WLANSC - Martin Expo DEIR Comments
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WLASNC Board
Jay Handal - Chair / Organization Rep.Thomas M. Donovan - Vice Chair / SouthEast District Rep.
Xochit Gonzalez - Secretary / North West Rep.
Al Casas - Small Business Rep.
Helga Hakimi/ Small Business Rep.
David Levitus / At Large Rep.
Kirk Watanabe / At Large Rep..
Jack Fujimoto / Educational & Religious Org. Rep.
Jean Shigematsu / SouthWest District Rep.
Zana Glisovic / Treasurer & N.E. Rep.
Grace Tabib / At Large Rep.
Moe Mostashari / Business Rep.
Jeronimo Garcia/ At Large Rep.
Rosie Kato/Secretary & At Large Rep.
Greg Ericksen/At Large Rep. / / 1645 Corinth Avenue
Los Angeles California 90025
310-235-2070
E Mail:
www.wlanc.com
Jay Handal
January 6, 2014
Sergio Ibarra, Environmental Analysis Section
Department of City Planning
200 N. Spring Street, Room 750
Los Angeles, CA 90012
Email:
Re: Martin Expo Town Center DEIR Comments
EIR Case No. ENV-2012-3063-EIR
Dear Mr. Ibarra,
The West L.A.-Sawtelle Neighborhood Council (WLASNC) Board of Directors submits this letter in response to the draft environmental impact report (DEIR) regarding the Martin Expo Town Center project (the "Project") on behalf of approximately 30,000 stakeholders in the West L.A. area. The WLASNC requests that these comments be included in the administrative record.
The WLASNC opposes the Martin Expo Town Center project as presently proposed. The enormous size of the proposed Project and the multiple discretionary action requests proposed by the developer conflict with the character of the neighborhood and the West Los Angeles Community Plan. A project of this magnitude would severely alter the character of the neighborhood and the quality of life for not only WLASNC residents, but all those that travel through the Bundy/Olympic area on a daily basis. As such, the WLASNC requests that it be denied in its current form.
As cited in the DEIR, the project as proposed will result in substantial adverse impacts that cannot be mitigated to a less than significant level. The variances that are requested are inappropriate and unwarranted. This project should meet current code. The plans for ingress/egress out of the project site are extremely flawed. We have concerns about how the impacts of the Project would impact emergency services and believe the infrastructure was not sufficiently studied as required.
1. General Project Comments
The Martin Expo Town Center project with its proposed uses, densities and height is inconsistent with the existing West Los Angeles Community Plan. The 807,200 square foot development includes three large scale buildings, the tallest of which is proposed to be 11 stories and 160 feet tall. While it is acknowledged that high density buildings have been constructed in the area, mostly along Olympic Blvd, this project would provide a new norm in terms of its sprawling mass.
The Project consists of two 200,000 sq. ft. plus buildings and one 350,000 sq. ft. plus building squeezed onto a tiny parcel of land. The Project would overdevelop the site, and the sheer density on the site would drastically dwarf all other commercial, residential and industrial buildings in the area.
There are sixty seven (67) "related projects” cited in the DEIR. However, NONE of these comparisons are of a similar size and scale as the proposed Project, making them dubious as actual comparisons. In fact, a dozen or more of the Project comparisons could be combined together and they would not equal the size and scale of this project.
The community of West Los Angeles - Sawtelle generally consists of single family homes surrounded by small multi-family apartments which are primarily located on the busiest thoroughfares. Local retail and commercial buildings are generally two or three stories in nature. The West Los Angeles Community Plan characterizes the neighborhood as follows:
“Low Density, single-family development comprises a majority of the residential land use in the Community. A mix of multiple-family development includes apartments and condominiums at varying densities and building types (duplexes, small, medium and large complexes and some high rise structures). Commercial land use consists primarily of strip development on major arterials such as Wilshire, Santa Monica, Pico, Sawtelle, and Westwood Boulevards. The majority of commercial facilities are either low-rise one and two story buildings small-scale and free standing or mini-mall type buildings designed to primarily serve local neighborhoods.”
