent to the future Exposition/Sepulveda Rail Expo Line station (and when the planning and funding comes, a connecting station for the future north-south transit line that Measure R funds to connect the Westside with the Valley). Unfortunately, that land parcel, which is also adjacent to the critical Pico

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commercial corridor and equally-critical Sepulveda and Sawtelle corridors, is owned by Alan Casden who, as I’ve opined previously to CityWatch is creating a car-oriented development at a transit-adjacent site and threatening the credibility of the Metro transit and City Planning process. Equally unfortunate is that at last Wednesday’s special Planning meeting to address the Casden project, we learned from the Casden team that it is “working with and in contact with Metro, City Planning and Neighborhood Councils” to improve and mitigate for this transit-oriented project that will get people out of their cars. ● Yet my own contacts with the Expo Line Construction Authority report that it has stopped trying to deal with the Casden team and is moving forward with the Expo Line construction process without considering the Casden project—which currently has 2000 parking spaces devoted to a car-oriented residential and commercial project, but ZERO spaces devoted to Expo Line riders, and which currently forces Expo Line riders to walk up Sepulveda and to Pico Blvd. and denies them direct project access. ● Yet every Neighborhood Council and community group has said “NO!” to the project as is, and wants a more environmentally-friendly and transit-friendly (not just transit-adjacent) project—in large part because it is so huge that it violates the West LA Community Plan and because it is oriented to CAR access, not RAIL/TRANSIT access. ● Yet City Planning just had a meeting at the Henry Medina Parking Enforcement Building (next to the future Expo Line station and Casden project—how ironic but fitting!) last Monday to focus on what SHOULD be built adjacent to the Exposition/Sepulveda station and along the Pico corridor, and IGNORED the Casden/Sepulveda Project altogether. Fortunately, Bill Rosendahl and Paul Koretz, whose council districts both include and abut the Casden/Sepulveda project, have come out strongly against the project as is, but it’s anyone’s guess as to whether the other thirteen councilmembers will support their position. There IS an answer that is both jobs-friendly, environment-friendly, and will enhance—not obstruct—access of commuters to the future Exposition/Sepulveda station, which should be the site of a public/private partnership between Metro, the City of LA and private developers to include the aforementioned Westside Regional Transportation Center and establish a large park-and-ride parking lot as well as for facilities to enhance bus, jitney, bicycle and pedestrian access and multimodal transfers to other forms of transportation. Any project at this site should be a facilitating factor for the Pico commercial corridor, and an industrial/commercial Internet/Media jobs center with accompanying restaurants could be a boon to the region. And if a residential component MUST be included, perhaps a hotel should be considered with indoor rooms, an indoor pool, and a community center to attract transit-using tourists and an army of jobs for the Westside…without forcing people to breathe fumes from the adjacent I-405 freeway. It’s hoped that Councilmembers Rosendahl and Koretz (and the entire City Council) will also reverse course on their parking policies—especially that which penalizes motorists who are too-often stuck between parking spaces with either broken meters, or no parking spaces at all.

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We need to HELP, not HURT, the motorists of L.A. who are quite frequently the loyal and taxpaying citizens of Los Angeles. More parking should be built to get motorists off the streets and onto our sidewalks (and into our businesses). We may have to deal with broken parking meters, broken parking policy, broken promises on the part of developers and City officials, and broken Planning processes … but the spirit of Angelenos to move our City forward into the 21st Century remains anything but broken. (Ken Alpern is a Westside Village Zone Director and Boardmember of the Mar Vista Community Council (MVCC), and is Co-Chair of the MVCC Transportation/Infrastructure Committee. He is co-chair of the CD11 Transportation Advisory Committee and chairs the nonprofit Transit Coalition, and can be reached at [email protected] This email address is being protected from spambots. You need JavaScript enabled to view it. . Tom Ponton is a co-founder and a past (and first-elected) Chair of the Board of the Mar Vista Community Council (MVCC, and is currently co-chair of the MVCC Recreation and Open Spaces Committee. He can be reached at: [email protected] This email address is being protected from spambots. You need JavaScript enabled to view it. The views expressed in this article are solely those of Mr. Alpern and Mr. Ponton.)  

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From: Ruth Gould Goodman <[email protected]>

Date: Fri, Dec 7, 2012 at 10:40 AM

Subject: Fwd: {Disarmed} Demand public hearings on Casden-Sepulveda Project - the huge

development project at Exposition and Sepulveda

To: [email protected]

To: Mr. Henry Chu, Member of L.A. City Planning Commission

Re: Casden-Sepulveda Project - public hearings needed on this huge development project at Exposition and Sepulveda

Dear Commissioner Chu:

The Casden-Sepulveda Development project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles. The project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.

As a resident living in Mar Vista, I oppose this project as proposed. I want to see local hearings where I and other stake-holders can evaluate the proposal and make important changes that we believe will affect the quality of our lives in our neighborhood. At the same time, we support the Expo Line and the station proposed at Exposition and Sepulveda.

Most Sincerely,

Ruth Gould-Goodman 90291  

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From: Linda Guagliano <[email protected]>

Date: Mon, Dec 3, 2012 at 6:12 PM

Subject: Fw: Re: Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CU B-

DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB:

To: [email protected]

Henry Chu - Please note the folowing message and do not allow the Casden project to come to

pass. We have enough problems with traffic on the Westside without allowing projects like this

to interfere with our life.

Linda Guagliano, Mar Vista

---------- Forwarded Message ---------- From: STEVE WALLACE <[email protected]> To:

[email protected] Subject: Re: Casden-Sepulveda Development: Case #CPC-2008-4604-

GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-

GB: Date: Sun, 02 Dec 2012 21:26:08 -0800 Mr. Chu All of the streets around this proposed

development are currently gridlocked. The last traffic study that was done in this area a couple of

years ago had a massive increase in traffic, more than the streets and intersections can

handle. The Metro Expo Line train will bring further delays to traffic in this area with the "at

grade crossings", this development will further cause massive grid lock in traffic on all the streets

both East, West and North and South. When someone provides 2000+ Parking Spaces, they

expect 2000+ cars, this is way more than this area can handle.

1. The Pico/Sepulveda intersection is already jammed as one of the few east west passages under the 405. Adding a major traffic generator there is ill conceived. 2. Sepulveda serves as an alternate to the 405, and carries a large amount of traffic to/from the National on/off-ramps. 3. Should Expo go in, traffic congestion at Pico/Sepulveda will block access to Expo from all directions. How will emergency services get through?

4. It is morally reprehensible to house men, women, children and seniors so close to a freeway where the poor air quality creates life-long and life-shortening health impacts. Studies show this is costing society millions in illness. 5. Projects along transit lines and around stations should be planned as part of outreach to impacted neighborhoods and through local community plan processes, not piecemealed in the absence of an approved Community Plan. 6. Projects along transit lines and around stations should be planned in harmony with the character of the community

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7. The only purpose for placing tall buildings next to the freeway are super graphics and digital billboards, creating more visual blight

-- Steve Wallace 3820 Coolidge Avenue Los Angeles, CA 90066  

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From: Gurzeler, Fred <[email protected]>

Date: Tue, Dec 4, 2012 at 11:29 AM

Subject: RE: CD11 Transp. Adv. Comm. motion opposing the Casden/Sepulveda project

(Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA

#ENV-2008-3989-EIR, Related Case #VTT-70805-GB)

To: "[email protected]" <[email protected]>, "[email protected]"

<[email protected]>, "[email protected]"

<[email protected]>, "[email protected]"

<[email protected]> Cc: "[email protected]"

<[email protected]>, "[email protected]" <[email protected]>,

"[email protected]" <[email protected]>, "[email protected]"

<[email protected]>, "[email protected]" <[email protected]>,

"[email protected]" <[email protected]>, "[email protected]"

<[email protected]>, "[email protected]" <[email protected]>, "[email protected]"

<[email protected]>

Gentlemen,   As  a  resident  who  would  be  adversely  affected  by  the  Casden-­‐Sepulveda  Development,  I  respectfully  add  my  voice  to  those  opposed  to  the  project.    To  allow  the  development  to  proceed  is  to  say,  in  effect,  that  EIRs,  Community  Plans  and  Neighborhood  Advisory  Committees  are  simply  inconveniences  that  can  be  ignored  at  will.   Too  often  projects  such  as  the  Casden-­‐Sepulveda  Development  are  approved  by  people  far  removed  from  the  area  in  question.    Perhaps  the  first  thing  one  should  always  ask  before  green  lighting  such  a  project  is:  Would  I  want  to  live  next  door  to  it?    Unlike  a  project  such  as  Expo  Rail  which  undeniably  benefits  the  greater  public,  the  Casden-­‐Sepulveda  Development  only  benefits  Casden  Development.    Community  Plans  exist  to  prevent  over  development.    Few  may  still  recall  how  the  late  Councilman  Marvin  Braude  put  a  stop  to  the  high-­‐rise  office  buildings  that  were  suddenly  springing  up  in  the  Wilshire/Bundy  area  to  the  horror  of  the  surrounding  neighborhoods.    Although  it  was  too  late  to  stop  the  buildings  already  under  construction,  it  would  have  been  much  worse  for  the  area  if  the  building  trend  had  been  allowed  to  continue  unabated.    By  not  approving  the  Casden  Project,  it  will  send  a  clear  message  that  past  mistakes  allowing  over  development  will  not  be  repeated.   Would  I  want  to  live  next  door  to  the  Casden  project?  For  myself  and  the  people  who  reside  in  CD11  and  CD5  the  answer  is  clearly  NO.   Please  do  not  approve  the  Casden-­‐Sepulveda  Development.   Sincerely  Yours,   Fred  Gurzeler Westside  Village  Homeowner  

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From: Margaret <[email protected]>

Date: Tue, Dec 4, 2012 at 5:51 PM

Subject: Casden Sepulveda Project

To: [email protected] Cc: [email protected],

[email protected], [email protected],

[email protected], [email protected]

December 4, 2012

Mr. Henry Chu, Hearing Officer

City of Los Angeles Department of City Planning

200 N. Spring Street

Room 750, City Hall

Los Angeles, CA 90012

Subject: Casden Sepulveda Project CPC-2008-4606-GPA-ZC-HD-CUB-DB-SPR ENV-2008-

3989-EIR

Dear Mr. Chu: I am opposed to the above project for the following reasons:

1) The FEIR ignores the impact of a huge project such as this on streets that are east and north of

the project. In the FEIR, a question regarding cut-through traffic was answered by the response

that "...most of the local/residential streets in the vicinity of the Development Project site are

discontinuous due to interruption by the Santa Monica Freeway and/or the San Diego rights-of-

way..." (FEIR Page III-31). This assertion completely ignores the fact that there is an entire

section of the adjacent community NORTH AND EAST of the proposed project where we are

already severely impacted by cut-through traffic going between Pico and Olympic and points

north. Consider, for example, Veteran Avenue which has traffic signals at Olympic and Santa

Monica Boulevard. This residential street will no doubt be used as an alternative to what will be

even more congested Sepulveda and Westwood Boulevards. The single stop sign on Tennessee,

another street that will carry far more traffic as a result of the development, will not deter cut-

through traffic. How an FEIR could have ignored the impact on the community north and east of

this project is rather startling and shows a real deficiency in the FEIR.

2) The FEIR provided no analysis of meaningful project alternatives that sought to preserve the

industrial zoned land, which City planners have been asking for.

3)Residential units should not be placed so close to a freeway because of proven health risks to

occupants, children in particular.

4) This project is FAR TO LARGE for this community and its already congested streets. There

are so many negative environmental aspects that the developer admits cannot be mitigated.

However, he is wrong about this. Clearly, the way to mitigate the impacts is to RADICALLY

DOWNSIZE THE PROJECT or CHOOSE AN ALTERNATIVE that would preserve the

industrial zoned land.

Thank you, Mr. Chu, for considering my reaction to the FEIR for the Casden Sepulveda Project.

Margaret Healy Board Member Westwood South of Santa Monica Blvd. Homeowners

Association  

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December 4, 2012 Re: Casden Project – Expo and Sepulveda To Whom It May Concern, I am totally against a project of this size in this location. The propositons by the Casden people for any mitigations to the neighborhood are wholly underwhelming and it is clear they do not care what happens to the West of Westwood HOA community. The lack of regard for ingress and egress to and from the project along Sepulveda and Pico (and taking out Sawtelle) is not well thought out and will only cause major traffic impacts, traffic jams, and chaos to the Sepulveda Blvd, Pico Blvd and the neighborhoods. A project of this size has no business being in an area like this, rail or no. Parking for hundreds of units, access to the gigantic retail being proposed again, is not well thought out. Without a complete and fully detailed EIR, which I’m sure will bear out the lack of facilities to fully complement a project being proposed of this size, is mandatory. I implore the City Council, the Mayor, the affected departments, county and state agencies to overlook the dollar signs and look at the neighborhood impacts, the traffic impacts and to take into account the affect of rail service which is coming in this neighborhood, which has not being looked at by the Casden company. I am against this project as it stands. Until something that is proposed that takes into account the longstanding good neighbors and family neighborhood my position does not change. Sincerely, Charles Horwitz 2630 Bentley Avenue Los Angeles, CA 90064

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From: Carol Iu <[email protected]> Date: Sun, Dec 9, 2012 at 4:43 PM Subject:

Pico/Sepulveda development To: [email protected]

Dear Mr. Chu, I am a resident of west LA and I drive around Pico/Sepulveda often. The idea of

a major development in that intersection is a nightmare. Already, the west side traffic is

extrememly congested. You can experience grid-lock traffic after 2 p.m. every day, especially

the east-going traffic. Pico, Olympic, National, Venice, Palms are streets I have tried to navigate

but there is no easy path. The intersections with north-south streets in the area -- Sepulveda,

Sawtelle, Barrington, Bundy are impossible. With the Expo Metro line coming to the area, the

traffic will only get much worse.

Residents like myself are not against development, but it must be thoughtfully done, with the

participation of neighborhood groups through community-based planning. I do not think this has

been done and it is irresponsible to allow this project to go forward.

Sincerely, Carol Iu 11050 Charnock Road

 

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From: Leonor Jacquard <[email protected]> Date: Fri, Dec 7, 2012 at 12:24 PM Subject:

Casden-Sepulveda Project - public hearings needed on this huge development project at

Exposition and Sepulveda To: [email protected]

To: Mr. Henry Chu, Member of L.A. City Planning Commission

Re: Casden-Sepulveda Project - public hearings needed on this huge development project at Exposition and Sepulveda

Dear Commissioner Chu:

The Casden-Sepulveda Development project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles. The project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.

As residents living in West Los Angeles, we oppose this project as proposed. We want to see

local hearings where all stake-holders can evaluate the proposal and make important changes that

we believe will affect the quality of our lives in our neighborhood.

