III. Responses to Written Comments...Southern California Association of Governments 818 W. Seventh...

III. Responses to Written Comments

City of Los Angeles Columbia Square Project SCH No. 2007041112 September 2009

Page III-1 WORKING DRAFT - Not for Public Review

III. Responses to Written Comments

CEQA Guidelines Section 15088(a) states that “The lead agency shall evaluate comments on environmental issues received from persons who reviewed the Draft EIR and shall prepare a written response. The lead agency shall respond to comments that were received during the noticed comment period and may respond to late comments.” In accordance with these requirements, this section of the Final EIR provides responses to each of the written comments received regarding the Columbia Square Draft EIR during the comment period. Table III-1, which starts on page III-2, provides a summary of the issues raised in response to the Draft EIR.

III. Responses to Comments



Table III-1 Response to Comments Matrix

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SUMMARY OF WRITTEN COMMENTS EX

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STATE AGENCIES

1 Terry Roberts, Director State of California Governor's Office of Planning and Research State Clearinghouse and Planning Unit 1400 10th Street PO Box 3044 Sacramento, California 95812-3044

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CITY AGENCIES

2 Elmer Alvarez IGR/CEQA Program Manager Department of Transportation District 7, Office of Regional Planning IGR/CEQA Program 100 South Main Street Los Angeles, California 90012-3606

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3 Jacob Lieb, Manager Assessment, Housing & EIR Southern California Association of Governments 818 W. Seventh St., 12th Fl. Los Angeles, California 90017-3435

X X


Table III-1 (Continued) Response to Comments Matrix



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4 Susan Chapman Program Manager, Long Range Planning Los Angeles County Metropolitan Transportation Authority (Metro) Metro CEQA Review Coordination One Gateway Plaza MS 99-23-2 Los Angeles, CA 90012-2952

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5 Denise Chow, Environmental Engineering Associate City of Los Angeles Department of Public Works Bureau of Sanitation Wastewater Engineering Services Division [email protected]

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6 Brent Lorscheider, Division Manager City of Los Angeles Department of Public Works Bureau of Sanitation Wastewater Engineering Services Division

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mailto:[email protected]�





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ORGANIZATIONS

7 Brian Curran Director of Preservation Issues Hollywood Heritage, Inc. P.O. Box 2586 Hollywood, CA 90078

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8 Mike Buhler Director of Advocacy Los Angeles Conservancy 523 West Sixth Street, Suite 826 Los Angeles, California 90014

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9 Frank A. Stephan Senior Managing Director The Clarett Group 1901 Avenue of the Stars, Ste. 1465 Los Angeles, CA 90067

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INDIVIDUALS

10 Darryl Ford 1821 1/2 Winona Boulevard Los Angeles, CA 90027 [email protected]

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11 Doug Haines P.O. Box 93596 Los Angeles, CA 90093-0596

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12 Kelly Chu-Keenan [email protected] X X





Terry Roberts, Director State of California Governor’s Office of Planning and Research State Clearinghouse and Planning Unit 1400 10

LETTER NO. 1

th Street P.O. Box 3044 Sacramento, California 95812-3044

The State Clearinghouse submitted the above named Draft EIR to selected state agencies for review. The review period closed on July 6, 2009, and no state agencies submitted comments by that date. This letter acknowledges that you have complied with State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act.

COMMENT NO. 1-1

Please call the State Clearinghouse at (916) 445-0613 if you have any questions regarding the environmental review process. If you have a question about the above-named project, please refer to the ten-digit State Clearinghouse number when contacting this office.

This comment acknowledges receipt of the Draft EIR by the State of California Governor’s Office of Planning and Research, State Clearinghouse and Planning Unit, and compliance with State Clearinghouse review requirements for draft environmental documents, in accordance with CEQA. The comment also states that no state agencies have submitted comments to the State Clearinghouse with regard to the Draft EIR.

RESPONSE NO. 1-1

SCH# 2007051084

COMMENT NO. 1-2

Project Title Columbia Square Lead Agency Los Angeles, City

Type EIR Draft EIR

Description PPD Gower I, LLC, the Project Applicant, proposes to develop the Columbia Square Project in the Hollywood community of the City of Los Angeles. The 4.68 acre project site is generally bound by Selma Ave to the north, Gower Street to the east, Sunset Boulevard to the south, and EI Centro Ave to the west. The project would provide 400 residential units, a 125 room hotel,




~380,000 sf of office space, and 41,300 sf of retail and restaurant/bar uses (including restaurant/bar uses in the hotel). Included within these project uses is ~105,510 sf of the 136,233 sf Columbia Square Complex that would be rehabilitated to provide for ~91,110 sf of office uses and 14,400 sf of retail and restaurant/bar uses. In addition, a substantial part of the project would include landscaped courtyards and pathways and other open space features connecting the various proposed uses that would establish a more pedestrian-oriented environment within the project vicinity. The project would also include a 9 level parking facility (including 3 subterranean levels) with ~2,004 parking spaces. Construction of the project would occur over ~48 months from the start of grading and excavation activities to the receipt of certificates of occupancy. Approximately 190,000 cubic yards of soil would be exported.

Lead Agency Contact Name Adam Villani Agency City of Los Angeles Phone (213) 978-1472 Fax email Address 200 North Spring Street, Room 750 City Los Angeles State CA Zip 90012

Project Location County Los Angeles City Region Lat / Long 34°05’53.66” N / W Cross Streets Sunset Blvd. and Gower Street Parcel No. Several Township 1S Range 14W Section 11 Base SBB&M

Proximity to: Highways US 101, SR 2 Airports Railways Metro Red Line Waterways Schools Grant Elem., Le Conte MS, Hollywood HS, Bernstein HS Land Use Offices and studios / (Q) C4-1VL-SN (Commercial Manufacturing Zone,

Very Limited Height, Hollywood Signage Supplemental Use District) / District Commercial Manufacturing Industrial

Project Issues Air Quality; Archaeologic-Historic; Drainage/Absorption; Noise; Public Services; Recreation/Parks; Schools/Universities; Solid Waste; Toxic/Hazardous; Traffic/Circulation; Water Quality; Water Supply; Growth Inducing; Landuse [sic]; Cumulative Effects; Aesthetic/Visual




Reviewing Resources Agency; Department of Fish and Game, Region 5; Office of Historic Agencies Preservation; Department of Parks and Recreation; Department of Water

Resources; California Highway Patrol; Caltrans, District 7; Regional Water Quality Control Board, Region 4; Department of Toxic Substances Control; Native American Heritage Commission

Date Received 05/21/2009 Start of Review 05/21/2009 End of Review 07/06/2009

This comment provides a record of the Draft EIR submittal to State Clearinghouse. In particular, this comment acknowledges receipt of the Draft EIR by the State of California Governor’s Office of Planning and Research, State Clearinghouse and Planning Unit, and review of the Draft EIR by those State agencies with jurisdiction over the project, in accordance with CEQA.

RESPONSE NO. 1-2




Elmer Alvarez IGR/CEQA Program Manager Department of Transportation District 7, Office of Regional Planning IGR/CEQA Program 100 South Main Street Los Angeles, California 90012-3606

LETTER NO. 2

Thank you for including the California Department of Transportation (Caltrans) in the review process for the proposed Colombia Square Project. We have reviewed the development proposal that consists of the following:

COMMENT NO. 2-1

200 dueling units of condominium, 200 dueling units of apartments, 380,000 SF of office space, 125 rooms of hotel building, 20,000 SF of restaurant & bar, 11,000 SF of fast wood space and 10,300 SF of retail space.

This project is forecast to generate a net increase of 9,226 trips, including 758 trips during AM peak hour and 755 trips during PM peak hour in the year 2013, the build-out year (see page IV.I-27, IV.l-28 & IV.I-29) of the document.

This comment reiterates the components of the project and its forecasted trip generation as provided in Section IV.I, Transportation and Circulation, of the Draft EIR.

RESPONSE NO. 2-1

In response to public input and community outreach, the project Applicant has announced its preference for Alternative 6 described in Section V, Alternatives, of the Draft EIR. As provided on page V-150 through V-156 of the Draft EIR, Alternative 6 would result in approximately 8,584 net new daily trips which would be less than the project’s 9,226 net new daily trips. With implementation of mitigation measures, this Alternative would result in significant and unavoidable impacts at the same seven intersections as the project and on the same three neighborhood street segments as the project.

COMMENT NO. 2-2

We note the project would create significant impacts at 13 study intersections including the following freeway ramp intersections:

Intersection Impacts

Argyle Avenue/Franklin Avenue - US101 northbound on-ramp (PM only)




Gower Street & Southbound – US101 off-ramp (AM Only) Sunset Boulevard southbound – US101 on-ramp (PM Only)

However, no mitigation measures are proposed. We request the City coordinate with Caltrans and search for appropriate mitigation measures. Mitigation alternatives may include Transportation demand measures, transit-related improvements, and/or fair share contributions towards pre-established or future highway improvements.

A number of mitigation measures were explored for mitigating impacts on the three freeway ramp intersections as discussed in detail in Appendix I, Traffic Impact Study, of the Draft EIR.