The Martin Expo Town Center Project fails to meet the neighborhood characterization provided above and does not meet the following requisites of the West Los Angeles Community Plan: a) Need to maintain the low density character of single-family neighborhoods and avoid encroachment from other uses, commercial off-street parking, or spillover traffic. b) Preservation of residential neighborhood; c) Transition in scale, density and character between multiple housing and adjacent single-family neighborhoods; and d) Adequate transition between commercial and industrial uses and single and multi-family areas.
Of major importance is the Land Use Equivalency Program (LUEP) which is supposed to allow development flexibility of the Project's land uses and floor areas so that the Project could, if necessary, respond to the changing needs. The LUEP ostensibly defines a framework within which the proposed mix of
land uses could be modified without resulting in any new significant impacts. This is supposed to allow the Project to respond to "market conditions." What this actually does is allow the developer to make substantial changes to the Project without returning to the community if the developer decides that these changes do not involve "significant impacts." The mix of land uses is critical to this project and community input should be allowed before any changes are instituted.
2. Land Use:
The WLASNC strongly believes that the Project as proposed is inappropriate for the project site. The Zone Change/Height District Change requested by the Project would allow the development at a FAR of 3.9 and include 516 residential units, office space, restaurants, and retail. This would signal that overdevelopment in the City of LA is acceptable and developers need only to apply for discretionary entitlements in order to skirt zoning laws.
This is especially egregious as the revision of the West L.A. Community Plan was halted in 2008 and there are no current plans to restart the revision process. Until this Community Plan is revised and is current, then the developer should consider a project that conforms to current zoning law and land use restrictions.
The DEIR fails to detail what the proportion of affordable housing units would be for the complex. The fact that three years into the project the developer is not sharing basic aspects of the plan with the public is deplorable.
This only reemphasizes that the Land Use Equivalency Program (LUEP) should allow for community input, public hearings and stakeholder oversight before any changes to the land uses are implemented.
- Traffic and Circulation:
The Project will make an already congested and bad traffic situation in West Los Angeles much worse. INRIX, the leading provider of traffic information rated Los Angeles as no. 1 in the Top 10 Worst Cities for Traffic in America in 2013 with the highest total annual hours wasted in traffic and Los Angeles has only become more congested in 2014.
Many of the intersections surrounding the project site already exceed acceptable levels of service (LOS) and volume capacity (V/C) ratios during peak hours.
We believe the 8,407 estimated traffic count to be extremely low for a project of this size and its multi-purpose nature. The DEIR states the “project would create significant traffic impacts at the following 16 analyzed intersections under cumulative plus project conditions:”
Centinela Avenue & Santa Monica Boulevard (PM)
Centinela Avenue (west) & Olympic Boulevard (AM and PM)
Centinela Avenue (east) & Olympic Boulevard (AM)
Centinela Avenue & I-10 WB On-/Off-Ramps (AM and PM)
Bundy Drive & Idaho Avenue (AM)
Bundy Drive & Pico Boulevard (AM and PM)
Bundy Drive & I-10 EB On-Ramp (AM and PM)
Bundy Drive & Olympic Boulevard (AM and PM)
Bundy Drive & Ocean Park Boulevard (PM)
Bundy Drive & National Boulevard (AM)
Barrington Avenue & Santa Monica Boulevard (PM)
Barrington Avenue & Olympic Boulevard (PM)
Barrington Avenue & Pico Boulevard (PM)
Purdue Avenue & Olympic Boulevard (AM and PM)
Sawtelle Boulevard & Olympic Boulevard (PM)
Cotner Avenue & Olympic Boulevard (PM)
The intersections at Centinela where it connects with Santa Monica, Colorado, Nebraska and Olympic are exactly where traffic exiting on Olympic will go to if wanting to go North or East. There is very little chance the this traffic will use Bundy as an exit. According to the Traffic report this Olympic exit will carry 53% of outbound traffic. The traffic report states that these significantly impacted locations do not have feasible mitigation measures, and impacts at these intersections would be considered to be “significant and unavoidable.”