Sincerely,

Maria Leonor Jacquard Sanford E. Jacquard

 

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From:  Michelle  Steenson  Jones   <[email protected]>  Date:  Thu,  Dec  6,  2012  at  10:28  AM  Subject:  Casden  Major  Development  To:  [email protected]        Mr.  Chu    All  of  the  streets  around  this  proposed  development  are  currently  gridlocked.    The  last  traffic  study  that  was  done  in  this  area  a  couple  of  years  ago  had  a  massive  increase  in  traffic,  more  than  the  streets  and  intersections  can  handle.    The  Metro  Expo  Line  train  will  bring  further  delays  to  traffic  in  this  area  with  the  "at  grade  crossings",  this  development  will  further  cause  massive  grid  lock  in  traffic  on  all  the  streets  both  East,  West  and  North  and  South.    When  someone  provides  2000+  Parking  Spaces,  they  expect  2000+  cars,  this  is  way  more  than  this  area  can  handle.    1. The Pico/Sepulveda intersection is already jammed as one of the few east west passages under the 405. Adding a major traffic generator there is ill conceived. 2. Sepulveda serves as an alternate to the 405, and carries a large amount of traffic to/from the National on/off-ramps. 3. Should Expo go in, traffic congestion at Pico/Sepulveda will block access to Expo from all directions. How will emergency services get through? 4. It is morally reprehensible to house men, women, children and seniors so close to a freeway where the poor air quality creates life-long and life-shortening health impacts. Studies show this is costing society millions in illness. 5. Projects along transit lines and around stations should be planned as part of outreach to impacted neighborhoods and through local community plan processes, not piecemealed in the absence of an approved Community Plan. 6. Projects along transit lines and around stations should be planned in harmony with the character of the community 7. The only purpose for placing tall buildings next to the freeway are super graphics and digital billboards, creating more visual blight Thank you for your consideration, Michelle Jones  

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From:  Lillian  Laskin   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  10:19  PM  Subject:  Re:  Casden-­‐Sepulveda  Project  To:  [email protected]      ====  To: Mr. Henry Chu, Member of L.A. City Planning Commission  Dear Commissioner Chu:  

The Casden-Sepulveda Development project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles. The project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.  As a resident living in Mar Vista, I oppose this project as proposed. I want to see local hearings where I and other stake-holders can evaluate the proposal and make important changes that we believe will affect the quality of our lives in our neighborhood. At the same time, we support the Expo Line and the station proposed at Exposition and Sepulveda.    Most Sincerely,    Lillian Laskin  3145 Coolidge Ave  Los Angeles, CA 90066    

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Executive Officers Jacob Lipa, Chairman Psomas Brad Cox, Immediate Past Chairman Trammell Crow Company Alan Rothenberg, Vice Chairman 1st Century Bank Nadine Watt, Vice Chairman Watt Companies Richard Ziman, Vice Chairman, Chairman’s Circle American Value Partners Mary Leslie, President Los Angeles Business Council David Sears, Treasurer JP Morgan Asset Management Chairman’s Circle Celeste Altimari, Haworth Javier Angulo, Walmart Ellen Berkowitz, Gresham Savage Nolan & Tilden, PC Linda Bernhardt, Greenberg Traurig Patricia T. Clarey, Health Net, Inc. David Cobb, HDR, Inc. Andy Cohen, FAIA, Gensler Joaquin DeMonet, Arden Realty Kevin Dow, Turner Construction Co. John Ek, Ek & Ek Frank Faye, SunCal Tom Flintoft, Kindel Gagan Melinda Franklin, United Airlines Amy Freilich, Armbruster Goldsmith & Delvac LLP Sean Gallagher, K Road Power Ron Griffith, Century Housing Corporation Arno Harris, Recurrent Energy Mary Hemmingsen, Brookfield Renewable Power Carlos Herrera, Interior Removal Specialist, Inc. Carlos Illingworth, Safeway/Vons Deborah Kallick, Cedars-Sinai Health System Sharon Keyser, Paramount Pictures Janet Lamkin, Bank of America Bryan Leroy, Manatt, Phelps & Phillips LLP Antonio Manning, J.P. Morgan Chase & Co. Mike Massey, National ITC Corporation Allan McArtor, Airbus Americas, Inc. George Mihlsten, Latham & Watkins Andrew Millar, Hensel Phelps Construction Co. Ron Nichols, LA Dept. of Water & Power Kelly Olson, HMC Architects Jerry Porter, CresaPartners Kevin Ratner, Forest City Tom Roell, Parsons Michael Rosenfeld, Next Century Associates, LLC Carmel Sella, Wells Fargo Bank Sarah Shaw, JMB Realty Corporation Patti Shwayder, AIMCO Lori Tierney, Unisource Solutions Mike Whatley, SunPower Jim Willson, National Electrical Contractors Association Gillian Wright, Sempra Energy Utilities

December 3, 2012 Henry Chu, Hearing Officer Los Angeles Department of City Planning 200 North Spring Street, Room 750 Los Angeles, CA 90021 Dear Mr. Chu: Our mission at the Los Angeles Business Council (LABC) is to unite the power of business with the power of government for education and advocacy to promote environmental and economic sustainability. We believe that the Casden West LA project exemplifies many of the virtues that we preach, including the importance of job creation, revenue generation, and smart and thoughtful development that is designed with high environmental standards. LABC believes strongly that this project is good for our city, and above all, makes sense given its location next to an Expo Line station. LABC has become an influential link between business and city government and has had a major impact on sustainability, workforce housing, transportation, job creation, education and business development policy. It is a known fact that there is a desperate need for quality housing on the Westside. With more than 500 new apartments, including an affordable senior housing component, we feel that this project will help fill a major gap in the market. Combine the housing with the more than 260,000 square feet of commercial space and you will have well over 1,000 new jobs. This obviously is not including the near 1,500 sorely needed construction jobs. We at the LABC believe that transportation and environmental sustainability goes hand in hand. With the growing population, increased understanding of global warming, and frustrating traffic gridlock, never has it been more important for our region to look to public transit as a means to help alleviate these concerns. With phase 2 of the Expo Line scheduled to be up and running by 2015, it is imperative that we build the proper infrastructure around it to ensure maximum ridership. The Casden West LA project is the exact type of transit-oriented development that belongs at this site. This development will be more than just apartments and shopping. With the close proximity to the Expo Line and major bus stops, a large-scale bicycle station, reserved parking for ride-sharing vehicles, and potentially a bus layover zone within the property, this project could represent a real transit center for the region. The LABC is proud to support this project, and we urge the Mayor, City Council, and the Planning Department to join us. Sincerely,

Mary Leslie President, Los Angeles Business Council

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From:  Kathleen  LeVasseur   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  9:00  PM  Subject:  new  building  construction  in  West  Los  Angeles.  To:  "[email protected]"  <[email protected]>      Mr. Chu

All of the streets around this proposed development are currently gridlocked.

The last traffic study that was done in this area a couple of years ago had a massive increase in

traffic, more than the streets and intersections can handle.

The Metro Expo Line train will bring further delays to traffic in this area with the "at grade

crossings", this development will further cause massive grid lock in traffic on all the streets both

East, West and North and South.

When someone provides 2000+ Parking Spaces, they expect 2000+ cars, this is way more than

this area can handle.

1. The Pico/Sepulveda intersection is already jammed as one of the few east west passages under the 405. Adding a major traffic generator there is ill conceived. 2. Sepulveda serves as an alternate to the 405, and carries a large amount of traffic to/from the National on/off-ramps. 3. Should Expo go in, traffic congestion at Pico/Sepulveda will block access to Expo from all directions. How will emergency services get through? 4. It is morally reprehensible to house men, women, children and seniors so close to a freeway where the poor air quality creates life-long and life-shortening health impacts. Studies show this is costing society millions in illness. 5. Projects along transit lines and around stations should be planned as part of outreach to impacted neighborhoods and through local community plan processes, not piecemealed in the absence of an approved Community Plan. 6. Projects along transit lines and around stations should be planned in harmony with the character of the community 7. The only purpose for placing tall buildings next to the freeway are super graphics and digital billboards, creating more visual blight  

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PLASTERS LOCAL UNION 200
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From: Aaron Luber <[email protected]>

Date: Fri, Nov 30, 2012 at 1:53 PM

Subject: Casden Project

To: [email protected]

Mr. Chu,

I will be traveling and unable to attend the hearing for Casden’s project on Sepulveda. I would like to voice my support for this project as I think it is the type of development we need as our population grows and we will have no choice but to begin using public transportation at a much higher rate. If we choose not to invest in transit and the right development to build around it, I am afraid that traffic and the health of our world will be worse off for it. I strongly encourage you and our elected officials to approve this project, and begin moving our city in the right direction for a better future.

Aaron Luber 1154 South Barrington Ave #317 Los Angeles, CA 90049  

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From: Christopher McKinnon <[email protected]>

Date: Mon, Dec 3, 2012 at 12:20 PM

Subject: Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR,

CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB:

To: [email protected] Cc: [email protected],

[email protected], [email protected],

[email protected], [email protected]

Dear  Mr.  Chu,   Casden-­‐Sepulveda  Development:  Case  #CPC-­‐2008-­‐4604-­‐GPA-­‐ZC-­‐HD-­‐CUB-­‐DB-­‐SPR,  CEQA  #ENV-­‐2008-­‐3989-­‐EIR,  Related  Case  #VTT-­‐70805-­‐GB:     I  strongly  object  to  this  massive  development.     Transit  Oriented  Development  is  a  cover  story  for  OVERdevelopment  and  will  only  increase  transportation  and    infrastructure  problems  in  this  and  surrounding  communities  and  will  not  help  solve  the  housing  issues  for  middle  and  economically  challenged  residents  of  Los  Angeles.   Sincerely,   Christopher  McKinnon

11837  North  Park  Avenue

Los  Angeles,  CA  90066  

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From: Annette Mercer <[email protected]>

Date: Mon, Dec 3, 2012 at 9:50 PM

Subject: Opposition to the Casden/Sepulveda project (Casden-Sepulveda Development: Case

#CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case

#VTT-70805-GB)

To: [email protected], [email protected], [email protected],

[email protected] Cc: Christopher Koontz <[email protected]>

Mr. Henry Chu, Hearing Officer

City of Los Angeles Department of City Planning

200 N. Spring Street

Room 750, City Hall

Los Angeles, CA 90012

Subject: Casden Sepulveda Project

CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR

ENV-2008-3989-EIR

To the Honorable Mr. Henry Chu, the Honorable Mr. Michael LoGrande, the Honorable Councilmember Bill Rosendahl and the Honorable Councilmember Paul Koretz:

I fully support the motion passed by the CD11 Transportation Advisory Committee,on November 19th, 2012:

The CD11 Transportation Advisory Committee opposes the Casden-Sepulveda Development (Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB), and demands it not receive any approval of any zone change, tract map, or variance at the upcoming Planning Hearing on Wednesday, December 5th, 2012 (10:00 a.m., West Los Angeles Municipal Building Hearing Room, Room #200). The project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles, and therefore the project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit. The CD11 Transportation Advisory Committee therefore opposes any spot-zoning and land use changes for this project. In addition, I would like to add my own opposition to this horribly oversized and inappropriate

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development. This developer has not listened to the community's concerns, proposed reasonable

alternatives suggested in the DEIR comments, or responded in any meaningful way to DEIR

comments. The same community concerns of traffic, land use, etc. remain.

Sincerely,

Annette Mercer

2647 Glendon Ave. LA 90064

 

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Painters & Allied Trades

District Council 3 6ONE UNION

oGrant MitchellBusiness Manager

DRYWALL FINISHERS, FLOORLAYERS, GLAZIERS, PAINTERS, TRADESHOW& SIGNCRAFT

Sent by mail

December 3, 2012

Paul Koretz, Councilmember5t"

District

Los Angeles City Hall200 North Spring Street, Rm. 440Los Angeles, CA 90012

Re: Casden West LA ( CPC- 2008-4604- GPA- ZC- HD- CUB- DB- SPR)

Honorable Councilmember Paul Koretz:

The Painters and Allied Trades District Council # 36 would like to express our strongsupport for Casden West LA, LLC and their proposed transit-oriented, mixed- usedevelopment at 11122 W. Pico Boulevard and 2341- 2441 S. Sepulveda Boulevard inWest Los Angeles. In this challenging economy, creating jobs and revenue sources isvital to our City' s recovery. This project shows the importance of smart growth, creatingsustainable communities, and building the proper infrastructure for the future.

We support development that creates significant employment. With nearly 1, 500construction jobs and over 1, 100 annual permanent jobs created, this project will helprevitalize the local economy. Over a 15 year period, the project will produce $34.6million in fees and tax revenue. In the City' s current budget crisis, generating newrevenue is our priority.

In addition to the tremendous economic benefits, this is a major opportunity to developa 6. 5- acre parcel directly adjacent to the future Expo Line at Sepulveda and ExpositionBoulevards. High- density developments along transit corridors are needed toaccommodate anticipated population growth, without a negative impact on

infrastructure. With 538 market- rate and affordable senior apartments and nearly270,000 square feet of commercial space, this project will transform the site into a placewhere people can easily commute by public transportation.

1155 Corporate Center Dr., Monterey Park, CA 91754 ( 800) 841- 4366 ( 626) 584-9925 Fax ( 626) 584- 1949M....:; 3

SERVER\ Fileserver\ Departments\ Political\ Correspondence\ Support Letters\ 20121203 Grant Mitchell Paul Koretz Casden WestLA. docx

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We in the Building Trades believe in building for the future. This is an opportunity wecannot afford to lose. We urge you to join us in supporting this essential development.

Thank you,

L G

Grant Mitchell,

Business Manager Recording SecretaryPainters and Allied Trades DC# 36

G M/ cm

Cc: Antonio Villaraigosa, Mayor

Herb Wesson, Council President

Ed Reyes, Councilmember, CDI

Bill Rosendahl, Councilmember CDI 11

Mitchell Englander, Councilmember, CD12

Jose Huizar, Councilmember, CD14

William Roschen, President, City Planning CommissionHenry Chu, Department of City Planning

1155 Corporate Center Dr., Monterey Park, CA 91754 ( 800) 841- 4366 ( 626) 584- 9925 Fax (626) 584- 1949

SERVER\ Fileserver\ Departments\ Political\ Correspondence\ Support Letters\ 20121203 Grant Mitchell_ Paul Koretz_ Casden WestLA. docx

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From: D. Mogerman <[email protected]> Date: Sun, Dec 2, 2012 at 9:37 PM Subject:

Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA

#ENV-2008-3989-EIR, Related Case #VTT-70805-GB: To:

Dear Guardian of the Public Trust, All of the streets around this proposed development are currently gridlocked. The last traffic study that was done in this area a couple of years ago had a massive increase in traffic, more than the streets and intersections can handle. The Metro Expo Line train will bring further delays to traffic in this area with the "at grade crossings", this development will further cause massive grid lock in traffic on all the streets both East, West and North and South. When someone provides 2000+ Parking Spaces, they expect 2000+ cars, this is way more than this area can handle.