RESPONSE NO. 2-2

Specifically, the impact at Argyle Avenue/Franklin Avenue & US-101 northbound on-ramp could be partially mitigated by restriping Argyle Avenue to separate the northbound shared through/left movement, resulting in dual left-turn lanes (leading to the US-101 northbound on-ramp), a single through lane (leading to Argyle Avenue north of Franklin Avenue), and a separate right-turn lane on the northbound approach. This would require removal of on-street parking spaces along the west side of Argyle Avenue south of the intersection beneath the US-101 overpass and restriping of the southbound travel lanes plus the addition of a new overhead sign for traffic bound for US-101 northbound. This mitigation would mitigate the project impact to a level below the LADOT significance criteria during the P.M. peak hour but not, however, during the A.M. peak hour. However, during discussions with LADOT during preparation of the project’s Traffic Impact Study, LADOT has determined that this mitigation strategy is not feasible because of geometric design limitations. The City recently lengthened the southbound left-turn lane on Argyle Avenue leading to the US-101 southbound on-ramp just south of the freeway overpass. It is not possible to shift this lane and the adjacent southbound Argyle Avenue through lanes to the west a sufficient distance to accommodate the mitigation measure without creating a substantial offset in the southbound through lanes as they cross Franklin Avenue. Once past the left-turn lanes, the southbound through lanes would then need to transition quickly back to match the existing lanes on Argyle Avenue at Yucca Street. The intersection would, therefore, remain significantly impacted by project-related traffic.

With regard to the intersection of Gower Street & US-101 southbound off-ramp, mitigation of the project impact would require installation of a three-phase traffic signal controlling the northbound and southbound Gower Street approaches, the freeway off-ramp, and the eastbound Yucca Street approach. A signal warrant analysis was performed and is presented in Appendix D of the Traffic Impact Study (see Appendix I of the Draft EIR). This analysis determined that the projected cumulative plus project traffic volumes would satisfy the Four Hour Volume and Peak Hour Volume traffic signal warrant from the




Manual on Uniform Traffic Control Devices (MUTCD). This improvement would fully mitigate the project impact to a less than significant level. LADOT has determined, however, that this mitigation strategy is not feasible for a combination of reasons. The resultant new signal would be approximately 280 feet from the existing signal at Gower Street and Carlos Avenue, too close to allow for effective timing of the signals. In addition, installing the signal at Yucca Street could encourage additional use of Yucca Street through the residential neighborhood along Yucca Street to the west of Gower Street. Finally, restriping associated with the new signal would require removal of on-street parking spaces along Gower Street south of Yucca Street. It should be noted that, per the MUTCD, the satisfaction of a traffic signal warrant does not in itself require the installation of a signal, and that other factors should be considered when investigating the need for a signal. The project impact at this location would therefore remain significant.

For the intersection of Sunset Boulevard & US-101 southbound on-ramp, the addition of an eastbound right-turn lane would mitigate the project impact at this intersection. Currently 15 feet exists behind the curb to the right-of-way line. In order to maintain a sidewalk, however, additional right-of-way would be required, which LADOT determined is not considered feasible.

Therefore, based on the above, impacts on these intersections would be significant and unavoidable as stated in Section IV.I, Transportation and Circulation, of the Draft EIR.

It should be noted that the project will be developing and implementing a transportation demand management (TDM) program pursuant to the City’s requirements and as a project design feature, as identified in the traffic analysis to reduce project-generated vehicle trips. Potential measures that could be included in the program are discussed in Appendix E to the Traffic Impact Study (provided in Appendix I of the Draft EIR). To provide a conservative analysis of project traffic impacts, trip reductions that would occur as a result of the TDM program were not taken into account.

COMMENT NO. 2-3

Freeway ImpactsThe directional trip distribution to US-101 (Page IV.I-14) is 20% Northbound and 30% Southbound (Figure 6 chart, Trip Distribution), (0.30 x 758 = 227, the added trips) during AM peak hour. The traffic study for the project states that "the project would increase the D/C ratio by a maximum of 1.9%, which would be less than the significance threshold of 2.0%. Therefore, the project would not create a significant impact at the CMP freeway monitoring location or the three freeway segments during the AM and PM peak hours." We wish to point out that it would take only a few trips (approximately 10) to meet the established criteria. We note that other related projects such as: Blvd 6200, Paseo Plaza,




Vine Street Tower, Highland Center, The Lexington also used County CMP criteria and did not evaluate impacts to US101 or determined that traffic impacts were not significant. We understand that this threshold is used for County Congestion Management Program purposes not for California Environmental Quality Act purposes.

This comment reiterates the results of the traffic impact analysis provided in Section IV.I, Transportation and Circulation, of the Draft EIR. As stated by the commenter and analyzed on page IV.I-34 of the Draft EIR, the project would increase the D/C ratio by a maximum of 1.9 percent at the northbound US-101 freeway at Santa Monica Boulevard and at the northbound US-101 freeway at Melrose Avenue during the A.M. peak hour. With regard to the significance threshold of 2.0 percent, it should be noted that both the Los Angeles County Congestion Management Program (CMP) and the City of L.A. CEQA Thresholds Guide (2006) state that a project would significantly impact a freeway if the project would increase the D/C ratio by 2.0 percent or greater, causing a LOS F (or if the facility is already at a LOS F). Thus, even with an increase a few trips (e.g., 10 trips) resulting in a D/C increase of 2.0 percent, the project would not result in a significant impact since the northbound US-101 freeway would not operate at a LOS F.

RESPONSE NO. 2-3

In response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. Alternative 6 would result in a reduction in overall development within the site when compared with the project. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 41,300 square feet of retail, bar and restaurant floor area. Studio B/C (4th

As analyzed in Section V, Alternatives, of the Draft EIR, Alternative 6 would result in approximately 8,584 net new daily trips which includes 738 A.M. peak hour trips and 719 P.M. peak hour trips (less than the project’s 9,226 net new daily trips that includes 758 A.M. peak hour trips and 755 P.M. peak hour trips). As indicated in Table V-48 on page V-157, the project would result in a D/C increase of 2.0 percent on the US-101 northbound freeway at Santa Monica Boulevard and at the US-101 northbound freeway at Melrose Avenue during the A.M. peak hour (the percent increase is greater than for the original project because, even though Alternative 6 would generate less total A.M. peak hour trips, more of these would be inbound trips to the project). However, the D/C of 2.0 percent

Wing) would also be removed and approximately 105,510 square feet of the existing 136,233 square foot CBS Complex located along Sunset Boulevard would be retained and renovated to meet the Secretary of Interior Standards for office, retail and studio uses.




increase would not cause a LOS F. Thus, Alternative 6’s impacts on freeways would also be less than significant.

The commenter states that the County CMP threshold ‘is used for County CMP purposes not for CEQA purposes.” In fact, the County CMP, which was adopted by the City of Los Angeles (the lead agency for the Columbia Square Draft EIR), requires that the County CMP regional transportation impact analysis (TIA) methodology and criteria be used for the evaluation of project impacts on the regional freeway system for any project for which an environmental impact report is being prepared and states that “TIA requirements should be fulfilled within the existing environmental review process, extending local traffic impact studies to include impacts to the regional system.” (Los Angeles County Metropolitan Transportation Authority, 2004 Congestion Management Program for Los Angeles County, Appendix B Guidelines for County CMP Transportation Analysis, page B-2).

The cumulative effects of the project along with all other proposed projects in the area have the potential to have a significant impact on the State Transportation System. US101 freeway currently operates heavily congested, level of service F or stop and go during peak commute periods which last for hours each weekday. At this Level of Service the assumed freeway capacity is not 2000 vehicles per hour, vph. Traffic flows of 2000 vph are possible at free-flow speeds or higher, not when traffic flows at stop and go conditions. At LOS F, the freeway capacity is reduced. Thus, the addition of approximately 200 vehicle trips during peak hours should be considered significant. Based on the information provided, we suspect the project's cumulative effects have the potential to be considerable as it may contribute to exacerbate current conditions by extending the duration of peak period congestion.

COMMENT NO. 2-4

It is agreed that the maximum throughput falls to less than 2,000 vehicles per hour (vph) under stop-and-go conditions. Under these conditions, the full capacity of the freeway system is not utilized. The 2,000 vph value is, however, appropriate for use as a theoretical capacity in the calculation of future demand/capacity ratios for planning purposes and is used by the County CMP in the monitoring of freeway operating conditions at freeway monitoring stations in Appendix A of the County CMP. As such, the freeway analysis in the Draft EIR was consistent with the County CMP analysis methodology.

RESPONSE NO. 2-4

The Draft EIR indicates that poor levels of service (LOS E and F) are experienced on portions of the US-101 freeway during peak periods but concluded that the project’s impacts would be less than significant.




Since it appears that cumulative transportation impacts are likely (Page IV.I-16), appropriate mitigation measures should be considered and reported in the EIR. In the absence of any immediate physical improvement to state facilities, fair share contributions towards pre-established or future US-101 improvements in the vicinity should be calculated and offered. We recommend the City coordinate with Caltrans and prepare a comprehensive study that would determine deficiencies and improvements that would be doable. The Columbia Square project could contribute on a fair share basis to those improvements. Especially, in view of the fact that the CMP debit and credit system has been suspended for some time.

COMMENT NO. 2-5

As discussed previously, the traffic analysis in the Draft EIR determined that the Columbia Square Project would not have a significant impact on the US-101 freeway mainline. Therefore, no mitigation measures are required for the project.

RESPONSE NO. 2-5

The commenter’s recommendation that the City of Los Angeles coordinate with Caltrans to prepare a comprehensive study of deficiencies and potential improvements for the US-101 freeway in the Hollywood area is noted and will be transmitted to City decision-makers.

COMMENT NO. 2-6

To minimize any potential demolition, excavation and construction traffic impacts, we recommend that construction related truck trips on State highways be limited to off-peak commute periods.

Construction Impacts

The contractor should also avoid platooning of truck trips on mainline freeways, on freeway on/off-ramps and at freeway ramp intersections.

