149 S. Barrington Ave., Box 194, Los Angeles, CA 90049
January 30, 2015
Environmental Analysis Section
Department of City Planning
200 N. Spring Street, Room 750
Los Angeles, California 90012
Via email: firstname.lastname@example.org
Re: Martin Expo Town Center
12101 West Olympic Boulevard
Case Number: ENV-2012-3063-EIR
State Clearinghouse Number: 2013031057
Dear Mr. Ibarra,
The Brentwood Community Council (“BCC”) is the broadest based Brentwood community organization, representing approximately 50,000 stakeholders of the 90049 community. BCC includes homeowners associations, multi-family residential dwellers, business organizations, schools, religious groups, volunteer service groups, public safety and environmental organizations.
The BCC submits the following comments to the DEIR of the Martin Town Expo Center. Our organization strongly opposes this project as currently proposed.
At over 800,000 square feet, the project is much too large for the West LA/Brentwood region, which is already gridlocked during peak hours as thousands of commuters from throughout LA County drive to and from work in West LA and Santa Monica every day. All of the major east-west streets in our region including Pico Blvd., Olympic Blvd., Santa Monica Blvd., Wilshire Blvd., San Vicente Blvd., Montana Avenue, and Sunset Blvd. and the I-10 are already over-capacity, as is the I-405.
As the DEIR notes, 18 of the 56 intersections studied already operate at a level of service “E” or “F.” The DEIR fails to note that another 12 intersections currently operate at an LOS “D”— meaning that 2/3 of the signalized intersections in this area already operate at unacceptable levels.
The DEIR states that 16 of these intersections will be worsened to a level that is significant as the result of this project, and 18 by 2030. Numerous others will be worsened but not to “significant” levels under CEQA. This level of impact by a single project is simply unacceptable.
Bundy Drive is a particularly important artery for Brentwood residents as it is the primary route from Brentwood to the I-10 freeway and one of only two north-south streets (the other being Barrington Avenue) that extend from the I-10 freeway to Sunset. It is an important route used to drive to LAX and other southern destinations when other roads are full. There is no public transportation planned that would accommodate service in a timely fashion to the airport from Sunset Blvd locale.
Westside residents and commuters are well aware that gridlock on one street causes a chain reaction throughout the entire region as drivers shift their journeys to other streets as far north as Sunset Blvd. in (unsuccessful) attempts to find streets that are not gridlocked.
It is evident from the DEIR that the Martin Town Expo project would substantially add to the horrendous traffic that already exists in our area, yet the project’s DEIR is deficient in that it greatly understates the impact that this project will have on traffic in the region.
In addition to the traffic, the very large and unsightly billboard embedded in the front of the project creates a significant negative impact on aesthetics in the area.
The BCC also opposes allowing the applicant to submit this as a “Conceptual Plan” under the Land Use Equivalency Program and Design Flexibility Program (LUEP). The applicant must be required to submit the project that it actually proposes to build, as the impacts on traffic under different land uses vary, and the DEIR misstates the traffic impacts of some uses such as commercial and retail space to a particularly large degree so allowing the applicant to add even more commercial space than is reflected in this plan is extremely problematic.
SPECIFIC ISSUES AND DEFICIENCIES IN THE DEIR
Aesthetics of the Building and Embedded Billboard
The project proposes replacing:
a) a 5 acre site that consists of small 1 and 2 story structures, a lot of open space, and large landscaped setbacks from the corner
b) Three enormous structures of up to 12 stories high, minimal setbacks with virtually no open space on Bundy and Olympic, and a massive billboard on the corner of Olympic and Bundy.
These changes are labeled this change as “not significant” from an aesthetics perspective in the DEIR. This characterization is absolutely incorrect.
These buildings are much taller than any other buildings near the project. Other developed properties on the same block and across the street from this project are a maximum of 4 stories. Taller buildings listed in the DEIR as being comparable in height are blocks away, not next to this project site as is implied in the DEIR.
The project proposal includes a massive billboard directly on the corner of Bundy/Olympic to replace 2 existing billboards on the project site. To make matters worse, the billboard may be digital. The current billboards are on the sides of the property, not on the corner, so are very significantly less intrusive than the huge billboard proposed. The proposed billboard is 4 times as large as the current billboards in addition to being in a much more invasive location.
Pages 4.B.1-4 to -5 of the DEIR state that “a project could have a potentially significant impact related to aesthetics if it were to: …. (c) Substantially degrade the existing visual character or quality of the site and its surroundings” [which includes] “The degree to which a proposed zone change would result in buildings that would detract from the existing style or image of the area due to density, height, bulk, setbacks, signage, or other physical elements.”