1. The Pico/Sepulveda intersection is already jammed as one of the few east west passages under the 405. Adding a major traffic generator there is ill conceived. 2. Sepulveda serves as an alternate to the 405, and carries a large amount of traffic to/from the National on/off-ramps. 3. Should Expo go in, traffic congestion at Pico/Sepulveda will block access to Expo from all directions. How will emergency services get through?

4. It is morally reprehensible to house men, women, children and seniors so close to a freeway where the poor air quality creates life-long and life-shortening health impacts. Studies show this is costing society millions in illness. 5. Projects along transit lines and around stations should be planned as part of outreach to impacted neighborhoods and through local community plan processes, not piecemealed in the absence of an approved Community Plan. 6. Projects along transit lines and around stations should be planned in harmony with the character of the community

7. The only purpose for placing tall buildings next to the freeway are super graphics and digital billboards, creating more visual blight Sincerely, Dennis Mogerman 3447 Beethoven St. Mar Vista, CA 90066  

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From: D. Mogerman <[email protected]> Date: Wed, Dec 5, 2012 at 10:04

PM Subject: Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-

SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB: To:

Dear Mr, Chu,

This project really is bad news for Mar Vista. If you drive you know how much traffic is on the

streets, imagine this for a second:

1, Playa Vista second phase is completed - 2800 more residential units, 175,000 sq ft office space,

150,000 sq ft retail - lots of traffic to the South

2, Bundy Village (Bundy & Pico) bringing around 1800 car trips twice per day from this office

complex

3, Expo Line with tracks crossing all major North South Streets like Bundy and Sepulveda, when

the train comes, streets are blocked off, 10 mins for every train, at least 60 times a day.

4, The Casden development brings another 2000 parking spaces, so you can guarantee more than

2000 cars in and out twice per day.

Please do not allow this to happen. Please preserve some way of life here so we are able to leave

our homes with out being subjected to more traffic then we already have. If I think that I have to

sit in more traffic to dine at local restaurants or shop at local stores---then I will just stay home

and not spend my money if it means sitting in more traffic and have difficulty finding a parking

space on top of everything.

Thank you,

Dennis Mogerman

3447 Beethoven St. Mar Vista, CA 90066  

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From: Jack Neff <[email protected]>

Date: Fri, Dec 7, 2012 at 11:33 AM

Subject: Opposing Casden-Sepulveda Project

To: "[email protected]" <[email protected]>

Mr. Chu - The Planning Commissioner has taken steps to increase density again without proper review. Please do your part and make sure the Planning Commission performs a thorough review of environmental, traffic, geologic and quality of life issues surrounding the mega-dense Casden-Sepulveda project, which I understand is larger than the Bundy Village project. Right now I oppose the Casden-Sepuleveda project as overly-large, poorly thought out and have an overwhelming negative impact on everyday life in my community. Thank you. Jack Neff 1408 Brockton Ave., #9

Los Angeles, CA 90025  

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From:  Bill  Nuttle   <[email protected]>  Date:  Thu,  Dec  6,  2012  at  1:33  PM  Subject:  Casden-­‐Sepulveda  Project  -­‐  public  hearings  needed  on  this  huge  development  project  at  Exposition  and  Sepulveda  To:  [email protected]      Dear Commissioner Chu:  The Casden-Sepulveda Development project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles. The project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.  As  a  resident  living  in  Mar  Vista,  I  oppose  this  project  as  proposed.    I  want  to  see  local  hearings  where  I  and  other  stake-­‐holders  can  evaluate  the  proposal  and  make  important  changes  that  we  believe  will  affect  the  quality  of  our  lives  in  our  neighborhood.  At  the  same  time,  we  support  the  Expo  Line  and  the  station  proposed  at  Exposition  and  Sepulveda.        Most Sincerely,  Bill Nuttle  

2497  Wellesley  Avenue  

Los  Angeles,  CA  90064-­‐2735  

[email protected]  

(310) 312-6820  

Power concedes nothing without a demand. It never did and it never will. -Frederick Douglass  

 

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From:  Marla  Pelz   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  8:22  PM  Subject:  Re:  Casden-­‐Sepulveda  Development  (Case  #CPC-­‐2008-­‐4604-­‐GPA-­‐ZC-­‐HD-­‐CUB-­‐DB-­‐SPR,  CEQA  #ENV-­‐2008-­‐3989-­‐EIR,  Related  Case  #VTT-­‐70805-­‐GB)  To:  [email protected]      Dear Mr. Chu, I am writing as a follow up to the hearing on the above project. Although I wanted to attend, I was unable as I work seven days a week. I have a business on Pico Blvd., between Sepulveda and Westwood and vehemently oppose this project. Our streets are already at gridlock and will continue to get worse. We have to factor in the number of car trips for people planning on using the Expo line and driving around looking for extra spaces when they won’t be able to find one in the lot. We have to factor in the Expo line stopping traffic at the major intersections along the north/south streets, thus further causing additional gridlock on our streets. We have to factor in the additional cars that will be on the street because of the number of units proposed for this development. This project is too big for the area and does not belong here, Regards, Marla Pelz 10960 W. Pico Blvd. Los Angeles CA 90064  

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From:  Laurie  Pincus   <[email protected]>  Date:  Thu,  Dec  6,  2012  at  3:32  PM  Subject:  Fw:  Westside  residents  must  demand  public  hearings  on  huge  development  project  at  Exposition  and  Sepulveda:  Casden-­‐Sepulveda  Project  To:  [email protected]      Dear  Commissioner  Chu:    The  Casden-­‐Sepulveda  Development  project  as  currently  defined  and  described  in  the  Final  EIR  is  in  gross  violation  of  what  West  LA  needs.    It  will  create  much  more  traffic  than  we  can  afford.    As  a  resident  living  of  Mar  Vista,  I  oppose  this  project  as  proposed.    I  want  to  see  local  hearings  where  I  and  other  stake-­‐holders  can  evaluate  the  proposal  and  make  important  changes  that  we  believe  will  affect  the  quality  of  our  lives  in  our  neighborhood.  At  the  same  time,  we  support  the  Expo  Line  and  the  station  proposed  at  Exposition  and  Sepulveda.      Sincerely,      Laurie  Pincus    

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From:  Elizabeth  A.  Pollock   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  8:59  AM  Subject:  Casden-­‐Sepulveda  Development:  Case  No.  CPC-­‐2008-­‐4604-­‐GPA-­‐ZC-­‐HD-­‐CUB-­‐DB-­‐SPR,  CEQA  #  ENV-­‐2008-­‐3989-­‐EIR,  Related  Case  #VTT-­‐70805-­‐GB  To:  [email protected],  [email protected],  [email protected],  [email protected]  Cc:  [email protected],  [email protected],  [email protected],  [email protected],  [email protected],  [email protected],  [email protected],  [email protected],  "G.B."  <[email protected]>,  Brian  Reiff  <[email protected]>,  Chris  Nevil  <[email protected]>,  Cory  Watkins-­‐Suzuki  <[email protected]>,  Elizabeth  Pollock  <[email protected]>,  Marlene  Savage  <[email protected]>,  Mary  Cain  <[email protected]>,  [email protected],  Maureen  Madison  <[email protected]>,  Michelle  Rudo  <[email protected]>,  Sharon  Blunk  <[email protected]>,  Steve  Knight  <[email protected]>,  [email protected],  Wendy  Averill  <[email protected]>      In regards to the above captioned planning case, I very strongly endorse the CD11 Transportation Advisory Committee's motion to oppose any spot-zoning and land use changes for this project: The CD11 Transportation Advisory Committee opposes the Casden-Sepulveda Development (Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB), and demands it not receive any approval of any zone change, tract map, or variance at the upcoming Planning Hearing on Wednesday, December 5th, 2012 (10:00 a.m., West Los Angeles Municipal Building Hearing Room, Room #200).  

The project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles, and therefore the project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.  

The CD11 Transportation Advisory Committee therefore opposes any spot-zoning and land use changes for this project. Sincerely,  

Elizabeth A. Pollock  

11923 Bray Street  

Culver City, CA 90230  

(This is in the Del Rey neighborhood of Los Angeles.)  

 

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From:  Bill  Pope   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  7:10  PM  Subject:  Casden  Development:  Case  #CPC-­‐2008-­‐4604-­‐GPA-­‐ZC-­‐HD-­‐CUB-­‐DB-­‐SPR,  CEQA  #ENV-­‐2008-­‐3989-­‐EIR,  Related  Case  #VTT-­‐70805-­‐GB)  To:  [email protected]  Cc:  Chuck  Ray  -­‐  MVCC  Transportation  &  Infrastructure  Cmte  CoChair  <[email protected]>,  Sharon  Commins  -­‐  MVCC  Chair  <[email protected]>,  Ken  Alpern  -­‐  CD11  Transportation  Advisory  Committee  CoChair  <[email protected]>      Dear Mr. Chu,      Below are my comments on the two topics we discussed after Wednesday's hearing on the Casden West project.          LADOT's internal policies and practices violate the City's General Plan and have caused today's congestion.      Attached is the study of LADOT's internal traffic study and mitigation policies and practices I promised to send you. As you will see, if you do not already know, LADOT's internal policies and practices violate many of the City's official published General Plan Policies. This makes the City in violation of State Law 65300.      LADOT's internal traffic impact study and mitigation policies and practices has caused and are now accelerating the traffic congestion choking the City. They:      1. Under estimates the true transportation demand generated by land development projects by using ITE Trip Rates which are only observations of congestion-constraints flows possible during the most traffic-congested hour of the day(a rate which declines over time as congestion builds) in cities with better transit options that L.A., rather than true demand based on the numbers of commuters an L.A.-based unit is likely to house. It takes two incomes to purchase or rent most LA housing units today. Therefore each unit is like to generate 2 trips, not one-half trip.      2. Excuses from physical mitigation requirements development projects whose impacts LADOT deems "Insignificant". Today is allow developers to build up to 84 general-market condos and up to 525 so-called "Senior Living condos with multiple bedrooms, full kitchens and laundry rooms for active 55 year olds (claiming they will generate only 0.16 trip per unit) without the developer having to spend a dime on physical mitigation of the 1050 trips such a project can add.      3. Make no effort to maintain a "Satisfactory Level of Service" not to exceed LOS "E" (which is maximum capacity) as called for by all 35 Community Plans.[You just can't any more lenient than this.]      4. Allow traffic increases that cannot be accommodated (i.e., at LOS "F" intersections), in violation of all 35 Community Plans.      

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5. Employ "Transportation Specific Plans" for the most traffic congested areas of the City which exempt all residential development projects, and the other 30 most-command types of development project, from having to pay the Transportation Impact Assessment (TIA) Fee to be used by the City for regional improvements when no physical mitigations are possible at the project site.      6. Set thresholds for what constitutes a "Significant" impact to residential neighborhood streets so high that no single development project every triggers them, so neither developers nor the City make any attempt to fulfill its published General Plan policies to protect residential neighborhoods from cut-thru traffic.      7. Choose to interpret General Plan policies which call for the elimination of non-residential traffic on residential streets as excluding protection of the very streets typically used by cut-thru traffic. Cut-thru traffic can typically only use those streets designated as Collector streets because it is only the Collector streets which connect to arterial at signal-controlled intersections, thereby providing an alternate route for regional commuters to use. Yet LADOT excludes these from the streets it says it can protect.      Comments on the Casden West Project.      In view of all the un-mitigate-able issues raised in the FEIR and at Wednesday's Hearing, I believe that the City of Los Angeles needs to become pro-active in cleaning up the traffic congestion mess it has caused with the laxed traffic study and mitigation policies and practices outlined above, by purchasing the Pico-Sepulveda-Sawtelle-Exposition site and building a Transit Hub for the Westside. This Hub should include:      1) Parking for Westside transit riders,      2) Interchanges between:   - Expanded Sepulveda, Sawtelle and Pico bus lines,   - the East-West Expo Line,   - a Subway running north to the Valley, and   - a Monorail elevated over the 405 or Sepulveda running south to Long Beach.   (The water table south of Venice Bl. to high for subways.)      3) A maintenance yard for the above trains and buses.      Please let me know what you think of the issues I have identified with LADOT's internal traffic impact study and mitigation policies and practices, their violations of the City's General Plan, and with the recommendation made be many that the Casden West site should be used to build a Transit Hub for the Westside.      Thank you,  Bill Pope  

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LADOT Reforms Demanded by the City’s General Plan and Reality By Bill Pope

Summary of Issues State Code 65300 requires that CA cities publish a General Plan for their growth and include the policies by which the City will conduct business. State law requires that a city’s day-to-day actions and decisions must logically follow the policies it publishes in its General Plan. The Los Angeles Department of Transportation (LADOT) does not abide by to the City’s official, State-recognized transportation policies published in the City’s General Plan. This is a violation of State Law. Furthermore the policies followed by LADOT have caused, and are now acceleration, traffic congestion and causing commuter traffic to cut-thru residential neighborhoods. This is not only a violation of State Law, it is also un-sustainable. Below is a list of transportation issues that the City must address to 1) support continuing population growth, and 2) to comply with State law. 1. LADOT’s Traffic Study and Mitigation Policies and Procedures and City Planning’s project approval procedures must be

changed to adhere to the following Los Angeles General Plan policies:

“The City is to maintain a satisfactory LOS for streets and highways that should not exceed LOS "D" (90% of capacity) for Secondary Highways and Collector Streets; nor LOS “E” (100% of capacity) for Major Highways or major business districts.” - Policy 16-1.1 in most General Plan Land Use Element Community Plans.

“No increase in density shall be effected by zone change, plan amendment, subdivision or other discretionary action, unless it is determined that the transportation infrastructure serving the property can accommodate the traffic generated.” - Policy 16-2.1 in most General Plan Land Element Section Community Plans.

2. To accomplish 1 above and to support continued growth, all new trips must now be completely mitigated. Therefore the following LADOT internal policies and practices must be abandoned:

§ Escapes from traffic impact study and mitigation afforded by LADOT’s 42-Trip = No Study policy. § Escapes from mitigation by declaring trip increases of from 1% to 4% to be “Insignificant” § Exemptions from payment of the Traffic Impact Assessment fee for mitigating regional-impacts that are afforded

to all residential development projects and 30 other types of projects by the Coastal Transportation Corridor and the West LA Transportation Improvement and Mitigation Specific Plans.