Transport of over-size or over-weight vehicles On State highways will need a Caltrans

If you have any questions regarding this response, please call the Project Engineer/Coordinator Mr. Yerjanian at (213) 897-6536 and refer to IGR/CEQA # 090524/NY.

Transportation Permit.




Construction truck trips could occur during peak periods. However, Mitigation Measure I-1 in Section IV.I, Transportation and Circulation, of the Draft EIR requires the project Applicant to devise a Construction Staging and Traffic Management Plan to be implemented during construction of the project. As part of the Construction Staging and Traffic Management Plan, most if not all of the truck trips would be scheduled during the first eight hours of the permitted construction work period (7:00 A.M. to 3:00 P.M.) to avoid generating trips during the P.M. peak hour.

RESPONSE NO. 2-6

Construction activities for the project would not involve the use of technology for the platooning of truck trips on freeways or other roadways. Furthermore, Project construction managers would ensure that departures for construction trips would be staggered in an effort to minimize trucks traveling in large platoons. This specification has been included in Mitigation Measure I-1 and is noted in Section II, Corrections and Additions. As indicated in this comment, if the use of oversized-transport vehicles on State highways becomes necessary during project construction, the project Applicant would obtain a Caltrans transportation permit.




Jacob Lieb, Manager Assessment, Housing & EIR Southern California Association of Governments 818 West Seventh Street, 12

LETTER NO. 3

th Floor Los Angeles, California 90017-3435

Thank you for submitting the Draft Environmental Impact Report for the Columbia Square Project, ENV-2007-819-EIR [SCAG No. I20090360] to the Southern California Association of Governments (SCAG) for review and comment. SCAG is the authorized regional agency for Inter-Governmental Review of Programs proposed for federal financial assistance and direct development activities, pursuant to Presidential Executive Order 12372 (replacing A-95 Review). Additionally, pursuant to Public Resources Code Section 21083(d) SCAG reviews Environmental Impacts Reports of projects of regional significance for consistency with regional plans per the California Environmental Quality Act Guidelines, Sections 15125(d) and 15206(a)(1). SCAG is also the designated Regional Transportation Planning Agency and as such is responsible for both preparation of the Regional Transportation Plan (RTP) and Regional Transportation Improvement Program (RTIP) under California Government Code Section 65080 and 65082. As the clearinghouse for regionally significant projects per Executive Order 12372, SCAG reviews the consistency of local plans, projects, and programs with regional plans. This activity is based on SCAG's responsibilities as a regional planning organization pursuant to state and federal laws and regulations. Guidance provided by these reviews is intended to assist local agencies and project sponsors to take actions that contribute to the attainment of regional goals and policies.

COMMENT NO. 3-1

SCAG staff has reviewed this project and determined that the proposed project is regionally significant per California Environmental Quality Act (CEQA) Guidelines, Sections 15125 and/or 15206. The proposed project, located on 5 acres, would provide 400 residential units, a 125-room hotel, approximately 380,000 square feet of office space, and approximately 41,300 square feet of retail and restaurant/bar uses (including restaurant/bar use in the hotel).

This comment acknowledges receipt of the Draft EIR by the Southern California Association of Governments (SCAG) and provides an overview of the role of SCAG. This comment is noted for the administrative record and will be forwarded to the decision-makers for review and consideration.

RESPONSE NO. 3-1




We have evaluated this project based on the policies of SCAG's Regional Transportation Plan (RTP) and Compass Growth Vision (CGV) that may be applicable to your project. The RTP and CGV can be found on the SCAG web site at: http://scag.ca.gov/igr. The attached detailed comments are meant to provide guidance for considering the proposed project within the context of our regional goals and policies. We also encourage the use of the SCAG List of Mitigation Measures extracted from the RTP to aid with demonstrating consistency with regional plans and policies.

COMMENT NO. 3-2

An evaluation of the consistency of the project with relevant SCAG policies was completed in Section IV.F, Land Use, of the Draft EIR. As indicated therein, the project would be substantially consistent with the goals and policies set forth in SCAG's Regional Transportation Plan and Compass Growth Vision Report. Based on the analysis presented in the Draft EIR, with incorporation of the project design features and approval of the proposed discretionary permits and requests, impacts relative to consistency with land use plans would be less than significant. Thus, no mitigation measures are required for land use.

RESPONSE NO. 3-2

Please provide a copy of the Final Environmental Impact Report (FEIR) for our review. If you have any questions regarding the attached comments, please contact Bernard Lee at (213) 236-1800. Thank you.

COMMENT NO. 3-3

This comment is acknowledged. Per the commenter’s request, a copy of this Final EIR is being provided to the commenter.

RESPONSE NO. 3-3

COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE COLUMBIA SQUARE PROJECT, ENV·2007-819·EIR [SCAG NO. I20090360]

COMMENT NO. 3-4

The project site, consisting of 4.68 acres, is generally bound by Selma Avenue to the north, Gower Street to the east, Sunset Boulevard to the south, and El Centro Avenue to the

PROJECT LOCATION




west. It is located within the Hollywood Community of the City of Los Angeles and is approximately six miles northwest of Downtown Los Angeles and 13 miles northeast of the Pacific Ocean.

The Columbia Square Project would provide a vertically integrated mix of .uses that will assist in promoting Hollywood as a center of population, employment, retail services and entertainment. The project would provide 400 residential units, a 125-room hotel, approximately 380,000 square feet of office space, and approximately 41,300 square feet of retail and restaurant/bar uses (including restaurant/bar use in the hotel). Included within these project uses is approximately 105,510 square feet of existing building area (91,110 square feet for office and 14,400 square feet for retail/restaurant/bar) that would be retained and rehabilitated from the existing 136,233 square-foot Columbia Square Complex. In addition, a substantial part of the project would include landscaped courtyards and pathway and other open space features connecting the various proposed uses that would establish a more pedestrian-oriented environment within the project vicinity. Amenities such as recreation rooms, swimming pools, and landscaped recreation areas would also be provided for residents and guests. The project would also include a multi-level parking facility (including three subterranean levels) with approximately 2,004 parking spaces.

PROJECT DESCRIPTION

The project is located in a highly urbanized area. Surrounding land uses are generally commercial in nature. A parking structure and office building are located north of the project site. A mix of commercial and residential uses is located east of the project site. Commercial uses line Sunset Boulevard to the south. The Hollywood Palladium and associated surface parking are located west of the project site.

Approvals being sought by the project from the City of Los Angeles and/or other agencies include the following:

• Community Redevelopment Agency Board Approval to develop up to 5.42:1 FAR • Community Redevelopment Agency Board Approval of an Owner Participation

Agreement (OPA) to permit development in excess of a 4.5:1 FAR. • City approval of a Development Agreement. • General Plan Amendment to amend the existing Hollywood Community Plan land

use designation for the site from "Commercial Manufacturing" Industrial to the "Regional Center" Commercial land use designation; and pursuant to Hollywood Community Plan Footnote 9, permit a floor area ratio of 5.42:1.

• Vesting Zone Change from [Q]C4-1VL-SN to C4-2-SN Zone. • Height District Change to permit Height District Number 2, in lieu of Height District

1VL. • Vesting Conditional Use Permit (CUP) to permit the following:

o Motion picture and television studios and related incidental uses in a C4 Zone. o A hotel within 500 feet of an R Zone.




o Live entertainment/patron dancing. o On- and off-site sales and consumption of a full line of alcoholic beverages.

• Site Plan Review to allow a development project that creates 50,000 gross square feet or more of nonresidential floor area, creates an increase of 50 or more dwelling units, or adds 1,000 or more average daily trips.

• City Planning Commission approval to allow a Phased Development that will be constructed in consecutive or overlapping phases over a 10-year period.

• Zone variance to allow a restaurant with an outdoor eating area not on the ground floor.

• Demolition, grading, excavation, foundation, and associated building permits. • Haul Route Approval. • Encroachment Permit to encroach approximately 5 feet underneath Gower Street to

construct a portion of the parking structure. • Signage approvals pursuant to the guidelines and policies of the Hollywood Signage

Supplemental Use District. • Certification of an Environmental Impact Report and adoption of a Mitigation

Monitoring and Reporting Program. • Coverage under the National Pollution Discharge Elimination System (NPDES)

Permit by the Los Angeles Regional Water Quality Control Board. • Issuance of all required ministerial permits necessary to implement the project (e.g.,

grading, building, certificate of occupancy, water, sewer, storm drain, etc.) by the City of Los Angeles.

• Any additional actions deemed necessary.

This comment reiterates the characteristics of the project as described in Section II, Project Description, of the Draft EIR.

RESPONSE NO. 3-4

In response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. Alternative 6 would result in a reduction in overall development within the site when compared with the project. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 41,300 square feet of retail, bar and restaurant floor area. Studio B/C (4th Wing) would also be removed and approximately 105,510 square feet of the existing 136,233 square foot Columbia Square Complex located along Sunset Boulevard would be retained and renovated to meet the Secretary of Interior Standards for office, retail and studio uses. Under this Alternative, at least 1,770 parking spaces would be provided within a parking structure of up to nine levels. Up to the three lower levels would be subterranean while the remaining upper levels would form the podium upon which the residential tower and town homes would be located (the podium level would thus comprise the seventh floor).




Approvals required for this Alternative would be similar to those under the project and would include approval of a Development Agreement, a General Plan Amendment, a Vesting Zone Change, a Height District Change, multiple Conditional Use Permits (CUPs) (including a Vesting CUP for a mixed use development), a Site Plan Review, a Vesting Tentative Tract Map, other approval as deemed necessary, and associated permits for demolition, grading, excavation, foundation and building, signage, and haul routes, as well as City Planning Commission approval for a phased development.