This project absolutely fits the criteria of having a significant impact on aesthetics, and one which is unacceptable.
Insufficient traffic study area
The DEIR is inadequate because it failed to study any streets north of Wilshire Blvd.
In their scoping comments on this project, Brentwood groups emphasized the necessity of studying streets such as Sunset Blvd., Montana Avenue, and San Vicente Blvd. However, these comments were ignored and no streets north of Wilshire were included in the study area.
In addition, the signalized intersection of Federal and Wilshire was not included, even though it is within the study are and a heavily traveled intersection of Brentwood.
Because the study area is too small, the DEIR almost certainly understates the number of intersections that would be significantly impacted by the project.
Because all of the east-west arteries throughout West LA, Brentwood, and south of the I-10 already operate at LOS “D”, “E”, and “F,” any impacts caused by this project on streets such as Olympic, Pico, and Santa Monica Blvd, and the I-10/Bundy on-and off-ramps will cause drivers to change routes in an unsuccessful attempt to find streets that are not completely gridlocked.
In particular, drivers from Santa Monica who are trying to access the I-405 north to get to the Valley cut through Brentwood on streets such as Sunset Blvd., San Vicente, and Montana because the I-10/I-405 transition is so gridlocked. These motorists do not have the option of using any sort of mass transit, including Expo, to get from Santa Monica and West LA to the Valley.
Representatives from the BCC have discussed with the applicant’s traffic representative that the failure to study these streets is a severe inadequacy of the DEIR. In these conversations we were told that the only traffic impacts on Wilshire Blvd that were considered in the DEIR analysis were those caused by drivers turning left from the project to get to Wilshire.
Specifically, the traffic consultant for the project stated that they did not take into account any traffic originating west of the project in Santa Monica that would divert onto east-west arteries from Wilshire to Sunset in their analysis. This is a major deficiency in the traffic section of the DEIR.
Other large projects adjacent to this one have included a larger study area in their DEIRs that included intersections in Brentwood on San Vicente and Montana, including the Bergamot Transit Village site and Bundy Village.
Martin Town Expo must be required to provide an appropriate traffic study that covers a regional study area as others have done, and this study area must extend north to Sunset Blvd.
Impact of commercial space is severely underestimated
The number of peak hour trips estimated to be generated by the project by commercial space is grossly understated.
The BCC is particularly concerned about the addition of 200,000 sf of commercial space to this highly congested region. As has already been stated, a primary cause of peak traffic in Brentwood is the very large number of commuters who cut through the area to get to jobs in Santa Monica and West LA.
Although we hope that some commuters are able to take the Expo line, this line does absolutely nothing to reduce the large number of commuters who cut through Brentwood to get to the I-405 N and on to the Valley.
We support the concept of including an appropriate amount of residential space in the project, but object strongly to adding more commercial space in an area that has over 4 million of sf of office space within a few miles from this building in West LA, eastern Santa Monica, and Brentwood. Local infrastructure simply cannot support it.
Before accounting for reductions from the Expo line and other mitigations, the base number used for the number of peak hour trips from the 200,000 sf of commercial space is 275.
Today’s “Creative” office space consists of open floor plans with cubicles which typically host 10 workers or more per 1,000 square feet (100 feet per person). With 200,000 sf, of space, 1,600 workers would work there not 275—the base estimate is understated by over 1,300 workers. In other words, the number of peak hour trips generated by the commercial space is understated by over 80%. This is before the various credits are taken into account, after which only 158 (!) peak hour trips are included in the traffic analysis.
If only 158 peak hour trips can cause significant impacts on 16 intersections, imagine how many intersections would be impacted if the correct number of 1600 workers were used instead of 275!
The use of the term “creative office space” is used to claim that workers who work in the buildings won’t commute during peak hours. This is a complete fallacy not justified by any hard facts. Companies who rent similar “creative” space in the buildings immediately surrounding this project are large corporations such as Comcast, Yahoo!, HBO, and Lionsgate. Employees at these locations work regular work hours. It is simply false to claim that “creative” workers who work in Class A commercial space don’t commute during peak hours— workers at tiny tech start-ups, writers, actors, and other creative who work flexible hours don’t work in Class A commercial space.
Adding a large grocery store that generates over 4,600 trips per day is completely unnecessary, and its impact is understated in the DEIR
Large grocery stores are easily some of the highest traffic generators of any potential site use, and the project proposal includes a large 45,000 sf grocery space.