3. Mitigation must be at the developer’s, not the taxpayer’s, expense (e.g., No more Prop R-type sales tax increases). 4. Because there is no room to add or expand roads, most new trips must be accommodate by expanding mass transit. 5. Because the cost of transit expands with each hour of operation, total Commute Period Trip Demand must be assessed,

not just the congestion-constrained Peak Hour flow observed in cities were 2 incomes are not required to buy a home. 6. ITE Trip Generation Handbook lists a trip rate of 0.08 trips per living unit (8 trips per 100 condos) for projects referred to as Senior Housing – Attached. Developers are using this ITE Trip Rate for condo projects that say will be sold to those 55 years old or older. My research indicates that such a low trip rate only addresses visitors to such “senior housing” projects such as custodial care homes, nursing homes, assisted living homes and residential board and care facilities. However, developers are using this rate for active senior condo projects. This can allow a development project building 525 “Senior” Condo to go unstudied and un-mitigated, and could release over a 1000 trip an hour to our streets without mitigation. 7. LADOT’s Level of Service metric is invalid and misleads the public and decision makers. A true travel-time or delay-

based LOS metric must be developed per Federal Highway Capacity Manual 2000 recommendations. 8. The Los Angeles General Plan has several policies designed to protect residential neighborhood from the intrusion of non-residential regional commuter traffic (often referred to as “cut-thru” traffic):

“4.1 Seek to eliminate or minimize the intrusion of traffic generated by new regional or local development into residential neighborhoods while preserving an adequate collector street system.” – Transportation Element. “4.2 Incorporate traffic management measures to control traffic speeds and volumes on local and collector streets within low density residential neighborhoods to assure safe and orderly traffic flow. Traffic management measures for such local streets may include partial closures and/or traffic diverters.”

and the Residential Neighborhood Protection Plan of all 35 community plans state that the City is to,

“Discourage non-residential traffic flow on residential streets” LADOT’s practice of approving more traffic generation than can be accommodated on the arterials forces commuter traffic through residential neighborhoods and then LADOT refuses to implement measures to prevent such intrusion.

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Summary of Recommendations 1. The following recommendation addresses issues 1. thru 5.: § Require the complete mitigation of all net new commute period trips from all land development projects,

regardless of type or size. § All mitigation to be at the developer’s, not the taxpayer’s, expense. § Develop of a program and fee structure whereby development projects can mitigate by their impact on the

transportation infrastructure by expanding existing or committed mass transit, including shelters and bike-racks, any or all project-generated and/or competing trips that cannot be accommodated at General Plan-specified satisfactory Levels of Service via developer-provided roadway and/or intersection improvements.

§ Adhere to published General and Community Plan policies regarding:

− Maintaining a satisfactory Level of Service, − Disallowance of projects when the transportation infrastructure cannot accommodate the traffic

generated, and − Eliminating or minimizing the intrusion of non-residential traffic into residential streets.

§ Require mitigations to be completed and on-line before project occupancy permits are issued. § Ensure, via CEQA Challenge, compliance with the above by non-LA City projects whose traffic will use L.A.

City streets. The above asks no more of today’s developers than was required from the City’s original developers. L.A.’s original developers had to build the transportation infrastructure required to accommodate the circulation needs of their project’s buyers. They built the roads and passed the cost on to their project’s buyers. Today’s developers should be required to do the same by providing the mass transit systems required to accommodate the additional trips their projects add. However, today, developers can build from 84 to 525 condos and not pay a cebt toward mitigating the impact of their project’s traffic on the rest of us. This must be stopped not only because it is unfair to existing L.A. residents and unsustainable, but because it also violates published City Policy, which makes the City in violation of State law. 2. The following recommendation addresses Issue 6. Allow use of ITE's "Senior Housing - Attached" trip generation rate of 0.08 trips per living unit only for residential projects which have no kitchens of any form in any living unit, and do have a central kitchen and dining space sufficient to serve all residents assuming two persons per living unit. 3. The following recommendation addresses Issue 7.

Develop and implement a true Level of Service metric, separate from its intersection physical capacity utilization metric, i.e., its Volume to Capacity (V/C) Ratio. The Level of Service metric developed should convey to City decision makers and the public, in an easily understood manner, the real-world impact that a proposed project would have on existing commuters in terms of increases in travel delays and/or decreases in average travel speeds over those which exist today. 4. The following recommendation addresses Issue 8. Prohibit, via signage and pavement markings, the flow of traffic from one residential neighborhood’s Collector street, across an major or secondary highway arterial, into another residential neighborhood’s Collector street.

This Neighborhood Traffic Management measures is already in use successfully in the City of Los Angeles, but it took a court order to force LADOT to do so. This should be the City’s standard solution to cut-thru traffic.

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Detail Description of Issues and Recommendations. 1. LADOT’s Traffic Study and Mitigation Policies violate the City’s General Plan. State law 65300 says that California cities must develop and publish a General Plan stating the policies they will following in approving city growth, and that once published, the City’s day-to-day activities and decisions must logically follow the policies published in its General Plan. The City’s most fundamental transportation policies are contained in the Community Plans which compose the Land Use Element of the City’s General Plan. The first policy state that the City is to,

“Maintain a satisfactory Level of Service of LOS “D” for Secondary Highways and Collector streets, nor LOS “E” for Major Highways or Business Districts.”

The second states that:

“No increase in density shall be effected by zone change, plan amendment, subdivision or discretionary action, unless the transportation infrastructure can accommodate the traffic generated.”

You can’t maintain a satisfactory Level of Service if you allow developers to build up to 84 general-market condos or 525 “Senior Living” condos without studying the impact of such projects. This is what LADOT’s 42-or–fewer-Trip, No-Study policy does. (See Issue 3 above.) Your can’t maintain satisfactory Levels of Service of LOS “D” or “E” when you allow increases that drive LOS “D” intersections to LOS “E”, and LOS “E” intersections to LOS “F”, even if you choose to call them “Insignificant”. And instead of disallowing projects where demand at the intersections required for project access already exceeds its capacity, or is predicted to be so from already-approved-but-not-yet-occupied projects, LADOT allows further traffic increases. In short, LADOT’s Traffic Study Policies and Procedures contain no provisions to address, fulfill or adhere to either of the City’s two fundamental, official transportation policies published, pursuant to State Code 65300, in its General Plan. Therefore the City is in violation of State law. My three-year effort to secure cut-thru traffic controls to prevent the Playa Vista traffic that LADOT Planning allowed Playa Capital to route in their traffic planning on the residential streets of Inglewood, Beethoven-Rose and Walgrove ended in a stalemate because LADOT's Neighborhood Traffic Management Section refused to adhere to the Residential Neighborhood Protection Plan contained in the City's Community Plans. .The City has just lost a law suit over LADOT not following this published city General Plan policy. So you can expect similar suits in the future on this and the two fundamental transportation policies mentioned above. 2. All new trips must now be completely mitigated to support further City growth and to prevent true Gridlock. Not requiring complete mitigation and accommodate of all new project trips is a non-sustainable policy. There are limits to what the roadway infrastructure can accommodate and those limits have already been reached on at least the Westside by a combination of existing traffic plus that guaranteed from projects already approved, but not yet built and occupied. If you look at my report on Bundy Village, you will see that intersections have already been “overbooked”, by assigning future traffic to them, by as much as 75%. How would you feel if your airline overbooked your flights by 75%? Well, that’s the way L.A.’s existing commuters feel. L.A. must now abandon all escapes and exemptions from mitigations, such as those allowed by:

– The so-called “Insignificant Impact”. CEQA did us no favor when it allowed individual jurisdictions to set their own rules for what level of impact would be considered “significant” and therefore must be reported. LADOT allows traffic and congestion increases of from 1% to 4% to go unmitigated, calling them “Insignificant”.

– Requiring mitigation of “Significant Impacts” only down to “Insignificant Impacts”. These so-called Insignificant

Impacts still increase traffic and congestion by from 1% to 4%. - Allowing traffic increases at LOS “F” intersections that are already over their capacity, either now or by the proposed project’s build-out from already-approved-but-not-yet-occupied projects. (This is totally irrational and irresponsible.)

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- The 42-or–fewer-Trip, No-Study policy which, when used with ITE’s, congestion-constrained, peak-hour-only Trip Generation Rates, allows projects developing as many as 84 general-market condos, and as many as 525 so-called “Senior” condos, possibly adding from a 160 to a thousand additional trips, to go unstudied and unmitigated.

This issue is only partially addressed by LADOT in their 2010 TSPP document. There is now a requirement for projects estimated (by ITE Rates) to generate between 25 and 42 peak hour trips to produce something called a Technical Memorandum, which is only described as “a significantly scaled-down version of a traffic study”. (The version of the TSPP forwarded to me contained no description of this new mini-study.) Whereas LADOT’s 42-Trip No-Study policy, when combined with ITE’s 0.5 trip per condo rate, allowed projects building up to 84 condos to escape traffic study and mitigation, this new policy will require projects developing between 50 and 84 condos to produce some type of documentation. But it will allow projects building up to 50 general-market condos, possibly adding up to 100 new trips, or 312 “Senior” condos, adding up to 624 trips to an area during each commute period, to escape study and mitigation. This is still insufficient, especially considering that the infrastructure has already been overbooked by projects already approved.

- Transportation Specific Plans. According to LADOT’s website, TSP’s were purportedly developed to address the most traffic-congested areas of the City. This was to be accomplished by charging development projects a Traffic Impact Assessment (TIA) Fee to be used by the City to fund City-planned improvements. However, the TSP’s, governing the Westside exempt all residential development projects, and almost all other types of projects from having to pay TIA Fees. It is my understanding that these exemptions are political decisions and/or favors, rather than LADOT’s decision. So this is something the Councilman can tackle directly.

The above escapes and exemptions have caused today’s traffic congestion and residential neighborhood cut-thru traffic. And they will start accelerating it again when the recession ends. The above escapes and exemptions have and are:

1. Driving intersection over their physical capacity limits, thereby … 2. Forcing commuters to spread their commuting over more hours of the day and night, and business to accept more

staggered start times, thereby … 3. Causing fewer trips to be observed leaving and entering a particular project during the one Peak Traffic Hour,

resulting in fewer trips being estimated for future projects, thereby … 4. Leaving more future trips un-studied and unmitigated, thereby … 5. Causing further expansion of the commute periods, thereby … 6. Repeating the cycle above in an accelerating downward spiral.

3. All new Trips Must Be Mitigated at the developer’s, not the taxpayer’s, expense. Proposition R, the one-half cent sales tax increase, was sold to the public as a way for them to end traffic congestion and shorten their commute time to work. That was a lie. Proposition R funds are and will be used to provide transportation infrastructure enhancements to accommodate the new density-increasing development planned by Los Angeles cities and county. Existing residents were lured into approving Prop R so electeds would not risk loosing the support of their campaign-funding developers by making them pay for the transportation infrastructure required to support their land development projects. The transportation infrastructure enhancements to be built with this increased tax will only slightly lessen the further decline in travel speeds and increases in commuter time to be caused by the density increases planned. For instance, instead of average freeway speeds dropping from 34 MPH to 17 MPH by 2030 without Prop R funds, they will drop only to 19 MPH. So even the $150 Billion in new taxes will not accommodate the planned growth. The planned development will further degrade the level of service experienced by existing commuters in spite of the new tax they are now paying. Existing L.A. residents should not be forced to pay for the transportation infrastructure required by future development projects. Today’s developers should do what L.A.’s original developers had to do. The original developers had to build the roads to support the circulation needs of their project’s buyers. They just past that cost on to the original buyers, and they in-turn passed that cost, at a very inflated price, on to you if you own property. Today’s developers should be required to fully-fund the transit system expansions required to accommodate the circulation needs of their projects.

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4. New trips must be mitigated by expanding mass transit. There’s no room left to accommodate additional trips from land development projects by building new roads. Chapter II of the Transportation Element of the City’s General Plan concedes this point. Furthermore, accommodating additional trips by private vehicles does not make the paradigm shift necessary to prevent catastrophic climate change. Therefore new trips generated by land development projects must be first be eliminated where possible via telecommuting, and the remaining trip accommodated by expanding mass transit. As you may remember, Jay Kim countered by stating that road expansion was still possible in the out-lying areas. However, City Planning is promoting (and developers seem to be focused on) in-fill rather than continuing sprawl. In-fill reduces total Vehicle Miles Traveled. In-fill also reduces green-house gas emissions (if in-fill developments have “green” roofs to reduce the “heat-island” effect and therefore reduce requirements for air conditioning). However, sustainable in-fill will not be possible without drastic improvements in our mass transit systems.

Although the new June 2010 version of LADOT’s Traffic Study Policies and Procedures (TSPP) paper lists Transit Capacity and Access Improvements as a mitigation option that developers “should” consider, there appears to be no pre-calculated fee they can pay to have their trips accommodated on transit, and no pre-arranged program with transit providers to add the capacity. Therefore you can not consider this a “policy”. It is just suggestion, open for negotiation.

5. A project’s total Commute Period, not just Peak Hour, trip generation must be assessed. For estimating the number of trips expected to be generated by new land development projects, LADOT uses Trip Generation Rates from the Institute of Transportation Engineers (ITE). ITE Trip Rates are based on voluntary studies sent to them. The studies are of the number of private vehicles observed (or mechanically counted) entering and leaving a development project. However, the trip rates are only during the Peak Traffic Hour. While this was sufficient years ago when new trips could be accommodated by building new or expanding existing roads to accommodate the peak load, it is insufficient for estimating the demand new projects place on mass transit systems. The cost of transit systems increase with each hour of required operation Furthermore, operational costs may out-weight capital cost over the life of a transit system by a factor of 20 to 1.. Therefore, to mitigate a project’s impact by accommodating its new trips on mass transit, you must know the total trips a project will generate during the entire commute period, not just during the one “Peak Traffic Hour” of the day. I will suggest two possible ways to solve this problem. 1. Base the number of commute period trips on the likely number of commuters to occupy a residential development project.

According to the banks with which I have spoken, two incomes are typically required to qualify for a loan to purchase a Los Angeles condo. Therefore it is logical that each Los Angeles-based condo built today will generate close to two trips during each commute period. Reduce this by the percentage of income-producers who work from home and you have the number of total commute trips likely generated during each commute period. It is not necessary to account for any trips involved in taking kids to school or sports as these will not likely be made via mass transit.

2. Use ITE’s Peak Hour Trip Rates to calculate the total trips during each Commute Period.

While there are several problems which make continued use of ITE Trip Rates questionable in my mind, I do understand the need to have a widely-recognized basis of trip estimation with which both cities and developers agree. I will discuss my issues with ITE rates in a side bar below, but will offer here a possible way to use ITE’s Peak Hour trip rates to calculate a trip rate for Commute Periods. Simply use the ITE Peak Hour Trip Rates and the Peak Hour to non-Peak Hour Trip Factor published by either ITE or the Transportation Research Board to compute a weighted average trip rate for each Commuter Period.