COMMENT NO. 3-5

Regional Growth Forecasts

CONSISTENCY WITH REGIONAL TRANSPORTATION PLAN

The Draft Environmental Impact Report (DEIR) should reflect the most current SCAG forecasts, which are the 2008 Regional Transportation plan (RTP) Population, Household and Employment forecasts (adopted May 2008). The forecasts for your region and subregion/city are as follows:

Adopted SCAG Regionwide Forecasts

1

2010 2015 2020 2025 2030

2035

Population 19,418,344 20,465,830 21,468,948 22,395,121 23,255,377 24,057,286 Households 6,086,986 6,474,074 6,840,328 7,156;645 7,449,484 7,710,722 Employment 8,349453 8,811,406 9,183029 9,546,773 9,913,376 10,287,125

Adopted City of Los Angeles Subregion Forecasts

1

2010 2015 2020 2025 2030

2035

Population 4,140,516 4,214,082 4,292,139 4,367,538 4,440,017 4,509,435 Households 1,386,658 1,445,177 1,506,564 1,554,478 1,600,754 1,638,823 Employment 1,860,672 1,905,337 1,933,860 1,967,393 2,003,196 2,037,472

1. The 2008 RTP growth forecast at the regional, subregional, and city levels was adopted by the Regional Council in May 2008.

The DEIR does not appear to utilize the final 2008 RTP growth forecasts. The Final EIR should incorporate growth forecasts from the 2008 RTP.

SCAG Staff Comments:




Section IV.K, Population, Housing, and Employment, of the Draft EIR does utilize final 2008 RTP growth forecasts. However, the forecasts provided in the Draft EIR are analyzed in the geographic contexts of the Hollywood Community Plan area, the City of Los Angeles, and the County of Los Angeles (rather than the contexts of the SCAG region and City of Los Angeles Subregion).

RESPONSE NO. 3-5

The growth forecasts provided by the commenter for the City of Los Angeles Subregion consists of forecasts for the City of Los Angeles as well as forecasts for the San Fernando City and unincorporated areas adjacent to the City. The Draft EIR only utilizes forecasts for the City of Los Angeles and does not include forecasts for the San Fernando City and unincorporated area. For example, Table IV.K-1 on page IV.K-7 of the Draft EIR provides a projected 2010 population for the City of Los Angeles as 4,057,484 persons. The commenter’s 2010 population forecast for the City of Los Angeles Subregion includes the 4,057,484 for the City, 25,452 persons for San Fernando City, and 57,580 persons for unincorporated areas. Hence, the population total of 4,140,516 residents as provided by the commenter.

While the Draft EIR does not analyze growth within the geographic context of the SCAG Region and City of Los Angeles Subregion as provided in this comment, the Draft EIR does accurately utilize 2008 RTP growth forecasts. The Draft EIR’s analysis of population, housing, and employment impacts within the geographic context of the Hollywood Community Plan area, the City of Los Angeles, and the County of Los Angeles is appropriate as it provides a more conservative analysis of the project’s growth with regard to its location in these specific areas.

The 2008 Regional Transportation Plan (RTP) also has goals and policies that are pertinent to this proposed project. This RTP links the goal of sustaining mobility with the goals of fostering economic development, enhancing the environment, reducing energy consumption, promoting transportation-friendly development patterns, and encouraging fair and equitable access to residents affected by socioeconomic, geographic and commercial limitations. The RTP continues to support all applicable federal and state laws in implementing the proposed project. Among the relevant goals and policies of the RTP are the following:

COMMENT NO. 3-6

Regional Transportation Plan Goals: RTP G1 Maximize mobility and accessibility for all people and goods in the region. RTP G2 Ensure travel safety and reliability for all people and goods in the region. RTP G3 Preserve and ensure a sustainable regional transportation system.




RTP G4 Maximize the productivity of our transportation system. RTP G5 Protect the environment, improve air quality and promote energy efficiency. RTP G6 Encourage land use and growth patterns that complement our transportation

investments. RTP G7 Maximize the security of our transportation system through improved system

monitoring, rapid recovery planning, and coordination with other security agencies.

SCAG staff finds the project meets consistency with RTP G6, partial consistency with RTP G1 and G4, and cannot determine consistency with RTP G5. RTP G2, G3, and G7 are not applicable to this project.


The proposed project meets partial consistency with RTP G1. Mobility pertains to the speed at which one may travel and the delay, or difference between the actual travel time and travel time that would be experienced if a person traveled at the legal speed limit. Accessibility measures how well the transportation system provides people access to opportunities, such as jobs, education, shopping, recreation, and medical care. Table IV.I-12 (Future 2013 Intersection Level of Service with Mitigation) indicates that several intersections will be below a Level of Service (LOS) D, an acceptable LOS, after mitigation measures have been applied. With regard to accessibility, the proposed project would have regional access via US-101 and public transit access at the MTA Red Line stop at Hollywood and Vine along with several MTA and LADOT bus routes.

The proposed project meets partial consistency with RTP G4. Productivity is a system efficiency measure that reflects the degree to which the transportation system performs during peak demand conditions. As mentioned previously, the proposed project is expected to impair performance at several intersections near the project site.

SCAG staff cannot determine consistency with RTP G5. Per table IV.B-7 (Project-Related Operational Emissions (lbs/day), several criteria pollutants exceed the Regional Significance Thresholds and most of the emissions are from mobile sources.

The proposed project meets consistency with RTP G6. The project site is located in close proximity to US-101, which provides regional access, is located along Sunset Boulevard and Gower Street, which provide local access, and is within one-half mile of the Metro Red Line station at Hollywood and Vine.

This comment states that the project would be consistent with RTP Goal 6 and partially consistent with RTP Goal 1 and Goal 4. This comment does not change the conclusions provided in Section IV.F, Land Use, of the Draft EIR

RESPONSE NO. 3-6




With regard to RTP Goal 5, the project would be partially consistent with this goal. While regional operational emissions would still exceed the SCAQMD daily emission thresholds for VOC, NOx, CO, and PM10 after implementation of the mitigation measures, the project includes numerous features to reduce vehicular traffic and associated mobile emissions ( including design to meet the criteria for LEED® Silver designation, preferential parking for alternative-fueled vehicles and carpools, encouraging the use of mass transit, and encouraging pedestrians and bicycling as viable means of accessing the project site by employees, residents, and visitors). In addition, the project is originally designed as a mixed-used development with the intent of reducing vehicular trips and congestion as well as promoting pedestrian travel. This is accomplished by providing housing in close proximity to jobs, services and retail. Trips among such land uses can then occur without, or with very limited use of, private motor vehicles. Although not considered a mitigation measure or project feature, the mixed use design would further reduce mobile source impacts in the region.

COMMENT NO. 3-7

The fundamental goal of the Compass Growth Visioning effort is to make the SCAG region a better place to live, work and play for all residents regardless of race, ethnicity or income class. Thus, decisions regarding growth, transportation, land use, and economic development should be made to promote and sustain for future generations the region's mobility, livability and prosperity. The following "Regional Growth Principles" are proposed to provide a framework for local and regional decision making that improves the quality of life for all SCAG residents. Each principle is followed by a specific set of strategies intended to achieve this goal.

GROWTH VISIONING

Principle 1: Improve mobility for all residents. GV P1.1 Encourage transportation investments and land use decisions that are

mutually supportive. GV P1.2 Locate new housing near existing jobs and new jobs near existing housing. GV P1.3 Encourage transit-oriented development. GV P1.4 Promote a variety of travel choices

The proposed project meets consistency with Growth Visioning Principle 1. SCAG Staff Comments:

The proposed project meets consistency with GV P1.1. It is located in close proximity to US-1 01, which provides regional access, and within walking distance of the Metro Red Line station at Hollywood and Vine.




The proposed project meets consistency with GV P1.2, as it provides housing in close proximity to employment in Hollywood and also would provide entertainment-related jobs on-site.

The proposed project meets consistency with GV P1.3, as it is located within walking distance of a high-capacity transit (Metro Red Line) station and intends to leverage its proximity through increased density. The proposed project meets consistency with GV P1.4. In addition to driving, the proposed project is well-served by public transit, would create a pedestrian-oriented environment, and intends to include bicycle parking.

This comment supports the conclusion in Section IV.F, Land Use, of the Draft EIR that the project is consistent with Principle 1 of SCAG’s Compass Growth Vision. This comment is noted for the administrative record and will be forwarded to the decision-makers for review and consideration.

RESPONSE NO. 3-7

Principle 2: Foster livability in all communities.

COMMENT NO. 3-8

GV P2.1 Promote infill development and redevelopment to revitalize existing communities.

GV P2.2 Promote developments, which provide a mix of uses. GV P2.3 Promote "people scaled," walkable communities. GV P2.4 Support the preservation of stable, single-family neighborhoods.

Where applicable, the proposed project meets consistency with Growth Visioning Principle 2. GV P2.4 is not applicable since there are no single-family residences on the project site.


The proposed project meets consistency with GV P2.1 since the location is an infill site and the project is a redevelopment.

The proposed project meets consistency with regard to GV P2.2 and P2.3. The Development and Site Objectives section on page 11-12 describes the mixture of uses and the pedestrian-oriented nature of the proposed project.





RESPONSE NO. 3-8

Principle 3: Enable prosperity for all people.