Including a large grocery is completely unnecessary, given that 10 large supermarkets already exist in the immediate area:
Ralphs at Barrington/Olympic (47,000 sf)- 0.4 miles from project site
Trader Joes at Barrington/Olympic- 0.4 miles
Trader Joes at Pico/32nd – 0.7 miles
Vons/Pavilions and Santa Monica/Barrington- 0.8 miles
Smart & Final at Bundy/Santa Monica- 1.0 mile
Ralphs at Cloverfield/Olympic- 1.1 miles
Smart & Final at Pico/Sepulveda- 1.2 miles
Ralphs at Bundy/Wilshire- 1.3 miles
Bristol Farms at Wilshire/31st- 1.3 miles
Whole Foods at Barrington/National- 1.4 miles
This doesn’t count the numerous smaller markets and convenience stores also located within a similar distance. In other words, this area is not lacking in large supermarkets, and no more are needed.
The grocery store is projected to have 4,601 trips per day. While many are designated as “pass by” trips, the inability to turn left in or out of the project (covered below) means that these trips are likely to generate a lot more of an impact than is projected in the DEIR.
The DEIR also underestimates the traffic from the grocery because a transit credit reducing the number of trips by nearly 15% is applied. It is highly unlikely that anyone would do their grocery shopping before they get on the Expo line rather than go to a market close to their final destination.
As bad as the grocery store would be, nothing would prevent the applicant from building big box retail at the site, which could easily generate even more trips than a grocery store as fewer trips would be pass-bys.
The BCC objects to the development of any large retail at this location, whether grocery or otherwise.
Lack of vehicle access to the project
Because the project’s DEIR has severely underestimated the number of trips to and from the project each day, it is also underestimating the traffic backup that will be caused by the inability for people to turn left to get to or to exit the project.
People driving from the I-10 or other points south would need to turn left at Olympic/Bundy, a signal that already is backed up at an intersection with LOS “E” during AM peak and “D” during PM peak. Turning left into the project from Bundy is even more infeasible as the entrance is in the middle of an unsignalized block with only a dual left turn lanes shared by southbound traffic.
Similarly, it is ridiculous to assume that traffic exiting the property can do so without turning left. In public meetings on the project it was proposed that drivers might be required to make right turns only—an absurd proposition when one takes into account that this is a particularly large block, and with gridlocked east-west streets no one who is heading east from the project would go the equivalent of 2 or 3 blocks west to start their eastbound journey.
Most likely, drivers will make a combination of legal and illegal left turns and U-turns to attempt to enter and exit the project. Having a large number of cars waiting to turn left backs up streets even beyond what is estimated in the DEIR, and therefore the impact of this project is understated in the DEIR.
Lack of bicycle accessibility
While the project proposes 696 bicycle parking spaces, the project’s configuration prevents any bicyclists from getting through the property. On a 4.76 acre site that is only a few blocks from the Bundy Expo station, cyclists coming from the north or south of the project should have paths or streets that allow them to cycle through the project. However, the footprint of the buildings and lack of open space prevents any sort of access through the site.
Cyclists cannot safely bicycle on Bundy Drive, which was determined to be too narrow for dedicated bike lanes by the City, nor can they safely bike on Olympic Blvd. Cyclists can bike on neighborhood streets such as LaGrange, Missouri, or Nebraska to get close to the project, but then cannot get through the project to the Expo station.
Certainly given the City’s desire to see more people bicycle to mass transit stations like Bundy/Olympic Expo, the City should require anyone who develops a large parcel such as this one to provide bicycle access such as bike paths through the property. In this case the 696 bike parking spaces are wasted.
Lack of pedestrian accessibility
The DEIR fails to take into account that having large numbers of pedestrians from the project (residents, workers, and retail customers) attempt to cross Olympic at Bundy to get to the Expo station will tie up traffic and reduce the number of cars that can get through the intersection.
Olympic is a very wide street and even the relatively few pedestrians who cross today cannot all get across the street while the light is green. Adding potentially dozens more pedestrians to every light cycle from the project and from Expo will mean that stragglers will not make it across the street in time, blocking cars trying to turn or go straight.
Brentwood groups have previously proposed to the developer that they integrate a pedestrian bridge or tunnel into their site that would enable people to cross Olympic without blocking traffic.
The City should definitely require any applicants who wish to develop property at such a key intersection near a transit site to cooperate and develop ways for both project users and other passersby to access the station. This is critical if the City wants to encourage pedestrian activity.
Also, as is the case with bikes, adding walkways through the property will encourage pedestrians to walk from the Expo station to the north of the property. Currently the sidewalks along Bundy are narrow, and this project does nothing to improve the walkability of the streets near the Expo station.