ITE Peak Hour Trip Rate + (No. of Commuter Period Hours –1) x (ITE Peak Hour Trip Rate x Peak Hour Factor)

No. of Commuter Period Hours

LADOT’s new TSPP recognizes that the commuter periods are three hours long each, 7:00 to 10:00 AM and 3:00 to 6:00 PM. Therefore a Commute Period Trip Rate could be calculated as,

ITE Peak Hour Trip Rate + 2 x (ITE Peak Hour Trip Rate x Peak Hour Factor)

3 If these two trips are spread over a three–hour long commute period, then you would observe only two-thirds of a trip (2/3) per unit during any one hour of the currently three-hour long commute periods.

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Pope’s Issues with ITE Trip Generation Rates

1. ITE Trip Rates do not represent true Demand even during the Peak Traffic Hour.

ITE Trip Rates are based only on observations of private vehicles entering and leaving a development project, rather than on interviews of the project’s inhabitants. Therefore, the best that can be said about ITE Trip Rates is that they represent only the congestion-constrained flow possible during the Peak Traffic [congestion] Hour in the cities were the observations were made, none of which were in California where it takes two income, therefore the likelihood of two commuters to purchase a home. Therefore ITE Rates do not necessarily represent the true total (pent-up) demand created by the project even during the Peak Traffic Hour. 2. ITE’s Average Trip Rates have very large Standard Deviations.

Of all the trip rate date published by ITE, LADOT (and probably many other DOT’s) only uses the Average Trip Rate statistics. However the studies from which those average rates are calculated vary widely. For example, the current trip rate for condominiums/townhouses is 0.52 trips per unit. However, the studies from which this average was computed varied from 018 to 1.24. And the Standard Deviation among all the studies of condos and townhouses is 0.75. This is a 144% variation. This is a huge variance. Another issue is that the Average Trip Rate, the statistic used by LADOT, is in the lowest one-third in the range. Considering L.A.’s sprawl and lack of transit, does it make sense that L.A. condos would generate only one-third as many trips has have been seen in other parts of the country? I don’t think so. 3. ITE’s Average Trip Rates are not based on trips generated by Los Angeles-based projects.

None of the studies on which ITE Trip Rates are based were done in Los Angeles. At my last look, none of the studies were even done in California. ITE’s Trip Rates are compiled from studies often conducted in Midwest and other cities where two incomes are not required to purchase a condo. If studies were done in L.A., would the rates range even higher than 1.24. The closest benchmark we have for what L.A. Trips might possible be is the San Diego trip rate study. Although San Diego didn’t publish the range of rates they found, the average trip rate they use for projects building 20 or fewer condos per acre, the majority of condo projects built in Los Angeles, is 0.8 trips per unit. San Diego’s trip rate is 54% higher than that used by LADOT. (Note: San Diego’s 0.8 trip rate is only for the Peak Hour and represents only 10% of total daily trips. So 0.8 does not represent all commute period trips. See http://www.sandiego.gov/planning/pdf/tripmanual.pdf .) 4. ITE’s Average Trip Rates have declined over time.

ITE Trip Rates for a given type of development have declined over the years. This has caused fewer trips to be estimated for new development projects as time passes. And this has resulted in less mitigation and an acceleration in traffic congestion. The following table shows ITE’s Average Trip Rate for land use “230, Residential Condominium/Townhouse”.

ITE Edition Year Published Trip Rate per Unit Percent Decline from Prior Edition 5th 1991 0.78 6th 1997 0.54 31% 7th 2003 0.52 4%

Such a decline can occur when cities do not require full mitigation of all new development trips, as is the case in Los Angeles. Such a policy drives intersections beyond their physical capacities, forcing commuters to spread their commuting over more than their desired hour of travel. This expands “Rush Hour” to multiple hours. This reduces the number of trips observed entering and leaving a particular development project during any one hour. This in turn lowers the number of trips observed at completed projects and lowers the number estimated for the future projects. This cycle repeats, resulting in a continual decline of the ITE Trip Rates as time passes. I’ve seen projects claiming a trip rate as low as 0.36 (one-third trip per unit) for condos to be sold to the general public. I’ve also seen projects claiming a trip rate of 0.08 (less than one-tenth trip per unit) for condos supposedly to be sold to “seniors”. However, these so-called Senior Living condos have full kitchens and laundry rooms in each unit and do not have a central kitchen and dining room. Therefore these “Senior Living” condos are being developed for active seniors, not home-bound, bed-ridden patients who can’t drive. L.A.’s commute periods are now three hours long each. So one might expect to see a trip rate of two-thirds of a trip per unit from Los Angeles condos which typically generates 2 trips each during each commute period (2 trips spread over 3

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hours averages two-thirds of a trip per unit). However, the ITE Trip Rate for such condos is only one-half that expected, at one-half trip per condo. The possible reason for this in discussed next. Update: The 8th Edition, published in 2009, shows the trip rate still a 0.52. The fact that it did not continue its past trend downward may be due either to the recession or the fact that rates from new studies now have little effect on the published average rate which is produced by averaging studies that go back as far as the 1960’s. And this in and of itself is a problem. It was the combination of the above problems and unanswered questions that lead me to seek another way of estimating the commute trips likely generated by development projects. My suggestion is to base trip estimates for at least residential projects on the typically number of incomes banks are requiring to qualify for the type property being estimated. This is recommendation 1 under this issue. I automatically gives you an estimate of ALL Commute Period Trips per unit. 6. Decision makers and the public need a real Level of Service (LOS) metric to understand the impacts a proposed density-increasing development project will make on existing L.A. residents.

(aka, Volume to Capacity utilization (V/C) Ratios Do Not equal Level of Service (LOS).) We did not get to this point in the June 8 meeting, but it was the reason that Chuck Grobe pushed for this meeting. According to the national Transportation Research Board and their Highway Capacity Manual (HCM), intersection performance should be measured in two ways: 1) Physical Capacity Utilization, and 2) Level of Service to motorists. The analysis methods used by LADOT only measure capacity utilization, and express that utilization in terms of the Volume of vehicles using an intersection verses the maximum volume the intersection can accommodate in one hour. This is referred to as the Volume to Capacity Ratio or V/C Ratio. LADOT then just equates the calculated V/C Ratio to the particular Level of Service typically experienced by motorists when an intersection is running efficiently at the calculated V/C Ratio. This is both invalid and misleading. Level of Service is a totally separate measure from capacity utilization and needs to be evaluated and calculate independently from capacity utilization. Level of Service (LOS) is intended to express the level of satisfaction or frustration experienced by motorists. According to the Transportation Research Board, LOS is supposed to be based on the Average Total Delay vehicles experience at an intersection. Level of Service is expressed as a grade between “A” and “F”, with “A” representing unimpeded flow with no unnecessary delays, and “F” meaning totally jammed, unstable flow, where motorists sit through multiple signal cycle changes before they can clear the intersection.. An intersection with a capacity utilization ratio of 0.7 (which LADOT equates to LOS “C”) may actually be rated LOS “F” by HCM methods based on the delay experienced by motorists. Delays can be caused either by bad intersection or signal timing designs, poor multi-intersection signal synchronization, or congestion at downstream intersections. So an intersection can provide a poor Level of Service to motorists even when it is running at only a fraction of its theoretically maximum physical capacity in terms of the number of vehicles passing through it in an hour. If the condition causing the delay is not correctable, such as more traffic than can get through the next intersection, then an intersection with only 1000 vehicles an hour passing through it should be considered to be running a maximum capacity (V/C Ratio = 1.0) even though the intersection’s physical geometry indicates that it should be able to accommodate 1500 vehicle per hour. Basing Level of Service on an intersection’s V/C Ratio, as LADOT does, is not valid. Level of Service must be based on the satisfaction or frustration felt by motorists, such as the delay incurred in clearing the intersection. However, while current Intersection Delay is easy to see and measure in real time, predicting the Delay at some point in the future using the HCM method is non-trivial. It requires a lot of time-consuming date gathering and then some highly subjective intermediate analysis, such as deciding on such input assumptions as the Quality of Platoon Arrival Rates, and the Quality of Intersection Progression. LADOT is probably wise in not requiring this type of subjective and highly tweak-able analysis from developers. Fortunately there may be a couple of simple ways to approximate future delay sufficiently enough to give the public and decision makers a sense of a project’s true impact on motorists.

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One way is to add to the currently measured delay, the delay of an additional signal cycle or cycles, based on the probability that the traffic added by a project (and related projects) will exceed the “green time” of the lane(s) that project traffic will use. This can be calculated by the following formula:

Future Delay = Current Delay + Signal Cycle Time x ( ( Additional Future Trips x 2 Seconds) / Lane’s Green Phase ) Where:

Current Delay is the average time required to clear the intersection during the hour in question, calculated by dividing

the total time required by the last vehicle in each stopped queue during the hour, by the number of vehicles that successfully cleared the intersection in the critical lane being analyzed. (For a given proposed project, there will generally be only one direction of flow impacted at an intersection for a given hour. The Critical Lane is the lane serving that direction of flow with the most traffic.)

Additional Future Trips is the number of proposed and/or related project trips, depending on which is being analyzed,

expected to use the Critical Lane of the direction of flow being analyzed. 2 Seconds is the average start-up or passing time for each vehicle of a Stopped Queue. Current Delay, Future Delay, Signal Cycle Time and Lane’s Green Phase are expressed in seconds.

Another approach might also be possible. The Transportation Research Board has in the past published tables showing the ranges of Intersection Delays typically found at properly operating intersections running at various capacity utilizations (V/C Ratios). LADOT currently uses these tables to “declare” the LOS grade for a known or predicted capacity utilization or V/C Ratio. As explained above, this is incorrect. However, these tables could possibly be used in reverse to predict the future Delay, by doing the following:

1. Use current observed Intersection Delay to find the V/C Ratio that typically exists when such a delay is

experienced.

This V/C ratio may be higher than would be calculated by dividing the current traffic volume by the intersection’s theoretical maximum vehicle per hour flow capacity based on the intersection’s geometry and signal timing. However, since the Delay measured is real, it is a better determinant of the intersection’s real capacity in the system of intersections than the intersection’s theoretical vehicles-per-hour capacity.

2. Use the derived V/C Ratio to calculate the real world intersection capacity, expressed as Real Maximum Vehicles

Per Hour.

Do this by dividing the current observed traffic volume per hour by the V/C Ratio found in step 1.

3. Calculate the Future Real With-Project V/C Ratio.

Do this by adding the trips projected for the project to the current traffic flow volume, then divide the total by the Real Maximum Vehicles per Hour derived in step 2.

4. Use the Future Real With-Project V/C Ratio calculated in step 3 to find in the above mentioned HCM table, the Intersection Delay typically experienced at intersections with this V/C Ratio.

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7. Developers appear to be using Congregate Care Facility Trip Rates for Active “Senior” Condo Projects. (We did not get to this point at the June 8 meeting.) I have seen several projects, including the Bundy Village project, proposing condos supposedly to be sold to seniors, age 55 and up, use the ITE Trip Generation Rate titled “Senior Housing – Attached”. That trip rate is 0.08 trips per unit, or only one peak hour trip for every 12 units. This is the same rate ITE lists for “Congregate Care Facilities. If each of the L.A. “Senior” condos is occupied by two adults, such a trip rate would mean that only one out of 24 55-year-old adults drives during the peak traffic hour. This is ridiculous. I believe such a rate might cover the staff at a congregate care facility where occupants are bedridden, but is irrational for condos sold to active, 55 year old Los Angelinos. The condos of these projects each contain full kitchens and laundry rooms. But they do not have central kitchens nor dining rooms for serving inactive and invalid seniors as you would find in residential board and care homes. The attached file titled, “Motion re Use of ITE “Senior Housing - Attached” Trip Generation Rates” contains an example of one such project and the motion I sent to the Councilman via his CD11 Transportation Advisory Committee. I have not yet received a reply. One of you who gets paid more than I to do this work should check with ITE to determine whether their “Senior Housing – Attached trip rate should really be used for the type of “Senior” condo projects shown in the attached file. 8. Change LADOT’s Policies which Cause Cut-thru Traffic, and Prohibit Flow from one Neighborhood into another as a standard Neighborhood Traffic Mitigation Measure. LADOT’s traffic study and mitigation policies cause arterial congestion because they approve more traffic generation than can be accommodate by the transportation infrastructure they provide. This in turn causes commuters to divert from over-capacity arterials and cut through residential neighborhoods. This subjects residents of cut-thru streets to up to 1200 vehicles per hour which is typically 30 to 60 times the volume of traffic found on other neighborhood residential streets. Cut-thru street residents incur damages to their curb-parked vehicles at rates averaging one per ten households. This is many times higher than the rate of damage suffered by residents of other residential streets not impacted by cut-thru commuters. Even thought CHAPTER IV. OBJECTIVES AND POLICIES of the General Plan’s Transportation Element states that the City is to:

4.1 Seek to eliminate or minimize the intrusion of traffic generated by new regional or local development into residential neighborhoods while preserving an adequate collector street system. 4.2 Incorporate traffic management measures to control traffic speeds and volumes on local and collector streets within low density residential neighborhoods to assure safe and orderly traffic flow. Traffic management measures for such local streets may include partial closures and/or traffic diverters.

and the Residential Neighborhood Protection Plan of all 35 community plans state that the City is to,

“Discourage non-residential traffic flow on residential streets” LADOT has historically refused to recognize or abide by these published policies.. LADOT has a history of wasting a neighborhood’s hard-fought funds, acquired from developers to stop cut-thru traffic caused by their projects, by spending those funds on worthless, ineffective Neighborhood Traffic Management studies and plans, leaving the neighborhood with no funds with which to acquire real relief from cut-thru traffic. In some cases, these NTM Plans have actually increased the carrying capacity of cut-thru streets, thereby increasing the number of regional commuters using the residential street, rather than reduced that traffic. Cut-thru traffic typically cuts through one residential neighborhood on its Collector street or streets, crosses an arterial at the Collectors signal-controlled intersection with the arterial, and proceeds to cut through the next residential neighborhood. Cut-thru traffic can typically only use Neighborhood Collector streets because are the only neighborhood streets which connect to arterials at signal-controlled intersections, thereby allowing commuter traffic to safely cross the arterial. This pattern can be broken by prohibiting traffic flow from one residential neighborhood’s Collector street(s) across an arterial, into another neighborhood’s Collector Street(s). This should be the City standard Cut-thru traffic prevention measure. It can be implemented cheaply via only signage and pavement markings. It will also reduce the Green time allocated to flow out of the Collectors by half (right-turning traffic can flow during the arterial’s Green time) thereby allowing more Green time per cycle to be allocated to the arterial.