COMMENT NO. 3-9

GV P3.1 Provide, in each community, a variety of housing types to meet the housing needs of all income levels.

GV P3.2 Support educational opportunities that promote balanced growth. GV P3.3 Ensure environmental justice regardless of race, ethnicity or income class. GV P3.4 Support local and state fiscal policies that encourage balanced growth GV P3.5 Encourage civic engagement.

Where applicable, the proposed project meets partial consistency, or SCAG staff is unable to determine. GV P3.2 and 3.5 are not applicable.


With regard to GV P3.1, the proposed project is at least partially consistent. The proposed project intends to offer a range of unit types, but it is unclear if any of them will be affordable.

SCAG staff is unable to determine whether the proposed project meets consistency with GV P3.3 and P3.4, since they are not directly addressed in the DEIR.

This comment indicates that the project would be at least partially consistent with GV P3.1 of Compass Growth Vision Principle 3. As stated in Table IV.F-4 on page IV.F-56 of the Draft EIR, the project would include housing units of varying unit sizes to contribute to the range of housing opportunities in the City and subregion. The project does not propose to provide affordable housing units. Nonetheless, the project would still be generally consistent with this principle.

RESPONSE NO. 3-9

As stated in Table IV.F-4 on page IV.F-56, many of the Principle 3 items apply to civic responsibilities that are beyond the scope of an individual project. The commenter supports this statement and indicates that GV P3.2 and 3.5 are not applicable. This comment is acknowledged.




With regard to GV P3.3, the project’s residential and commercial uses would be available to all people regardless of race, ethnicity, or income class. Thus, the project would be consistent with GV P3.3. Additionally, the project would be consistent with GV P3.4 as it generate new revenue to the City and thus would support local and state fiscal policies that encourage balanced growth.

GV P3.5 encourages civic engagement, which is generally defined as “citizens contributing ideas, energy and action for proposals for improving community”. This principle is not applicable to the project and thus, was not addressed in the Draft EIR.

Principle 4: Promote sustainability for future generations.

COMMENT NO. 3-10

GV P4.1 Preserve rural, agricultural, recreational, and environmentally sensitive areas

GV P4.2 Focus development in urban centers and existing cities. GV P4.3 Develop strategies to accommodate growth that uses resources efficiency,

eliminate pollution and significantly reduce waste. GV P4.4 Utilize "green" development techniques

Where applicable, the project meets consistency with Growth Visioning Principle 4. GV P4.1 does not apply.


As mentioned previously, the proposed project may be characterized as an infill development and therefore meets consistency with GV P4.2.

The proposed project meets consistency with GV P4.4. Pages IV.B-33 to IV.B-35 illustrate how the proposed project intends to reduce pollution and waste, and to utilize resources more efficiently.

The proposed project meets consistency with GV P4.4. Per page II-30 in the Project Description section, the proposed project would be designed to achieve a Silver rating from the U.S. Green Building Council's Leadership in Energy and Environmental Design program.


RESPONSE NO. 3-10




COMMENT NO. 3-11

Overall, the proposed project partially meets consistency with SCAG Regional Transportation Plan Goals and Growth Visioning Principles.

CONCLUSION

All feasible measures needed to mitigate any potentially negative regional impacts associated with the proposed project should be implemented and monitored, as required by CEQA. We recommend that you review the SCAG List of Mitigation Measures for additional guidance, and encourage you to follow them, where applicable to your project. The SCAG List of Mitigation Measures may be found here: http://www.scag.ca.gov/igr/documents/SCAG_IGRMMRP_2008.pdf

When a project is of statewide, regional, or areawide significance, transportation information generated by a required monitoring or reporting program shall be submitted to SCAG as such information becomes reasonably available, in accordance with CEQA, Public Resource Code Section 21018.7, and GEQA Guidelines Section 15097 (g).

The commenter’s states that the project partially meets consistency with SCAG’s RTP and Compass Growth Visioning Principles. This comment is consistent with the conclusions provided in Section IV.F, Land Use, of the Draft EIR. The comment is noted for the administrative record and will be forwarded to the decision-makers for review and consideration.

RESPONSE NO. 3-11

The Draft EIR includes a number of mitigation measures to mitigate impacts of the project to less than significant levels. To ensure that all mitigation measures are implemented, a Mitigation Monitoring and Reporting Program (MMRP) has been prepared for the project in accordance with CEQA Guidelines Section 15097 and is included in Section IV, Mitigation Monitoring and Reporting Program, of this Final EIR.

The commenter’s request that any transportation information from the MMRP be submitted to SCAG will be implemented.

http://www.scag.ca.gov/igr/documents/SCAG_IGRMMRP_2008.pdf�




Susan Chapman Program Manager, Long Range Planning Los Angeles County Metropolitan Transportation Authority (Metro) Metro CEQA Review Coordination One Gateway Plaza MS 99-23-2 Los Angeles, CA 90012-2952

LETTER NO. 4

Los Angeles County Metropolitan Transportation Authority (Metro) is in receipt of the Draft EIR for the Columbia Square Project. This letter conveys recommendations concerning issues that are germane to Metro's statutory responsibilities in relation to the proposed project.

COMMENT NO. 4-1

This comment acknowledges receipt and review of the Draft EIR for the Columbia Square Project by the Los Angeles County Metropolitan Transportation Authority (Metro). This comment also introduces Metro’s comments to the Draft EIR for the proposed project.

RESPONSE NO. 4-1

The Traffic Impact Analysis prepared for the Draft EIR satisfies the traffic and transit requirements of the proposed project. However, the following issues should be addressed for the Final EIR:

COMMENT NO. 4-2

Several transit corridors with Metro bus service could be impacted by the project. Metro Bus Operations Control Special Events Coordinator should be contacted at 213-922-4632 regarding construction activities that may impact Metro bus lines. Other Municipal Bus Service Operators may also be impacted and therefore should be included in construction outreach efforts.

This comment indicates that the Traffic Study for the Draft EIR satisfies the traffic and transit requirements, although construction of the proposed project may impact several transit corridors. The commenter recommends that Metro Bus Operations Control Special Events Coordinator should be contacted as well as other Municipal Bus Service Operators during construction activities. Mitigation Measure I-1 in Section IV.I, Transportation and Circulation, of the Draft EIR requires the project Applicant to devise a Construction Staging

RESPONSE NO. 4-2




and Traffic Management Plan to be implemented during construction of the project. As part of the Construction Staging and Traffic Management Plan, a construction liaison shall be designated. The construction liaison shall be required to coordinate with Metro Bus Operations Control Special Events Coordinator and other potentially affected municipal bus service operators regarding any construction activities that could potentially impact bus routes. This specification has been included in Mitigation Measure I-1 and is noted in Section II, Corrections and Additions, of this Final EIR.

Considering that the project is located on the northwest corner of Sunset Bl/Gower St with Metro's bus stop located on the northeast corner; no construction trucks or equipment shall encroach upon Metro's bus zone.

COMMENT NO. 4-3

Per the commenter’s request, construction trucks and equipment during project construction shall be prohibited from encroaching upon Metro’s bus zone at the northeast corner of Sunset Boulevard and Gower Street. This prohibition has been included as new Mitigation Measure I-1(a) and is noted in Section II, Corrections and Additions, of this Final EIR.

RESPONSE NO. 4-3

Metro looks forward to reviewing the Final EIR. If you have any questions regarding this response, please call me at 213-922-6908 or by email at [email protected]. Please send the Final EIR to the following address:

COMMENT NO. 4-4

Metro CEQA Review Coordination One Gateway Plaza MS 99-23-2

Los Angeles, CA 90012-2952 Attn: Susan Chapman

This comment provides the appropriate contact for further questions on the commenter’s response to the Draft EIR. This comment is noted for the administrative record and no further response is required.

RESPONSE NO. 4-4




Denise Chow, Environmental Engineering Associate City of Los Angeles Department of Public Works Bureau of Sanitation Wastewater Engineering Services Division

LETTER NO. 5

[email protected]

The wastewater information from the Draft EIR will suffice for my analysis and the spreadsheet will not be necessary. However, I noticed that the Draft EIR did not include our (BOS) original response copy in the appendix. Please include our sewer response within the Draft EIR. Further details/comments will be sent upon completing the study. Thanks!

COMMENT NO. 5-1

This comment acknowledges that the wastewater analysis provided in the Draft EIR is adequate for the Bureau of Sanitation. A copy of the Bureau of Sanitation’s original response copy, as referenced by the commenter, is included on the last page of Appendix K, of the Draft EIR. Therefore, no further response is necessary. A follow-up comment letter from the Bureau of Sanitation was sent on June 29, 2009 and is included as Comment Letter No. 6 as follows.

RESPONSE NO. 5-1





Brent Lorscheider, Division Manager City of Los Angeles Department of Public Works Bureau of Sanitation Wastewater Engineering Services Division

LETTER NO. 6

This is in response to your May 21, 2009 letter requesting a review of your proposed project. The Bureau of Sanitation has conducted a preliminary evaluation of the potential impacts to the wastewater and stormwater systems for the proposed project.

COMMENT NO. 6-1

The Bureau of Sanitation, Wastewater Engineering Services Division (WESD) is charged with the task of evaluating the local sewer conditions and to determine if available wastewater capacity exists for future developments. The evaluation will determine cumulative sewer impacts and guide the planning process for any future sewer improvements projects needed to provide future capacity as the City grows and develops.

WASTEWATER REQUIREMENT

This comment introduces the comments that follow and provides an overview of the Bureau of Sanitation (BOS)’s role in reviewing future developments. This comment is acknowledged and no further response is required.