The Traffic study states very clearly that in both 2018 & 2030 the Project would have major impacts at all but 2 intersections if mitigations in the study were made. This is not very likely as these mitigations make very little sense. They reduce lanes in order to make more turn lanes and this will only exacerbate traffic issues.
Even with mitigation, “the project will result in significant and unavoidable impacts at fourteen of the study intersections.” This is unacceptable given that peak hour traffic is already absurdly congested at the Olympic/Bundy intersection, and the new Expo Line, especially at stations such as at Olympic/Bundy, is predicted to further worsen the already bad situation. The cumulative impacts with the Expo Line have not been fully accounted for in the DEIR. The City would be wise to table any future proposals for the project site until the Expo Line is up and running, so that there is a more precise estimation of how a project on this site would impact traffic.
The DEIR states during peak hours there will be 553 AM trips and 626 PM trips, an extreme understatement. A grocery store is proposed, which alone is capable of generating 626 trips during the PM peak hours. There are also restaurants, which would be expected to be highly utilized at peak hours. Presumably the employees who work in the 200,000 square feet of commercial office space will also be traveling at peak hours. Retail shopping often occurs at peak hours. All this adds up to mean more people will be frequenting the site during peak hours than they are now. The Project as proposed is a "destination" site that will wreak havoc on peak traffic.
Emergency vehicles need access to our already clogged roads. Even using the estimated peak hour trips cited in the DEIR, we believe would have an impact on emergency services. We believe the DEIR statement that the “project would not result in inadequate emergency access and impacts would be less than significant” is simply erroneous. Police and fire already claim to have problems getting through at rush hour. There is no way an 800,000 sq ft development at a key intersection is not going to make the problem worse.
Ingress/egress on the site is inappropriate for the number of trips and the diverse uses planned for the property. A lack of signalization at ingress/egress locations will prove to be very problematic and constrict flow into and out of the site. Only one driveway on Olympic and one driveway on Bundy will not sufficiently allow for ingress/egress. Additional outlets need to be explored. Traffic patterns will not allow easy access to the site for vehicles heading north on Bundy or east on Olympic. Physical barriers, double yellow lines and traffic patterns will impede and/or block ingress in these directions. Similarly egress by turning left eastward onto Olympic or left northward onto Bundy will exacerbate an already bad situation. This will cause vehicles to circulate through the adjacent neighborhood to maneuver safely and this will increase traffic. For these reasons and more, cut through traffic patterns need to be more precisely studied on some of the smaller streets like Westgate, Stoner, Harvard, Princeton and Iowa, which were not analyzed in the DEIR.
The distribution numbers of motorists who will make inbound left turns at both the Bundy Drive and Olympic Boulevard Driveways are inadequate. According to the Traffic Study this will account for 42% of the inbound traffic. However, the levels of service for both the driveways for inbound left turns indicates that the delay in turns varies from 16.6 seconds to 32.8 in 2018 and gets worse. So if 42% of the inbound traffic makes left turns, it would take 25 cars something between 7 minutes to 14 minutes if all goes as projected. 25 cars is a fraction of what is projected at these driveways.
The number of freeway trips cataloged in the DEIR analysis is also grossly underestimated. The Project is located one mile from the 405 Freeway and less than one mile from the I-10. People living on the site will likely drive daily. People who live off the site who need to get to work or want to visit the property may also utilize the freeways. The Expo Line being built travels east/west and people will utilize the 405 to travel north/south. West LA is a jobs center for people who live in the Valley and South Bay, where it is cheaper to reside. For such commuters, the freeways are the main way to get to work. There absolutely will be more than 150 trips on the freeway per day associated with this project and an analysis of the freeway segments should be required as part of this project under CEQA. Citizens have a right to know how this project will impact freeway traffic patterns, because it will.