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Conclusions 1. Most of the above issues can be avoided by implementing a Mitigation by Transit Expansion Program The Traffic Study and Mitigation Policy Reforms Motion proposed in 2007, if adopted, would:

1. Consider every additional commute period trip generated by any land development project to be a “Significant Impact” that must be mitigated (accommodated). No escapes! No exemptions!

2. Require all development projects, regardless of type and size, to either:

a. mitigate any trips which cannot be accommodated, by developer-funded road and/or intersection enhancement at General Plan-specified Satisfactory Levels of Service ( LOS “D”” or “E”), or

b. completely mitigate ALL trips, without need for a Traffic Impact Study,

by paying a fee sufficient to cover the acquisition and first-year start-up operational cost of the additional transit unit(s) (bus or train car) required to accommodate such trips. This fee would be channeled to the appropriate City or County transit agency to add the additional transit unit(s) by project occupancy. This is asking today’s developers to do nothing more than L.A.’s original developers were required to do. The original developers had to build the roads to support the circulation needs of their project buyers. That cost was passed on to the project’s buyers, and they in turn passed it, at a very inflated level, on to you. Today’s newcomers should to the same buy covering the transit expansion required to accommodate their circulation needs.

3. Enable all development projects, regardless of type and size, to pay their fair share. LADOT’s current traffic study

requirements are just two burdensome for any but the largest developers. Such a mitigate-by-transit-expansion fee program could avoid almost all of the issues listed above because a developer could opt to just pay a fee to have all their trips accommodated, rather than incur the cost and delay of a cumbersome traffic study, which just got more cumbersome with LADOT’s June, 2010 Traffic Study Policies and Procedures. The only issue of the those listed above that would need to be address would be the need to estimate the project’s total commuter demand, rather than just their Peak Hour private vehicle trips. I have described two simple ways to address this. See Issue 5. above. 2. San Francisco is now implementing reforms similar to those proposed in 2007. The County and City of San Francisco are now implementing reforms similar those described above. Their new policy is that every single “Automobile Trips Generated (ATG)” constitutes a “Significant Impact” per CEQA, and must by mitigated. In most cases, mitigation will be by expansion of mass transit systems. They are currently conducting the nexus study to determine the fee to be paid by developers for each trip their projects are expected to generate. Because “L.A.” is composed of 82 separate cities, such a program will be more difficult to implement in Los Angeles than in San Francisco. This is why I recommended in 2007 that the transit-expanding Commuter Accommodation Fee as I called it then, be implemented by Metro as a replacement for their unsuccessful Congestion Management Credits program. However, unless Metro is given both the authority and the mandate to levy such a fee, I doubt it will every happen. Metro says they have been “negotiating” a similar fee with the cities they serve for the last five years or so. Sincerely, Bill Pope Files Attached. - Issues - LADOT Traffic Mitigation Policies – Presentation. The visuals and documents I used at the June 8 meeting. - Motion re Use of ITE “Senior Housing - Attached” Trip Generation Rates. An example of the 0.08 Trip Rate use.

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From: Ingeborg Prochazka <[email protected]>

Date: Tue, Dec 4, 2012 at 2:53 PM

Subject: Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA

#ENV-2008-3989-EIR, Related Case #VTT-70805-GB:

To: [email protected], [email protected], [email protected],

[email protected], [email protected]

Please do not approve this horrendous project on the Westside. Traffic would come to a stand-still. Ingeborg Prochazka  

kerrie
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PROCHAZKA
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PULLITZ
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From: Joyce Purcell <[email protected]>

Date: Tue, Dec 4, 2012 at 12:01 PM

Subject: Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR,

CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB

To: [email protected] Cc: [email protected],

[email protected], [email protected],

[email protected], [email protected] Dear Mr. Chu,

I will not be able to attend the hearing regarding the Casden-Sepulveda Development on

December 5th, so I am sending this email as the next best thing.

I was appalled when I received the notice of the hearing that indicated that the Casden

organization wanted more variances for an expansion of their already unmanageable project. The

evening eastbound traffic along Pico Boulevard from Santa Monica to Westwood is already

approaching gridlock, yet they want to add to the congestion. The additional traffic from the Expo

Line station parking at Sepulveda will only make matters worse.

Please stand your ground and keep the property zoned for industrial use. That would encourage

businesses to locate there which would bring much-needed jobs and revenue for our community.

Sincerely,

Joyce Purcell

3316 Kelton Ave.

Los Angeles, CA 90034  

kerrie
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PURCELL
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JMBM Jeffer Mangels Butler & Mitchell LLP

Benjamin M. Reznik Direct: (310) 201-3572 Fax: (310) 712-8572 [email protected]

1900 Avenue of the Stars, 7th Floor Los Angeles, California 90067-4308 (310) 203-8080 (310) 203-0567 Fax

www.lmbm.com

Ref: 72672-0002

December 4, 2012

VIA E-MAIL AND U.S. MAIL

Henry Chu Hearing Officer City of Los Angeles 200 N. Spring Street, Rm. 750 Los Angeles, CA 90012

Re: Casden Sepulveda Project (the "Project") VTT-70805-GB ENV-2008-3989-ER CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR

Dear Mr. Chu:

This office represents the Beverlywood Homes Association (the "Beverlywood HOA"), an association of residents of an adjacent community that would be substantially and detrimentally affected by impacts to traffic and public services caused by the Project. As described in the Beverlywood HOA's comment letter, dated June 18, 2012, on the Draft Environmental Impact Report ("EIR") for the Project, the Beverlywood HOA maintains substantial concerns that the above-referenced Final ER has failed to present and analyze the environmental impacts of the Project in a legally adequate manner pursuant to the California Environmental Quality Act ("CEQA"). The Final ER for the Project failed to address concerns raised in the Beverlywood HOA's comment letter, and failed to remedy significant substantive defects in the Draft. ER, as described in more detail below.

As one would expect from a development of this size—about three quarters the size of Staples Center—and in an area for which traffic systems upgrades are already either fully implemented or fully funded, the Project would result in numerous environmental impacts across a range of categories, including a nearly unprecedented number of traffic impacts. According to the outdated Traffic Impact Analysis ("TIA") prepared for the Project (included as Appendix IV.N to the Draft ER), the Project would generate 19,232 daily vehicle trips, even after generous trip discounts. These trips would overwhelm the roadway system in the Project vicinity, significantly impacting twenty-seven (27) study area intersections, twenty-four (24) of which will remain significantly impacted even after mitigation. These significant traffic impacts

A Limited Liability Law Partnership Including Professional Corporations / Los Angeles • San Francisco • Orange County

LA 9157265v]

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REZNIK
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Mr. Henry Chu, Hearing Officer December 4, 2012 Page 2

would extend into Westwood, Santa Monica, and beyond, and would increase the use of short-cuts through residential neighborhoods adjacent to and in the vicinity of the Project, contributing to an already significant neighborhood traffic intrusion impact and requiring mitigation in areas that include the Beverlywood community. Yet the Final EIR failed to acknowledge, evaluate, and mitigate these impacts.

Further, the Final EIR understates the impacts of the Project, particularly with respect to traffic. The Project includes a General Plan Amendment that would re-designate the 2.27-acre "Add Area" from Industrial to the more intensive Community Commercial land use, strongly indicating the potential for additional or more severe impacts if the trip generation potential of even modest development projections were evaluated. Yet the Draft and Final EIR and TIA completely failed to evaluate either the direct or growth-inducing potential of the General Plan Amendment, arbitrarily truncating the analysis instead, and depriving the public and decision-makers of information crucial to any meaningful determination of whether to approve the Project or how to condition it and mitigate its significant impacts.

Also, among other things, operation of the roadway network can significantly affect response times to emergency incidents, exacerbating the effects of staffing and any equipment shortages. Traffic congestion and delay already plague most large urban areas—including West Los Angeles—and can increase travel time for emergency vehicles, which can in turn increase the response times. Increasing travel time can result in significant delays to emergency response, potentially exacerbating life and property loss. However, the Final ELR. for the Project briefly acknowledged and dismissed, without any analysis, the possibility that Project-related traffic could affect emergency vehicle response times_

I. THE EIR FAILED TO DISCLOSE OR ANALYZE THE EFFECTS OF FORESEEABLE FUTURE DEVELOPMENT IN THE ADD AREA.

The Project includes a General Plan Amendment that would both preclude future industrial use, and allow a substantially more intensive commercial or mixed use, of the 2.27-acre portion of the Property called the "Add Area." Yet the Final EIR includes no analysis of the impacts of the substantially increased development allowed under the new designation, or even of the (intended) growth-inducement potential of the change in designation.

A. The EIR Failed To Evaluate The Potential Direct Effects Of Development Of The Add Area Under Its Proposed Designation.

The Project would vastly increase the allowable density of development in the Add Area, even if the Project does not include a zone change. As described on page 11-65 of the Draft EIR, the existing General Plan designation (Industrial) is "less restrictive" than the proposed Community Commercial designation. Although page 11-66 of the Draft EIR provides a list of compatible zoning designations and briefly describes how development could intensify, any analysis of the effects of that intensified development is completely absent.

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The Add Area accounts for about one quarter of the total area of the Project site. The Draft EIR discloses on page 11-66 that the proposed Community Commercial designation for the Add Area would have a 1.5:1 floor area ratio ("FAR"), no limit on structure height and, in some compliant zones, no front, side, or rear-yard setbacks. Thus, the EIR ignores the potential for another approximately 150,000 additional square feet of commercial and/or multifamily residential development, or about twenty percent more development than the EIR discloses. This crucial omission causes the EIR to substantially understate the potential traffic and other effects associated with the Project, and deprives the public and decision makers of information that would peiluit a reasoned consideration of the consequences of approving the Project.

Just as a General Plan or Community Plan update EIR must evaluate the effects of the plan or plan amendments at issue, so too must the EIR for this Project disclose the full effects of the re-designation of the Add Area in addition to the specific development proposed. Although the Draft EIR attempts to justify its dodge with the claim that a zone change would be required for further development in the Add Area, the maximum development potential of the site is immediately ascertainable, and a very strong likelihood remains that eventual development would consist of some combination of commercial and residential development.

Further, development consistent with the new designation becomes foreseeable immediately upon adoption of the proposed General Plan Amendment. The impacts of a project, including cumulative impacts foreseeable at the time of EIR preparation, must be analyzed "before a project gains irreversible momentum." City of Antioch v. Pittsburg, 187 Cal. App. 3d 1235, 1333 (1986). Here, the failure to evaluate the full impact of the Project or to evaluate, even in a general sense, the Project within the context of reasonably foreseeable cumulative development made easier by the Project itself, renders the re-designation of the Add Area a fait accompli before any environmental evaluation occurs, which in turn renders the EIR fatally flawed. Therefore, the City must revise the EIR to include this analysis, and must recirculate the FIR to allow informed comment by the public and informed decision-making by the City.

B. The Ent Failed To Evaluate The Growth-Inducing Effects Of Development Of The Add Area.

Though the EIR declined to discuss the direct effects of redesignation of the Add area, the EIR also failed to provide even the most cursory discussion of the growth-inducing effects of the redesignation of the Add Area, or for the Project as a whole. The entirety of the analysis, for a Project that includes a change in the General Plan land use designation for a parcel that exceeds two acres, with the purpose of facilitating growth adjacent to a mixed-use commercial and residential development and, as the reader is repeatedly informed, near a future transit stop (assuming that stop is ever constructed), is about one scant paragraph, none of which even mentions the Add Area. See Draft EIR, p. V-4.

The EIR must discuss the ways in which the Project would directly or indirectly foster growth, whether economic or population growth. Pub. Res. Code § 21100(b)(5); 14 Cal. Code Regs §§ 15126(d), 15126.2(d). In City of Antioch, supra. a project that included

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infrastructure such as sewer lines and roadways—but no specific development proposal—required an EIR, because the facilities could not "be considered in isolation from the development it presages." Id. at 1335. In Stanislaus Audobon Society, Inc. v. County of Stanislaus, 33 Cal. App. 4th 144, the Court of Appeal rejected the lead agency's claim that development of a golf course would not induce substantial growth because agricultural zoning would prevent the conversion into residential uses of adjacent land. The court required an EIR, including analysis of growth inducing impacts, reasoning that "zoning is subject to change . . . rezoning and general plan amendments could be approved by the planning commission and board. [T]he record before us contains no assurances that the area surrounding the project will not one day be rezoned . . thus permitting the residential development. . ." Id. at 157.

Here, the Project would remove a substantial obstacle to economic and population growth. In addition to the specific development proposed, the Project would change the designation of property immediately adjacent to that development, purportedly to promote compatible or harmonious development. Draft EIR, p. 11-65-66. That is, the express purpose of the re-designation of the Add Area is the promotion of a certain kind of growth. Under these facts, and as in City of Antioch, the EIR cannot consider the redesignation of the Add Area in isolation from the development it is meant to presage. Furthermore, similar to the situation in Stanislaus Audobon Society, the EIR must recognize that rezoning the Add Area to allow zoning to conform to the proposed General Plan land use designation is at least foreseeable and almost a certainty, and does not represent any real impediment to growth. Consequently, rather than attempting to hide behind the necessity of rezoning the Add Area and improperly deferring analysis on that basis, the EIR should recognize that rezoning provides little—if any—impediment to development. In fact, here, unlike in Stanislaus Audobon Society, the change in land use designation of the Add Area actually provides a justification for future rezoning. Therefore, the City must revise the EIR to include an adequate analysis of the cumulative impacts regarding neighborhood traffic intrusion, and must recirculate the EIR to allow informed deliberation of the merits and consequences of the Project.

IL THE TRAFFIC ANALYSIS FAILS TO RECOGNIZE AND EVALUATE CUMULATIVE NEIGHBORHOOD INTRUSION/CUT-THROUGH IMPACTS OF PROJECT TRAFFIC.

A. The EIR's Cumulative Analysis Is Inadequate And Violates CEQA As A General Matter.

As a preliminary matter, the cumulative analysis of several of the Project's traffic impacts, including neighborhood intrusion, as well as most other impact categories, fails to satisfy the requirements of CEQA. As set forth in the CEQA Guidelines, a legally adequate cumulative impact analysis follows a two-step process: (1) identify whether a cumulative impact has occurred or will occur; and (2) determine whether the Project would result in a cumulatively considerable contribution to that impact. 14 Cal. Code Regs. §§ 15064(h)(1), 15065(a)(3), 15355(b); Communities for a Better Environment v. California Resources Agency ("CBE"), 103 Cal. App. 4th 98, 120 (2002). The purported cumulative impact analysis for neighborhood

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intrusion (as well as for safety, parking, transit, in-street construction, and Add Area impacts) does not follow this required method, and does not even attempt to describe or determine whether a cumulative impact to neighborhood streets has occurred or would occur in the first instance. Instead, the entirety of the cumulative impact analysis comprises a single, totally unsupported statement that "impacts . . . would be less than significant." Draft EIR, p. IV.N-157. This failure alone renders the impact analysis inadequate and requires revision and recirculation of the same.