RESPONSE NO. 6-1

Projected Wastewater Discharges for the Proposed Project:

COMMENT NO. 6-2

Type Description Average Daily Flow per Type Description (GPD/UNIT)

Proposed No. of Units

Average Daily Flow (GPD)

Existing Office/Studio 150 GPD/1000 SQ.FT 139,312 SQ.FT (20,897)

Parking 200 GPD/1000 SQ.FT 121,670 SQ.FT (2,433) Proposed

Residential: 1 BR 120 GPD/DU 185 DU 22,200 Residential: 2 BR 160 GPD/DU 186 DU 29,760 Residential: 3 BR 200 GPD/DU 29 DU 5,800

Hotel 130 GPD/ROOM 125 ROOMS 16,250 Office 150 GPD/1000 SQ.FT 380,000SQ.FT 57,000 Retail SQ GPD/1000 SQ.FT 10,300SQ.FT 824

Restaurant/Bar 300 GPD/1000 SQ.FT 31,000SQ.FT 9,300 Parking 20 GPD/1000 SQ.FT 689,000SQ.FT 13,780

TOTAL 131,584




This comment provides BOS’ calculation of the wastewater generation associated with the project (131,584 gpd), which is consistent with the wastewater generation calculated in Table IV.J-9 on page IV.J-47 of the Draft EIR.

RESPONSE NO. 6-2

COMMENT NO. 6-3

The sewer infrastructure in the vicinity of the proposed project includes the existing 10-inch line on EI Centro Ave. The sewage from the existing 10-inch line on EI Centro Ave feeds into a 12-inch line on EI Centro Ave and continues into a 15-inch line on Lillian Way before discharging into a 20-inch line on Melrose Ave.

SEWER AVAILABILITY

Based on our existing gauging information, the current approximate flow level (d/D) and the design capacities at d/D of 50% in the sewer system are as follows:

Pipe Diameter (in)

Pipe Location Current Gauging d/D (%).

50% Design Capacity

10 EI Centro Ave * 929,734 GPD 12 EI Centro Ave * 1.23 MGD 15 Lillian Way 13 2.05 MGD 20 Melrose Ave 31 1.56 MGD

*No gauging available

Based on the estimated flows, it appears the sewer system might be able to accommodate the total flow for your proposed project. Further detailed gauging and evaluation will be needed as part of the permit process to identify a sewer connection point. If the public sewer has insufficient capacity then the developer will be required to build sewer lines to a point in the sewer system with sufficient capacity. A final approval for sewer capacity and connection permit will be made at that time. Ultimately, this sewage flow will be conveyed to the Hyperion Treatment Plant, which has sufficient capacity for the project.

If you have any questions, please call Abdul Danishwar of my staff at (323) 342-6220.

This comment indicates that based on existing gauging data, it is anticipated that the existing sewer system and the Hyperion Treatment Plant would be adequate to accommodate project-generated wastewater. This comment supports the conclusion in the Draft EIR that project impacts on the sewer system would be less than the significant. As part of the City’s requirements, an S-permit would be obtained which would be subject to approval by the Bureau of Sanitation. In accordance with City requirements, final approval for sewer capacity and connection permit will be made at the time of obtaining the S-permit.

RESPONSE NO. 6-3




COMMENT NO. 6-4

The Bureau of Sanitation, Watershed Protection Division is charged with enforcement of the provisions of the National Pollutant Discharge Elimination System (NPDES) permit.

STORMWATER REQUIREMENTS

SUSMP AND STORM WATER INFILTRATION

The proposed project is subjected to Standard Urban Stormwater Mitigation Plan (SUSMP) regulations. The proposed project is required to incorporate measures to mitigate the impact of stormwater runoff as outlined in the guidance manuals titled "Development Best Management Practices Handbook - Part B: Planning Activities". In addition the "SUSMP Infiltration Requirements and Guidelines" prioritizes the use of infiltration and bio-filtration systems as the preferred methods to comply with SUSMP requirements. These documents can be found at: www.lastormwater.org/Siteorg/businesses/susmp/susmpintro.htm. It is advised that input regarding SUSMP requirements be received in the early phases of the project from SUSMP review staff.

As discussed in Section IV.E, Hydrology and Water Quality, in accordance with the National Pollutant Discharge Elimination System (NPDES) permit, the project would be required to prepare a Standard Urban Water Stormwater Management Plan (SUSMP) which would specify operational Best Management Practices (BMPs) to be implemented. The SUSMP would be prepared in accordance with City requirements and the City’s Development Best Management Practices Handbook, Part B Planning Activities. Therefore, operational impacts on water quality would be less than significant.

RESPONSE NO. 6-4

GREEN STREETS

COMMENT NO. 6-5

The City is developing a Green Street Initiative that will require projects to implement Green Street elements in the parkway areas between the roadway and sidewalk of the public right-of-way to capture and retain stormwater and urban runoff to mitigate the impact of stormwater runoff and other environmental concerns. If the proposed project includes public right-of-way improvements and presents an opportunity to include Green Street elements as part of the project. The goals of the Green Street elements are to improve the water quality of stormwater runoff, recharge local ground water basins, improve air quality, reduce the heat island effect of street pavement, enhance pedestrian use of sidewalks, and encourage alternate means of transportation. The Green Street elements may include infiltration systems, biofiltration swales, and permeable pavements where stormwater can

http://www.lastormwater.org/Siteorg/businesses/susmp/susmpintro.htm�




be easily directed from the streets into the parkways. For more information regarding implementation of Green Street elements, please call Wing Tam at (213) 485-3985.

At this time, it is unknown as to whether the project would include the Green Street elements described by the commenter. However, such elements will be taken into consideration during the design of final plot plans. This comment is noted for the administrative record and will be forwarded to the decision-makers for review and consideration.

RESPONSE NO. 6-5

As discussed in Response 6-4 above, as part of the SUSMP, the project would incorporate BMPs to minimize stormwater pollutant in urban runoff. Therefore, operational impacts on water quality would be less than significant.

WET WEATHER EROSION CONTROL

COMMENT NO. 6-6

A Wet Weather Erosion Control Plan is required for construction during the rainy season (between October 1 and April 15 per Los Angeles Building Code, Sec. 7002). For more information, please see attached Wet Weather Erosion Control Guidelines.

As discussed in Section IV.E, Hydrology and Water Quality, the project would be required to comply with City grading permit regulations, which require necessary measures, plans, and inspections to reduce sedimentation and erosion. Pursuant to the City grading permit regulations, if project construction does occur during the rainy season, the project Applicant would prepare a Wet Weather Erosion Control Plan in accordance with the Wet Weather Erosion Control Guidelines. The attachment for the Wet Weather Erosion Control Guidelines as provided by the commenter is presented as Comment No. 6-9.

RESPONSE NO. 6-6

STORM WATER POLLUTION PREVENTION PLAN

COMMENT NO. 6-7

A Storm Water Pollution Prevention Plan (SWPPP) is required for land disturbance activities over one acre. The SWPPP must be maintained on-site during the duration of construction. WPD staff is available at your request to provide guidance on stormwater issues. Should you have any questions, please contact Meher Irani of my staff at (213) 485-0584.




As discussed in Section IV.E, Hydrology and Water Quality, in accordance with the requirements of the NPDES General Construction Activity Permit (Order No. 99-08-DWQ), the project would prepare and implement a site-specific SWPPP, which would specify BMPs and erosion control measures to be used during construction to minimize pollution in runoff. BMPs would include but not be limited to proper scheduling to avoid mass grading during the rainy season; covering materials such as bags of cement, paint, etc.; designating wash pits for washing paint, stucco, etc.; berming the site to control effluent from leaving a site during a rain event; and establishing sediment traps. These and other BMPs would eliminate or reduce pollutant levels in runoff during construction activities. Therefore, construction-related impacts to hydrology and water quality would be less than significant.

RESPONSE NO. 6-7

COMMENT NO. 6-8

The City has a standard requirement that apply to all proposed residential developments of four or more units or where the addition of floor areas is 25 percent or more, and all other development projects where the addition of floor area is 30 percent or more. Such developments must set aside a recycling area or room for onsite recycling activities. For more details of this requirement, please contact Special Projects Division.

SOLID RESOURCE REQUIREMENTS

Special Projects staff is available at your request to provide guidance on solid resource issues. Should you have any questions, please contact Daniel Hackney at (213) 485-3684.

As discussed in Section IV.J.3, Solid Waste, of the Draft EIR, in accordance with the City’s Space Allocation Ordinance (Ordinance No. 171687), the project would include design features such as the provision of recycling containers on-site and adequate storage area for such containers. Thus, the project would be consistent with the City’s solid waste resource requirements.

RESPONSE NO. 6-8

COMMENT NO. 6-9

Wet Weather Erosion Control

ATTACHMENT

The official rainy season in the City of Los Angeles is from October 1st to April 15th. During the rainy season, developers are required to provide erosion control measures at their




construction sites to prevent dirt and debris from the spilling out into adjacent properties and the public right-of-way.

The procedures for enforcing erosion control requirements are specified below:

1. Department of Building and Safety, Grading Division provides a list of on-going grading projects (projects with active grading permits) to the Bureau of Contract Administration.

2. Bureau of Engineering provides a list of on-going B-permit projects for work in the public right of way to the Bureau of Contract Administration.

3. Contract Administration sends a letter to all developers that have an active grading permit and/or B-permit and that are determined to have a potential for erosion or flood hazard stating that the permittee must prepare an erosion control plan.