In summary, the DEIR for this project is deficient and needs to be redone once the project is reduced to a manageable size for the region. Even the existing DEIR with 16 significantly impacted intersections (18 in 2030) is completely unacceptable. The Brentwood Community Council requests that the City of Los Angeles’ Planning Department reject this project.
Martin Expo Town Center Project
1. To the extent the DEIR describes significant environmental impacts that can not be mitigated to a level of insignificance, particularly traffic and related impacts on such matters as air quality, and police/fire access, and the Applicant anticipates proposing overriding considerations to nevertheless justify approval of the Project with these unmitigated significant impacts, it is essential that such overriding considerations be disclosed in the EIR in order to enable the public to comment on the overriding considerations. This is a very important part of the process and the EIR is legally deficient without such disclosure.
2. The DEIR is legally deficient to the extent it does not describe in detail why each requested entitlement that causes a significant environmental impact that can not be mitigated should be granted beyond existing zoning and land use restrictions. A statement of Project objectives is a deficient response to a request for any not-by-right entitlement since that is tantamount to saying: “I want what I want because I want it.”
3. The Reduced Density Alternative – Alternative 3 is legally deficient since it reduces the total square feet of the Project by only 10% (807,200 to 722,800). This does not present a required meaningful reduction.
4. The Reduced Density Alternative 3 description is deficient because it does not make clear that it assumes 115 apartments and no condos. 115 condos, without more, would require 1,290 parking spaces, which is more than the total 1,248 parking spaces described for all of Alternative 3.
5. The flexibility described in the Conceptual Plan is too broad to allow for the public and the decision makers to be able to know what is being proposed, and to make comments as contemplated by CEQA. This can be demonstrated by looking at only one factor – parking for residential units. Required parking ranges from 851spaces for 516 apartments to 1,290 spaces for 516 condos (over a 50% increase). The difference, which is 439 vehicles, requires two different EIRs describing all the different environmental impacts from an additional 439 vehicles parked on the site. Merely describing a worse case scenario doesn’t enable a decision maker to identify all the impacts from apartments vs. condos, and be able to make an informed choice, nor does it enable the public to make comments about the choice. Analyzing only maximum impacts is not sufficient.
6. Existing non-digital billboards that contain signage for an existing business on the site are a totally different visual intrusion on the neighborhood than would be billboards advertising third-party products and services. This is particularly true if the billboards were digital, and if the ads were frequently changing. There would be an environmental impact on both residents and commercial tenants in the area, and on drivers (including a safety impact) on the nearby streets, all of which needs to be fully analyzed and described.
7. The traffic analysis is grossly deficient on its face since it assumes 8407 daily trips, and 553 AM peak hour trips and 626 PM hour peak trips. The total of the two peak hour trips is only 14% of the total daily trips; hence, it is obvious that peak hours are too narrowly defined. Also, any analysis that does not define and study PM peak hours as 3 – 7pm inclusive, is deficient.
8.The LUEP procedure MIGHT work if all significant impacts described in the DEIR were capable of mitigation measures described in the DEIR. However, when significant impacts are not capable of mitigation, the required CEQA disclosure cannot be analyzed and made because there are too many moving parts. Under such circumstances, the LUEP procedure is inconsistent with CEQA. Also, the request and documentation for an exchange hasn’t even been filed with City Planning and therefore the DEIR is deficient since it does not allow analysis and comment by the public as contemplated by CEQA.
9. The DEIR states that the Applicant is asking for a 10% reduction in the otherwise required commercial parking (Page 2-26). The DEIR is deficient unless it discloses the impacts from such request, and from an alternative set of impacts from reducing the commercial sq ft instead of reducing the required parking.
10. CMA Methodology is deficient on its face since it gives a LOS score to an entire intersection as if all directions of traffic were equal. If one direction has long lines of waiting vehicles through several signal cycles because that intersection approach has reached capacity, but the other directions of traffic have only occasional drivers waiting for more than one red light, the intersection LOS will be averaged and a Project’s impact will not be properly analyzed and disclosed in the EIR. That is the case with the subject DEIR which is therefore deficient and inadequate and misleading.
11. When traffic conditions in one direction on a roadway adjacent to a Project are materially different than in the other direction, and the relevant intersections have reached capacity, the DEIR is deficient, inadequate and misleading unless the time delay is studied between two points along the roadway. If a Project adds trips to such a direction of traffic, the delay impact is exponential, not merely linear. This DEIR is deficient since it does not study and describe, for example, the Project’s impact on the time delay to travel south on Bundy Drive from Santa Monica Boulevard to the I-10 during PM peak hours. Even if using CMA methodology discloses a significant Project impact along Bundy Drive intersections from Santa Monica Boulevard to the I-10 at PM peak, it is essential information for the public and decision makers to know if the Project would increase the time to travel that distance from, for example, 10 minutes to 30 minutes. It is obvious that such information could affect the decision makers’ grant of entitlements and permitted size of the Project, particularly for intersections that are at capacity.