B. The Cumulative Analysis Fails To Properly Evaluate Neighborhood Intrusion.

As stated in several comment letters to the Draft EIR, including the letter from the BWHOA (Comment Letter Diamond), neighborhood cut-through traffic represents a significant problem in West Los Angeles generally, and in Beverlywood in particular, with about 25,000 vehicle trips per day occurring on Beverlywood Street alone. A drive along Beverlywood Street and through the adjoining neighborhood during peak hours—and even mid-day—provides ample evidence of the intrusions. Additionally, residents along these roads have witnessed the growing congestion and associated safety hazards, as traffic on major roadways in and around the Beverlywood community has worsened with development, which in turn encourages neighborhood intrusion as drivers seek alternate routes. Past projects in Century City and elsewhere have failed to adequately address and mitigate impacts associated with these intrusions, despite the presence of two established programs to address the issue—the Neighborhood Protection Plan ("NPP") and the Century City Neighborhood Transportation Management Project ("CCNTMP"). See Final EIR, Comment Diamond-2.

Courts have long recognized the potential significance of past projects' cumulative impacts. See, e.g., City of Antioch v. Pittsburg, 187 Cal. App. 3d 1325, 1337 (1986). Moreover, the cumulative impacts of many projects may be (and often are) greater than the sum of the individual impacts of the various projects, and a failure to account for the cumulative effects of past projects or operations renders an EIR defective. Environmental Protection Info. Ctr. v. Johnson, 170 Cal. App. 3d 604, 624-625 (1985); see also Los Angeles Unified Sch. Dist. v. City of Los Angeles ("LAUSD"), 58 Cal. App. 4th 1019, 1025 (1997) (impacts may occur incrementally from a variety of sources).

Here, development of over three quarters of one million square feet of commercial and residential development, as well as the future development of another approximately 150,000 s.£ in the Add Area, will significantly increase traffic impacts and attendant safety risks of neighborhood intrusion, as the creation of 24 significant and unavoidable traffic impacts will induce more and more drivers to avoid congestion by traveling through residential neighborhoods. Project-generated congestion will exacerbate the cumulative effects of traffic from past projects on local streets, including those in Beverlywood.

However, the EIR turns a blind eye to this problem by narrowly (and wrongly) focusing the analysis only on the direct intrusion of Project traffic, failing to recognize and

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address the Project's contribution to an existing impact, and wrongly focusing on only one local roadway, Richland Avenue (see pp. IV.N-128-133). The analysis does not even acknowledge—let alone attempt to address—the observations of residents demonstrating that the overwhelming number of significant unavoidable traffic impacts would continue to divert drivers from impacted roadways to various cut-through routes, and that Project-related traffic would exacerbate the cumulative neighborhood intrusion impacts to which past projects have contributed and failed to mitigate. Instead of analysis, the discussion—such as it is—claims that no cumulative threshold exists, and merely reiterates guidance regarding project-level impact determinations. The conclusion of the analysis comprises a single unsupported statement that "impacts . . . would be less than significant." Draft EIR, pp. IV.N-128, 157. This problem is further magnified by the failure of the analysis to consider development in the Add Area, as described above.

This occurred despite numerous public comments regarding neighborhood intrusion in general and in Beverlywood in particular. See, e.g., Comment Letter Diamond. Rather than make the required good-faith effort to disclose and evaluate these impacts, the Final EIR simply dismissed residents' observations with the irrelevant claim that no significant unavoidable traffic impacts would occur within the Beverlywood Community. See Final EIR, responses to Comment Letter Diamond. This clumsy attempt to use the significance of direct Project impacts as a proxy for cumulative impacts violates CEQA, because the relative nature of the Project's impact is not the proper inquiry: the issue is whether the contribution of the Project to a cumulative impact is significant in light of the serious nature of the existing problem. LAUSD, supra, at 1025.

Also, the EIR cannot dismiss residents' observations regarding these matters. That personal observations of area residents—even those who are not environmental experts—can constitute substantial evidence is well settled at law. See, e.g., Bowman v. City of Berkeley, 122 Cal. App. 4th 572, 583 (2004). Observations regarding, for example, traffic conditions clearly qualify. See Arviv Enterprises, Inc. v. So. Valley Area Planning Commin, 101 Cal. App. 4th 1333, 1347 (2002); Citizens' Assn. for Sensible Devel. Of Bishop Area v. County ofInyo, 172 Cal. App. 3d 151, 173 (1985). The same holds true for subjective assessments such as aesthetics and noise. Ocean View Estates HOA v. Montecito Water Dist., 116 Cal. App. 4th 396, 402 (2004). Here, residents have provided substantial evidence, including a count of vehicle trips on Beverlywood Street and observations regarding intrusion into specific areas, and the EIR simply and improperly ignored that evidence.

A cumulative impact analysis that understates the severity and significance of cumulative impacts "impedes meaningful public discussion and skews the decision-maker's perspective concerning environmental consequences of a project, the necessity for mitigation measures, and the appropriateness of project approval. Citizens to Preserve the Ojai v. County of Ventura, 176 Cal. App. 3d 421, 431-32 (1985). Here, the failure of the Draft and Final EIRs to make any serious attempt to address the significant cumulative neighborhood intrusion impacts to Beverlywood and other communities precludes informed comment and deliberation by the public and City decision-makers. Therefore, the City must revise the DR to include an adequate

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analysis of the cumulative impacts regarding neighborhood traffic intrusion, and must recirculate the EIR to allow informed deliberation of the merits and consequences of the Project.

C.

The Project Must Include Mitigation To Reduce Cumulative Neighborhood Intrusion Impacts To Less-Than-Significant Levels.

As described above and in Comment Letter Diamond, two mitigation programs adopted by the City were intended to protect, among other residential communities, Beverlywood. However, neither the City nor any Project developer has implemented any of the measures in those plans in Beverlywood, leaving the significant cumulative neighborhood intrusion impact unaddressed. As the 24 significantly and unavoidably impacted intersections associated with Project traffic would worsen this condition by further inducing motorists to use alternative travel routes through residential neighborhoods including Beverlywood, the Final EIR must fully analyze, disclose, and mitigate its impact by identifying and funding or implementing specific improvements consistent with the NPP and CCNTMP to reduce or alleviate the effects of neighborhood intrusion. Therefore, the City must revise the EIR to include adequate mitigation of cumulative impacts regarding neighborhood traffic intrusion, and must recirculate the EIR to allow informed deliberation of the merits and consequences of the Project.

III. THE TRAFFIC ANALYSIS FOR THE PROJECT CONTAINS NO ANALYSIS OF THE HAUL ROUTE FOR THE PROJECT.

Among other discretionary approvals required for the Project is a haul route to dispose of earth excavated for the five subterranean parking levels planned as part of the Project. However, the traffic analysis provides no analysis of the haul route. As the heavy trucks that haul earth are considered the equivalent of up to three (3) passenger cars for the purposes of vehicle trip generation and distribution, the substantial quantities of earth that the Project would export could substantially affect local traffic patterns in the short term. That such impacts would occur only during the grading and excavation phase of the Project does not excuse the EIR's failure to provide the analysis: CEQA requires analysis and disclosure of short-term as well as long-term impacts. 14 Cal. Code Regs. § 15126.2(a). The absence of any such analysis provides no evidence—let alone substantial evidence—that would allow decision-makers to make any of the required findings regarding the environmental effects of approving a haul route. 14 Cal. Code Regs. §§ 15091, 15092. Therefore, the City must revise and recirculate the ER to provide the appropriate analysis and to allow informed deliberation by the public.

IV. THE PROJECT'S EXTENSIVE TRAFFIC IMPACTS COULD ADVERSELY AFFECT EMERGENCY RESPONSE TIMES IN THE AREA, BUT THE EIR FAILS TO DISCLOSE THIS IMPACT.

Traffic impacts on this scale could significantly affect the ability of fire and police protection vehicles to effectively respond to emergency calls. However, although the Public Services section in the Final EIR gives passing mention to "potential" delay in firefighting and rescue vehicles' response times to the Project Site, it fails to acknowledge a similar impact on

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police response times and fails in both cases even to attempt to quantify the delay or evaluate the effects of that delay. This failure is perplexing, given the availability of established traffic modeling principles and techniques for doing so. Further, given the acknowledgement in the Final EIR that police response times already exceed the City-wide goal, as well as the knowledge that fire station staffing in the Project vicinity has been reduced in response to the City's budget difficulties, any additional delay would exacerbate this problem.

Emergency response times have real-world effects and correlate to survival rates of victims. A 2008 study' determined that a one-minute delay in emergency medical response time corresponded to a 13% increase in the average death rate at 365 days from an incident for all calls.' Death rates measured further from an incident than 365 days show a greater increase. Additionally, these results suggest that increases of less than one minute also affect survival rates.' The City must revise the Final EIR to include an evaluation of this potential delay and to evaluate whether and to what extent mitigation is available to address the resulting impact. The City must also recirculate the Final EIR to provide the public and decision-makers with an adequate opportunity to review an comment on that analysis.

V. CONCLUSION

The absence of any analysis of the Add Area, or of an adequate cumulative impact analysis, provides ample substantial evidence of undisclosed significant traffic and other impacts of the Project. However, the Final EIR provides no analysis of these impacts and therefore provides no substantial evidence to support any refutation by the City of the existence or severity of these impacts. Further, this lack of substantial evidence precludes the City from making findings required under the California Environmental Quality Act ("CEQA") in order to certify the Final EIR and approve the Project. Among other things, the City cannot find that the Final EIR has been completed in compliance with CEQA (Guidelines § 15090(a)(1)), or that changes or alterations have been required in, or incorporated into, the Project which would avoid or substantially lessen the significant effects of the Project (Guidelines § 15091(a)(1)).

The traffic analysis prepared by the Applicant's consultant and included in the Draft and Final EIRs clearly demonstrates that the existing and future roadway network in the vicinity of the Project cannot accommodate Project-related traffic. Further, among other deficiencies, the traffic analysis fails to consider and evaluate additional, likely significant traffic impacts, the possibility of which the Final EIR itself merely states or simply ignores. The City must therefore withhold certification of the Final EIR and consideration of the Project, and revise and re-circulate the EIR, particularly the traffic analysis, to adequately inform decision makers

Elizabeth Ty Wilde. Do Response Times Matter? The Impact of EMS Response Times on Health Outcomes, Princeton Univ. Indust. Relations Section Working Paper # 527, March 2008. Available at: htto://w-ww.irs.princeton.eduipubs/pdfs/527.pdf. 2 Id., at p. 18. In the study data, the baseline average mortality rate was 9.8 percent at 365 days after an incident for all emergency medical services calls. An increase of one minute in the response time yielded an increase of 1.26 percent in average mortality at 365 days after an incident, a 13 percent increase from the baseline. 3 Id., at p. 21.

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BENJAM M. REZNIK, NEILL E. BROWER of Jeffer Mangels Butler & Mitchell LLP

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and the public regarding the true nature of the significant impacts of the Project and the required mitigation for the same.

Sincerely,

BMR:neb

cc: Councilmember Paul Koretz, Council District 5 Christopher Koontz, Planning Deputy, Council District 5 Shawn Bayliss, Planning Deputy, Council District 5 Jay Kim, Department of Transportation

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From:  Carole  Riggins   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  7:25  PM  Subject:  Casden-­‐Sepulveda  Development  (Case  #CPC-­‐2008-­‐4604-­‐GPA-­‐ZC-­‐HD-­‐CUB-­‐DB-­‐SPR,  CEQA  #ENV-­‐2008-­‐3989-­‐EIR,  Related  Case  #VTT-­‐70805-­‐GB)  To:  [email protected]      Dear  Mr.  Chu,    I  am  truly  concerned  upon  reading  about  this  development  for  our  area.    As  I  drive  the  Bundy,  Olympic,  Santa  Monica  Blvd.  route  every  day,  I  can  see  that  I  will  be  impacted  by  the  additional  traffic,  delays  due  to  trains,  etc.    Why  do  we  need  these  tall  buildings  and  2000  cars  more  when  it's  almost  impossible  to  make  a  left  turn  now  unless  there's  a  left  turn  signal.  The  last  traffic  study  that  was  done  in  this  area  a  couple  of  years  ago  had  a  massive  increase  in  traffic,  more  than  the  streets  and  intersections  can  handle.    This  is  going  to  impact  so  many  areas  of  the  residents  and  businesses  in  these  areas  that  I  am  amazed  that  it  would  even  be  considered.    Please,  do  everything  you  can  to  stop  this  plan  as  it  certainly  would  not  be  good  for  the  neighborhood,  or  the  the  businesses  that  are  already  getting  gridlocked  because  of  more  and  more  cars  coming  into  our  area.    Thank  you,    Carole  Riggins  Keeshen    Drive  Mar  Vista  

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From: Joe Santana <[email protected]> Date: Thu, Dec 6, 2012 at 5:50 PM Subject: Casden

Development West LA Casden-Sepulveda Development To: [email protected] Cc:

[email protected], [email protected]

Mr Chu

It is a shame that the City of Los Angeles is now a city of gridlock and congestion.

Having grown up in the WLA area, and currently a Mar Vista resident, I can tell you first hand

how much traffic patterns have diminish our quality of life.

My wife and I hurry home, although I work 7 miles and my wife 3.4 miles away, our daily

commute consist of a minimum of 30 minutes, and sometimes up to an hour. Once we arrive at

home, we don't venture out because of the horrible traffic. This of course means that it limits the

times when we do our errands, or shopping. Our window of opportunity steadily grows shorter

when we can leave to do errands without encountering traffic.

I travel to Santa Barbara to see my son and the grandsons. While there I take advantage of the

area shops and do all my shopping while I am there, just so I dont have to shop in Los Angeles

and fight the traffic.

I must also question how emergency services can respond to an emergency in a true emergency

when seconds mean life and death. Bring more multi-dwelling units, and business into our city,

means higher of volume of vehicles on the streets. This of course means shorter life span of the

asphalt which as you know means it needs repairing or replacement sooner. I question how the

City can repair more streets, when it cant handle the volume now.

At some point in time the reality that we just have too many people in the city and we cant handle

the volume.

It seems that the city doesn't care about the traffic, and only consider the tax the new projects will

generate,

I as a resident of Mar Vista ask for you to look at this project closely, and see that this

project doesn't make sense for the residence of Los Angeles,

I understand the city want to encourage bike riding, however closing traffic lanes only adds to the

congestion and really doesn't get needed vehicles off our streets. All it does is just add to a slower

moving traffic.