4. The erosion control plan must be designed in accordance with standards maintained by the City Engineer and must be prepared by a licensed engineer registered in the State of California.

5. Erosion control plans shall be submitted to the Bureau of Engineering for review and approval no later than September 1st. The plans shall be submitted to the Permit Section of the Bureau of Engineering's district office in which the project is located.

6. Erosion control plans submitted to the Bureau of Engineering will be forwarded to the Grading Division of the Department of Building and Safety for review and comments.

7. Permittees shall make the required revisions to the erosion control plans as indicated by both the Bureau of Engineering and the Department of Building and Safety.

8. Approved erosion control plans will be forwarded from the Bureau of Engineering to the Bureau of Contract Administration and to the Department of Building and Safety.

9. Approved erosion control plans must be maintained on-site prior to September 15th and throughout the entire rainy season.

10. Erosion control inspection will be made primarily by Contract Administration inspectors with assistance from Building and Safety grading inspectors.

11. Violators of erosion control requirements will be cited and grading and/or construction work will be terminated.

12. Debris from construction sites not complying with erosion control measures shall be cleaned up by the developer. If the permittee is non-compliant, the Bureau of Street Services will provide street maintenance and will charge the developer for the cost of clean up.

This comment provides the guidelines for Wet Weather Erosion Control Plans. If project construction does occur during the rainy season, the project Applicant would prepare a Wet Weather Erosion Control Plan in accordance with these guidelines.

RESPONSE NO. 6-9




Brian Curran Director of Preservation Issues Hollywood Heritage, Inc. P.O. Box 2586 Hollywood, CA 90078

LETTER NO. 7

I.

COMMENT NO. 7-1

I am writing you in response to the draft EIR submitted by AREA Property Partners for the proposed development at 6121 Sunset Blvd, the former CBS Columbia Square Studios. Hollywood Heritage was responsible for the designation of this historic complex in its entirety, now Los Angeles Historic Cultural Landmark no. 947. Our efforts to this end were compelled by the proposed development and our desire to see greater care, oversight and protection of the historic buildings on the site. Since our first review of the project in Dec 2008 no significant alterations to the project have been made to mitigate our concerns and the threats to the cultural resources located on and around the site still remain.

INTRODUCTION

After having read the DRAFT EIR we were pleased that the applicant chose a qualified and impartial Historic Preservation firm to write their section on cultural resources and we were encouraged by the applicant's intention to restore the William Lescaze buildings along Sunset Blvd. according to the Secretary of the Interior's Standards. It was to our dismay however that the findings of the report show substantial and unmitigable impacts on all of the cultural resources at this site.

Columbia Square Studios meets the criteria for listing in the National Register of Historic Places, the California Register of Historical Resources and as a Los Angeles Historic Cultural Monument as such the site is considered a historic resource under CEQA.

The Draft EIR states in section IV.C Cultural Resources," ... the characteristic configuration, spatial relationships and setting of the Columbia Square Complex would be altered and a substantial amount of historic fabric would be adversely affected with the demolition of Studios B/C as proposed by the project. In addition, the design, size, scale, and massing of the proposed new development would significantly alter the historic relationships with the Columbia Square complex and nearby historic resources. Thus, in accordance with CEQA, implementation of the project would result in a significant impact to historic resources that cannot be mitigated. Accordingly, the project's impact to historic resources in combination with anticipated impacts to Hollywood Entertainment industry-related historic resources that would occur with implementation of the related projects would result in a significant unavoidable adverse impact to historic resources. Therefore, the project's significant unavoidable historic impact in combination with historic impacts generated by related projects would result in a cumulative historic impact."




Hollywood Heritage Agreement with Measures C 1-7:

The Draft EIR goes on to conclude however, "The demolition of Studio B/C would not conform to the Secretary of the Interior Standards and would result in a significant impact. Removal of Studio B/C could also constitute a significant adverse change to the historic resource due to its size, spatial relationship to the complex, and function. In addition, as described above, the design, location, size, scale and massing of new development within the site would significantly alter the historic relationships with the Columbia Square Complex and nearby historic resources (including the Selma-La Baig Historic District and historic resources along the Sunset corridor). While the proposed mitigation measures would reduce impacts on historic resources, such impacts would remain significant and unavoidable. In accordance with CEQA, demolition of a portion of the Complex cannot be mitigated to a level of insignificance. As described in detail in Section V, Alternatives of this Draft EIR, mitigation measures to reduce these significant impacts were considered and were determined to be infeasible."

The report sets out a series of mitigation measures Mitigation Measures C 1-7 dealing with cultural resources. Hollywood Heritage agrees and supports the implementation of these mitigation measures.

This comment summarizes the conclusions reached regarding historic resources in Section IV.C, Cultural Resources and in the Historic Resources Technical Report included as Appendix C of the Draft EIR. This comment also discusses the listing of the Columbia Square Complex as a City of Los Angeles Historic-Cultural Monument, which is also discussed in Section IV.C, Cultural Resources, of the Draft EIR.

RESPONSE NO. 7-1

COMMENT NO. 7-2

Hollywood Heritage Objects to the Demolition of Studio B/C: With these facts taken into account Hollywood Heritage agrees with the above analysis and objects to the current project as proposed. The demolition of Studios B/C is particularly disturbing to us as this structure while considered not as architecturally significant as the William Lescaze buildings from 1938 nonetheless has great cultural value due to its role in the development of television in Hollywood as well as being important to interpreting the physical evolution of the historic studio. These facts were recognized by the Cultural Heritage Commission, the City PLUM Committee and the City Council especially by Councilman Eric Garcetti, who openly supported the designation of the entire site. The demolition of Studio B/C would destroy nearly 25% of the historic fabric of the site and deny future adaptive re-use of the structure for entertainment industry purposes, its historic role.




As discussed in Section IV.C, Cultural Resources, of the Draft EIR, the City Council concurred with the Cultural Heritage Commission and the Office of Historic Resources staff recommendation that additions dating from 1939-1940 by the firm of Parkinson & Parkinson and alterations and additions from 1961 by the firm of Allison and Rible be encompassed within the proposed nomination, but defined these as non-character-defining features. The staff report states:

RESPONSE NO. 7-2

“The staff of the Office of Historic Resources finds that additions dating from 1939-1940 by the firm of Parkinson & Parkinson and alterations and additions from 1961 by the firm of Allison and Rible are encompassed within the proposed nomination but are not character-defining features. Built after the original complex designed by Lescaze in 1938, these changes are encompassed by the Studio B/C sections of the subject property located in the upper northeastern portion of the property. Although the site of some significant radio programming by notable figures, these buildings lack sufficient integrity, having been entirely altered for use as studio space in recent history.”1

Thus, due to its lack of integrity, removal of Studio B/C would not have the same impact on historic resources as removal of other portions of the Columbia Square Complex would have. As discussed in Section IV.C, Cultural Resources, while Studio B/C is proposed to be removed, the majority of the Columbia Square Complex that does convey both historic and architectural associations would be rehabilitated in accordance with the Secretary of Interior Standards.

As discussed in Section V, Alternatives of the Draft EIR, if Studio B/C were to be retained, several of the key objectives of the project would not be met. For example, the retention of Studio B/C would require the elimination of the proposed new ground level open space plaza. In addition, the mid-block crossing that promotes access within the site would be eliminated and through pedestrian connectivity, which would promote walkability throughout the Project Site, would not be provided. The Sunset Boulevard plaza would also be isolated from other project ground level linkages. In addition, the structural underpinning to provide subterranean parking below may not be viable, thus a reduction in parking could result. Finally, as discussed in more detail below, based on its location and size, Studio B/C would be difficult to re-program into a viable use if it were to be incorporated into the proposed project.

1 City of Los Angeles Office of Historic Resources Staff Report to City Council, January 27, 2009.




Three development alternatives that would retain Studio B/C were evaluated in the Draft EIR. Under Alternative 3, Studio B/C would be retained and the adjacent office use proposed by the project would instead be used for residential uses. However, Alternative 3 would not meet many of the key objectives of the project for the reasons cited above nor would it meet many of the community and economic objectives due to the absence of office space that is anticipated to be used by entertainment-related businesses. Under Alternative 4, Studio B/C would be retained and the project site would be developed with commercial uses. Alternative 4 would also not meet the key objectives identified above, nor would it meet the underlying purpose and the majority of the community, development and site design, and economic objectives of the project. Finally, under Alternative 5, Studio B/C would be retained and the office uses would be located within the northern portion of the property. As discussed in the Draft EIR, Alternative 5 would not meet the project objectives discussed above. In addition, with the relocation of the office space to the north, the amount of office space would need to be reduced. Thus, community and economic objectives to provide opportunities for entertainment-related businesses and to strengthen Hollywood’s position as an economic hub for regional commerce and entertainment uses would not be achieved to the same extent as the project. In addition, the location of the office uses within the northern portion of the site under Alternative 5 would create light and view challenges and would affect the privacy of the residents. Furthermore, if Studio B/C were to remain under Alternative 5, the new design would not provide for an office lobby with prominent visibility and access. The removal of the pocket park proposed within the northern portion of the site would also be required under Alternative 5.

Based on the above and as discussed in detail in the Draft EIR, to provide for a project that would meet the key community, development and design and economic objectives established for the project site, removal of Studio B/C, which has been determined to lack integrity when compared with the other portions of the Columbia Square Complex that would be rehabilitated, would be necessary.

COMMENT NO. 7-3

Recommendation to Minimize Impacts:

1.