12. The DEIR is legally deficient because it hides what is meant by the AM and PM peak hour. If it is somewhere in all the DEIR pages, it is certainly not repeated in the traffic description and tables. It’s not in the Acronyms and Terms section. Talk about hiding the ball! Since most Tables use the word “hour” in the singular, it is reasonable to conclude that only one hour between 3 – 7pm was studied. If that is true, the DEIR is deficient and misleading.
13. Page 4.L-70 discloses that at least 24% of the Project traffic would use the I-10 east and west of Bundy Drive. The percentage of Project traffic using the major roadways in the Project vicinity must be added to that 24% and disclosed, because the total percentage would disclose the true impact of the Project being adjacent to transit.
14. Any and all credits being requested by the Project because it is transit adjacent must be specifically described in one place. And the transit use by each proposed land use element of the Project must be listed in that DEIR section. If the DEIR absurdly assumes that transit riders will use transit to access the proposed grocery market, that must be disclosed. If the DEIR absurdly assumes that transit riders will use transit to access the restaurants, that must be disclosed. If the DEIR absurdly assumes that transit riders will use transit to access the creative office space, that must be disclosed. And if the DEIR absurdly assumes that any of the residents in the 516 residential units (who the DEIR assumes will be persons who want to live and work at the same location) will use transit to travel to their work some place else in the City,that must be disclosed.
15. If the inexpensive and quick restriping mitigation measures at Bundy/Olympic and Bundy/Pico described on page 4.L-76 would truly have such a dramatic impact, and are capable of being implemented, the DEIR and LADOT must describe why these measures have not already been taken.
16.The EIR should disclose whether or not the heights of buildings comply with the proposed maximum in the Exposition Corridor Transit Neighborhood Plan (draft).
17. The EIR should disclose a comparison of the Project’s proposed zoning with the proposed zoning of the Exposition Corridor Transit Neighborhood Plan (draft).
18. The EIR should disclose the results of review of the Project by Caltrans.
19. The EIR should disclose the Project impacts on the I-10 ramps at Bundy and at Centinela.
20. The EIR should disclose the Project impacts on queuing on the I-10 near the ramps at Bundy and Centinela.
21. The EIR should disclose the Project impacts on the I-10 ramps and roadway in future years, after making reasonable assumptions about the growth rate of trips.
22. The EIR should disclose the Project’s impacts specifically on access to the Expo line, including on the availability for parking by Expo riders.
23. The EIR should disclose the source of assumptions made about the number of the Project’s proposed residents who would drive during peak hours.
24. The EIR should disclose the funding source for all proposed mitigations, and whether the funding will be set aside prior to the Project start.
25. The EIR should disclose the likelihood of being able to effectuate each and every proposed mitigation.
26. The EIR should disclose if any Plan or zoning or agency has identified the Project site for the proposed Project land uses, in view of existing zoning and proposed zoning in the Exposition Corridor Transit Neighborhood Plan.
27. The EIR should disclose specifically the data and documentation, if any, that supports this area of the City is underserved with respect to each of the proposed land uses of the Project.
28. If the Project intends to qualify as “mixed-use development”, the EIR should disclose whether the housing element of the Project will be economically available to the office employees.
29. The EIR should disclose the impacts resulting from actual inadequate parking because of technical parking credits being given for bicycles, transit, or any other credit for parking that does not actually exist.
30. The EIR should disclose the relative assumed numbers and percentages of use of the Project’s proposed retail services by Project residents, nearby residents who walk or bike, and all others who will drive to the new proposed Project’s retail services.
31. The EIR should disclose the rationale of locating higher densities in or near an area surrounded by intersections that are “E” or “F” and freeways that lack mobility.
32. The EIR should disclose the actual amount of open space that would be accessible by neighborhood pedestrians.
33. The EIR should disclose how the Project specifically proposes to improve the aesthetic quality of nearby residential development, with details and examples.
34. The EIR should disclose whether, and the extent, the proposed traffic mitigations could be made without implementation of the Project.
Larry Watts, Chair
Cc: Tricia Keane, CD 11Director of Land Use & Planning
Chris Robertson, CD11 Deputy Director of Land Use & Planning
Larry Watts, Chair, BCC
Lauren Cole, BCC Transportation Chair
Bryan Gordon, BCC Land Use Chair
 275 trips are assumed for AM peak and 257 trips for PM peak
 200,000 sf x 80% leasable / 100 sf per person
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