Again, we ask you to say no to

The Casden Development West LA

Casden-Sepulveda Development (Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB)

Thanks you

Joe Santana

12426 Mitchell Ave LA,CA 90066

 

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From:   <[email protected]>  Date:  Thu,  Dec  6,  2012  at  2:53  PM  Subject:  Casden-­‐Sepulveda  Development  (Case  #CPC-­‐2008-­‐4604-­‐GPA-­‐ZC-­‐HD-­‐CUB-­‐DB-­‐SPR,  CEQA  #ENV-­‐2008-­‐3989-­‐EIR,  Related  Case  #VTT-­‐70805-­‐GB)  To:  [email protected]      Mr. Chu- Please add my name/vote as opposed to the proposed development at Sepulveda Bl & Pico Bl. Traffic is grid-locked in most areas of the westside. But some pockets feel it more than others. Pico & Sepulveda intersection is one of them. I hesitate to shop or visit areas where the traffic is worst. I won't go out after 4pm because of the traffic gridlock. If for anyone reason I am caught away from home during rush hour, I will use all the available back streets and avoid the major arteries to get home. We have reached the point where development has overcome the streets traffic capacity. Martha Santana 12426 Mitchell Ave Los Angeles, CA 90066  

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From:   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  12:49  PM  Subject:  NO  to  Casden  at  Sepuveda  To:  "[email protected]"  <[email protected]>      Hi Henry, I live in Mar Vista and oppose the Casden Project/Sepuveda as it has been presented. It is TOO BIG and needs to be scaled down. I think there MUST be more input from the surrounding neighbors and an better in depth EIR. The project does not fit into the West LA Plan and should be tabled until which time the plan is approved. There should not be a change in zoning just to accommodate Casden. Keep it industrial and get the Google people or Yahoo or one of the many tech companies coming to the westside. And add a few coffee shops and local small business cafes. Casden will make millions of dollars at the detriment to the residents. The cut-thru traffic, the too tall buildings, the poorly planned entrance and exits, not to mention the health hazards from the near-by freeway-Seniors don't need to breath polluted air. I see this project creating MORE traffic in an already congested area. It just does not make sense. If anything ADD parking for the people who will drive to commute on the Expo Line- (Park and Ride) That is what is needed -to keep people wanting to ride the Expo and making it easy for them to get on and off. NOT A BIG CONDO COMPLEX. Thank You DO NOT JUST RUBBER STAMP THIS-not thought out enough plan. Kelly Stevens  

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JILL TEITELBAUM

9367 AIRDROME STREET

LOS ANGELES, CA 90035

Re: Casden Project at Pico & Sepulveda

December 4, 2012

Henry Chu, Hearing Officer

Los Angeles Department of City Planning

200 North Spring Street, Room 750

Los Angeles, CA 90021

Dear Mr. Chu:

In lieu of my appearance before the Hearing Officer tomorrow, please accept this letter in

support of Casden's proposed project at Pico and Sepulveda.

My support for this project is based on two key factors. First: This is a very forward-thinking,

Transit-Oriented Development that links a future stop on the Expo Line with market rate and

affordable housing, and approximately 300,000 feet of commercial space. Secondly, this project

will help put people back to work. Aside from the nearly 1500 construction jobs it will create,

once completed the Casden project will net approximately 1000 good-paying permanent jobs.

As a former Chicago resident, I miss living adjacent to a transit center where I could shop, dine,

and run errands all in one fell swoop. L.A. needs more of these types of developments; especially

on the Westside.

Sincerely,

Jill Teitelbaum

cc: Chris Koontz – Office of Councilman Paul Koretz

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From:  Bobby  Thomason   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  8:19  PM  Subject:  Casden-­‐Sepulveda  Development:  Case  #CPC-­‐2008-­‐4604-­‐GPA-­‐ZC-­‐HD-­‐CUB-­‐DB-­‐SPR,  CEQA  #ENV-­‐2008-­‐3989-­‐EIR,  Related  Case  #VTT-­‐70805-­‐GB:  To:  [email protected]      Mr. Chu All of the streets around this proposed development are currently gridlocked. The last

traffic study that was done in this area a couple of years ago had a massive increase in traffic,

more than the streets and intersections can handle. The Metro Expo Line train will bring further

delays to traffic in this area with the "at grade crossings", this development will further cause

massive grid lock in traffic on all the streets both East, West and North and South. When

someone provides 2000+ Parking Spaces, they expect 2000+ cars, this is way more than this area

can handle.  

1. The Pico/Sepulveda intersection is already jammed as one of the few east west passages under the 405. Adding a major traffic generator there is ill conceived.  

2. Sepulveda serves as an alternate to the 405, and carries a large amount of traffic to/from the National on/off-ramps.  

3. Should Expo go in, traffic congestion at Pico/Sepulveda will block access to Expo from all directions. How will emergency services get through?  

4. It is morally reprehensible to house men, women, children and seniors so close to a freeway where the poor air quality creates life-long and life-shortening health impacts. Studies show this is costing society millions in illness.  

5. Projects along transit lines and around stations should be planned as part of outreach to impacted neighborhoods and through local community plan processes, not piecemealed in the absence of an approved Community Plan.  

6. Projects along transit lines and around stations should be planned in harmony with the character of the community  

7. The only purpose for placing tall buildings next to the freeway are super graphics and digital billboards, creating more visual blight  

   

   

Bobby  Thomason  

(310)  266-­‐8870  

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OFFICERS Terri Tippit, Chair Steve Spector, Vice-Chair Shannon Burns & Mary Kusnic, Recording Secretary Drew DeAscentis , Corresponding Secretary Lisa Morocco, Treasurer BOARD MEMBERS Barbara Broide Drew DeAscentis Bob Guerin Dick Harmetz Colleen Mason Heller Michael McIntyre John Padden Aaron Rosenfield Sarah Shaw Phillip St. Pierre

November 30, 2012 Henry Chu, Hearing Officer Department of City Planning City of Los Angeles City Hall 200 North Spring Street, Room 750 Los Angeles, CA 90012 [email protected]

Re: Casden Sepulveda Project FEIR Comments CPC-2008-4604-GPA—ZC-HD-CUB-DB-SPR EIR Case No. ENV-2008-3989-EIR

Dear Mr. Chu,

I am writing on behalf of the Westside Neighborhood Council (WNC) Governing Board, representing approximately 80,000 stakeholders in Cheviot Hills, Rancho Park and Century City area.

Thank you for the opportunity to comment on the Casden Project (Case No. ENV‐2008‐3989‐EIR) located on Exposition Boulevard and Sepulveda Boulevard within the WNC boundaries of the Westside Neighborhood Council. Our stakeholders will be the most impacted by this project.

The WNC submits this letter in response to the final environmental impact report (FEIR) for the project and hereby requests that these comments be included in the administrative record for the project. The WNC Governing Board opposes the proposed Casden Sepulveda Project as designed. Although the WNC supports property improvements at the Project location, the Project as planned is out of compliance with the existing West Los Angeles Community Plan and exceeds current zoning allowances. Additionally, as the Project DEIR fails in key areas to comply with the California Environmental Quality Act (CEQA), the WNC requests that the CEQA concerns identified in the West of Westwood HOA Comment Letter attached be addressed prior to any Project approval. The WNC requests that this project be denied. . Sincerely, Terri Tippit, Chair Cc Councilmember Herb Wesson Councilmember Paul Koretz Councilmember Bill Rosendahl Howard Katz

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From:  Kent  Ugoretz   <[email protected]>  Date:  Wed,  Dec  5,  2012  at  7:18  PM  Subject:  Casden  Development  West  LA  To:  [email protected]      Mr.  Chu:    Re:    Casden-Sepulveda Development (Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA #ENV-2008-3989-EIR, Related Case #VTT-70805-GB)    Unfortunately  I  only  became  aware  of  this  project  today,  although  I  will  be  directly  and  significantly  affected  by  it.      This  is  amazing  because  I  peruse  the  Los  Angeles  Times  daily,  read  all  of  my  mail  and  live  approximately  a  mile  from  the  project's  location.    As  a  local  resident  and  a  frequent  user  of  all  of  the  streets  surrounding  this  proposed  project,  I  strongly  object  to  the  size  and  location  of  the  Casden  -­‐  Sepulveda  Development.    I  have  lived  in  the  Westdale  Trousdale  neighborhood  near  Sawtelle  and  National  since  1969.      The  continuous  development  surrounding  this  area  In  the  last  couple  of  decades  has  already  drastically  reduced  the  quality  of  living  due  to  high  traffic  volume  and  noise  and  air  pollution.    The  high-­‐rise  office  buildings  along  Olympic  Blvd  and  the  freeway  on  and  off  ramps  are  a  fact  of  life,  but  the  continued  development  and  completion  of  the  Expo  Line  and  The  Bundy  Village  Project  will  make  these  traffic  and  pollution  problems  much,  much  worse.      At  the  current  time  we  have  to  carefully  choose  where  and  when  we  will  attempt  to  exit  the  area  during  high  traffic  hours  and  look  for  alternate  routes  that  will  bypass  the  major  east-­‐west  and  north-­‐south  streets.    As  an  example,  we  recently  opted  to  give  up  our  season  tickets  at  the  Music  Center  rather  than  fight  traffic  to  get  out  of  our  area  and  arrive  downtown  in  time  to  make  the  performances.    Our  enjoyment  of  the  performances  was  trumped  by  our  aggravation  associated  with  getting  to  the  venue.    Southbound  traffic  on  Sepulveda,  Sawtelle,  Barrington/McLaughlin  and  Centinela  becomes  ridiculously  heavy  from  Wilshire  to  Venice  starting  at  4:00  pm  and  extending  until  7:00  pm.    Eastbound  traffic  on  all  major  east-­‐west  streets  from  Wilshire  to  Venice  from  the  City  of  Santa  Monica  to  Overland  suffer  the  same  fate.    Westbound  and  northbound  traffic  is  only  slightly  better.    Northbound  traffic  already  backs  up  on  Sawtelle  from  just  north  of  National  to  Pico  in  the  morning  and  late  afternoon.      With  the  development  of  the  Expo  Line,  Bundy  Village  and  the  Casden  Project,  those  of  us  living  in  the  area  between  Pico  and  Venice  and  between  Centinela  and  Sepulveda  may  as  well  be  living  on  a  small  island  in  the  middle  of  the  Pacific  Ocean  without  the  amenities  of  a  tropical  island.    The  addition  of  the  West  LA    Casden  Project  will  make  living  in  this  area  untenable.    This  project,  in  the  scale  currently  contemplated,  will  force  me  to  move  and,  if  I  move,  it  will  be  out  of  the  City  and  County  of  Los  Angeles.    I  believe  many  other  of  the  current  local  residents  will  feel  the  same  way.    Please  either  cancel  or  significantly  scale  down  this  project.      You  are  creating  a  city  and  an  environment  in  which  nobody  who  has  an  option  will  want  to  live.    Kent  Ugoretz  3232  Federal  Avenue  Los  Angeles,  CA  90066    

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From: Joan Verdon <[email protected]> Date: Thu, Dec 6, 2012 at 6:18 PM Subject:

Casden-Sepulveda Project - public hearings needed on this huge development project at

Exposition and Sepulveda To: [email protected]

Dear Commissioner Chu:

The Casden-Sepulveda Development project as currently defined and described in the Final EIR is in gross violation of the Community Plan of West Los Angeles. The project should not receive any approval of zone change, tract map, or variance until appropriate changes and mitigations are implemented to make it conform with that Community Plan. Specifically, the project as currently defined and described in the Final EIR presents too many unmitigable traffic and other infrastructural impacts to the existing Westside (CD11 and CD5) traffic/infrastructure deficit.

As a resident living in Santa Monica, I oppose this project as proposed. I want to see local hearings where I and other stake-holders can evaluate the proposal and make important changes that we believe will affect the quality of our lives in our neighborhood. At the same time, we support the Expo Line and the station proposed at Exposition and Sepulveda.

Yours truly,

Joan Verdon  

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From: STEVE WALLACE <[email protected]>

Date: Sun, Dec 2, 2012 at 9:26 PM

Subject: Re: Casden-Sepulveda Development: Case #CPC-2008-4604-GPA-ZC-HD-CUB-DB-SPR, CEQA

#ENV-2008-3989-EIR, Related Case #VTT-70805-GB:

To: [email protected]

Mr. Chu All of the streets around this proposed development are currently gridlocked. The last traffic

study that was done in this area a couple of years ago had a massive increase in traffic, more than the

streets and intersections can handle. The Metro Expo Line train will bring further delays to traffic in this

area with the "at grade crossings", this development will further cause massive grid lock in traffic on all the

streets both East, West and North and South. When someone provides 2000+ Parking Spaces, they expect

2000+ cars, this is way more than this area can handle.

1. The Pico/Sepulveda intersection is already jammed as one of the few east west passages under the 405. Adding a major traffic generator there is ill conceived. 2. Sepulveda serves as an alternate to the 405, and carries a large amount of traffic to/from the National on/off-ramps. 3. Should Expo go in, traffic congestion at Pico/Sepulveda will block access to Expo from all directions. How will emergency services get through?

4. It is morally reprehensible to house men, women, children and seniors so close to a freeway where the poor air quality creates life-long and life-shortening health impacts. Studies show this is costing society millions in illness. 5. Projects along transit lines and around stations should be planned as part of outreach to impacted neighborhoods and through local community plan processes, not piecemealed in the absence of an approved Community Plan. 6. Projects along transit lines and around stations should be planned in harmony with the character of the community

7. The only purpose for placing tall buildings next to the freeway are super graphics and digital billboards, creating more visual blight

-- Steve Wallace 3820 Coolidge Avenue Los Angeles, CA 90066  

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ATTACHMENT  B      From:  Brett  Pomeroy  <[email protected]>  Date:  Tuesday,  December  18,  2012  1:26  PM  To:  Kerrie  Nicholson  <kerrie@ceqa-­‐nepa.com>  Subject:  Re:  Casden  -­‐  truck  haul  trips    This  answer  is  only  for  soil  export  trips.    I  estimated  the  subterranean  garage  footprint/lot  area  to  be  around  189,000  sf.    189,000  sf  x  50  feet  deep  (5  levels)  got  us  to  9,450,000  cubic  feet,  or  350,000  cy.      At  350,000  cy  total  soil  divided  by  16  cy  per  truck  we're  looking  at  21,875  total  export  loads  (so  that's  43,750  round  trips  at  40  miles  per  round  trip  totaling  875,000  VMT).    So,  a  total  of  21,875  loads  over  173  grading/export  days  gives  us  126  loads  exported  per  day.  Assuming  8  hour  work  days  of  hauling,  I  think  that  gets  you  16  loads  per  hour,  or  one  load  every  3-­‐4  minutes.  Hope  that's  clear  enough.    Brett      

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