Hollywood Heritage would like to see the following;

Analysis of Adaptive Reuse of Studio B/C: Expanded analysis of the adaptive re-use of Studios B/C. We would like to see a detailed description of its current condition, adaptive re-use potential and within reason, integration into the design, for example the re-location of the El Centro located restaurant into the former Studio building or the use of the studio building as a lobby or gathering space.




A description of the current condition of Studio B/C is provided in Section IV.C, Cultural Resources and the Historic Resources Technical Report provided in Appendix C of the Draft EIR.

RESPONSE NO. 7-3

As part of the Draft EIR and the planning process for the project site, reuse and integration of Studio B/C was thoroughly considered. As summarized above and discussed in the Draft EIR, three development alternatives that would retain Studio B/C were evaluated in the Draft EIR. However, these alternatives do not meet several key project objectives. The first scheme maintains the Studio B/C in its current location. This situation eliminates the mid-block crossing and main internal plaza space. The building would need to be modified to accept new structural columns from above and its use would be limited due to its “concealed” location. One option was to keep the northern half of the existing structure and move the southern studio space to the El Centro plaza. The space vacated would create a small internal plaza. This scheme, however, compromises the nature of the existing studio beyond recognition and therefore would defeat the purpose of keeping the studios. While this scheme may allow for certain project objectives to be met, it provides for questionable programming opportunities and very costly structural, mechanical, and code issues.

In addition, reuse of Studio B/C for a restaurant was also evaluated. However, due to its location with a lack of pedestrian visibility and street activity, use of Studio B/C as a restaurant was not determined to be feasible. Rather, the location for the restaurant along El Centro Avenue is considered ideal due to pedestrian and vehicular activity as well as proximity to the new hotel use. In addition, use of Studio B/C as a lobby for the office tower was also analyzed. However, given that the lobby use would be physically separated from the office building, this use was not considered practical. The new buildings could face building code challenges trying to connect the lobby of new with structure of old and could require substantially re-doing the “bones” of the historic building to bring it up to current fire codes. This option was also not considered feasible because the Project currently proposes to provide parking beneath the office tower. However, if Studio B/C was used as a lobby for the office tower, it would not be feasible to construct parking beneath Studio B/C without risking structural damage to Studio B/C. Furthermore, if the blank façade along the northern side of Studio B/C were to be physically altered to provide for the integration with the office use, the integrity of Studio B/C would be further compromised.

2.

COMMENT NO. 7-4

Analysis of Studio Demand: Hollywood Heritage is also concerned that there is no analysis of current demand and use of studio/soundstage facilities in Hollywood.




What would the impact of the loss of another studio building be on Hollywood's rapidly vanishing entertainment related industrial building stock? The applicant proposed two Alternatives, which utilize Studio B/C in the context of their development needs. Alternatives 3 and 5 both presented options for the retention of the Studio while redistributing desired square footage to other areas of the project. Alternative 5 in our view accomplishes the best with regards to the historic resources, however scale and massing remains problematic.

As stated in the Draft EIR, the underlying purpose of the project is to create a fully-integrated, accessible, vertical community that enhances the City’s economic base and is connected to and respectful of the existing on-site historic structures and its surrounding neighbors. To fulfill this underlying purpose, several community and economic objectives have been set forth for the project with the key purpose of attracting entertainment related businesses that have been historically present in Hollywood. The “office” land use category used within the Draft EIR is a broad category that was used in order to provide a conservative analysis of potential traffic impacts and to account for the difficulty in defining office space expected to be used for entertainment-related purposes in such a way that would exclude non-entertainment-related office uses. Hence, the project proposes to provide 288,890 square feet of new state-of-the-art office space with flexible floor plates to better respond to market demand and 91,110 square feet of rehabilitated office space, all of which would be geared towards attracting entertainment-related businesses. Thus, the project would provide for a substantial net increase in the amount of office space available to entertainment-related businesses in Hollywood. In addition, the project would only result in the loss of approximately 30,000 square feet of space historically used for entertainment-related uses.

RESPONSE NO. 7-4

As summarized in Response No. 7-2 and discussed in detail in Section V, Alternatives of the Draft EIR, Alternatives 3 and 5 would not meet many of the key objectives of the project.

COMMENT NO. 7-5

Effects of Design, Size, Scale and Massing on the Historic Resource: Our second concern is the design, size, scale and massing of the proposed project. The current design if executed would overwhelm the low-density horizontal historic structures along Sunset Blvd. This contrast in size and design would be particularly striking with regards to the proposed 14-story office tower, to be built on the site of Studio B/C. The structure, projecting toward Sunset Blvd., would rise like a glass monolith over the double story east wing of the site abutting it from behind. The verticality of the office tower would intrude upon and dwarf the complex confusing spatial relationships and views from Sunset and the




plaza. We also concur with the Draft EIR in its judgment that the contemporary design and introduction of new materials contrasts unfavorably with the existing structures.

The Draft EIR does conclude that the project would result in significant impacts to historic resources as a result of its design, scale size and massing. However, as discussed in Section IV.C, Cultural Resources, of the Draft EIR, the project does include numerous positive design features that respond to the fact that the Columbia Square Complex is a historic resource. For example, the use of smooth finish concrete is planned for the podium structure, which is consistent with the original cladding on the historic buildings. In addition, it is important to note that the introduction of other building materials on the site that are not compatible with the historic structures are consistent with advances in building technology, are necessary to create the desired size and scale of the new buildings, and reflect the needs of the new residential and commercial uses on the site that differ from the original industrial space. In addition, while the design of the new buildings is clearly contemporary, the architect proposes to integrate several references to Lescaze’s International Style design and proportions of the vertical Radio Building in their plans. The height of the podium was also specifically designed to be equivalent to the height of the Radio Building. In addition, the schematic designs indicate that the horizontal banding created by the windows in the historic Radio Building would be referenced in the design of the new office tower, which would employ alternating bands of concrete and wrap-around window openings as well as in the design of the podium, which introduces spandrel glass installed on a horizontal bias. These design elements are intended to reference the historic windows, and also to introduce an element of horizontality to the buildings. In addition, Lescaze’s use of pilot is and a recessed ground floor are strategically recalled in the design of the new buildings, in particular at the entrance to the Office Tower on Gower, and the hotel porte-cochere on El Centro Avenue. These elements introduced to attempt a similar light touch on the ground as Lescaze intended for his buildings. The project also includes design features to ensure that impacts to the Sunset Courtyard would be less than significant.

RESPONSE NO. 7-5

In addition, it is also important to note that Alternative 6, which has been identified as the preferred project by the project Applicant, will include sides of openings in the design of the office building that will provide additional references to the original design of the Complex and building setbacks/voids to mitigate scale issues oriented towards Sunset Boulevard just north of the proposed preserved Radio Building. Alternative 6 also includes the design features indicated above.




COMMENT NO. 7-6

Recommendation to Minimize Impacts:

1. Design alternatives such as Alternative 5, are preferable which reduce the impact of the mass of the new construction on the historic resource by moving the mass and vertical elements of the development onto the northern portion of the site. In our view reduce the impact of the project on the historic Columbia Square Complex as well as the other resources along Sunset Blvd.

Hollywood Heritage has recently had the opportunity to meet with the applicant and architect Scott Johnston to discuss way to reduce the impact of the mass of the project on the historic Columbia Square Complex.

As discussed in detail in Section V, Alternatives, and summarized in Response No. 7-2, above, Alternative 5 does not meet many of the key objectives of the project. Specifically, with the relocation of the office space to the north, the amount of office space would need to be reduced thus community and economic objectives related to providing opportunities for entertainment-related businesses and strengthening Hollywood’s position as an economic hub for regional commerce and entertainment uses would not be achieved to the same extent as the project. In addition, the location of the office uses within the northern portion of the site would create light and view challenges and would affect the privacy of the residents. Furthermore, if Studio B/C were to remain as part of Alternative 5 the new design would not provide for an office lobby with prominent visibility and access. The removal of the pocket park proposed within the northern portion of the site would also be required under Alternative 5.

RESPONSE NO. 7-6

2. We would also recommend that new construction along El Centro and Gower make greater efforts to reflect closer the historic buildings in choice of materials and design.

COMMENT NO. 7-7

As discussed in Response No. 7-5, the proposed design includes numerous features that reference the original design of the Columbia Square Complex. In addition, it is important to note that the introduction of other building materials on the site that are not compatible with the historic structures are consistent with advances in building technology, are necessary to create the desired size and scale of the new buildings, and reflect the needs of the new residential and commercial uses on the site that differ from the original industrial spaces.

RESPONSE NO. 7-7




COMMENT NO. 7-8

Reduce the Impact of the Project on Historic Homes: The last objection to the proposed design concerns the effect of the size and scale of the project on the adjacent National Register eligible Selma-LaBaig historic district as well as the historic resources on Sunset Blvd such as the Palladium, the Earl Carroll Theater, Sunset Gower Studios etc. Placing two high-rise towers, one 40 stories, one 14 stories on the edge of the historic single-family neighborhood comprised of craftsman houses, bungalow courts, two story multi-family apartment buildings is a massive change in scale with no buffer to soften the transition from low to high density.

As discussed in the Draft EIR, the size, scale, and massing of the proposed project would significantly impact existing historic resources adjacent to the project site, including resources within the Selma-La Baig Historic District and along Sunset Boulevard. However, the proposed design does include transitions in building height from the south to the north. In addition, as discussed in Section IV.A, Aesthetics of the Draft EIR the project’s increase in density and building height would be in character with the area given the nature of other new high-density development recently completed and/or underway throughout the vicinity.

RESPONSE NO. 7-8

Furthermore, the project Applicant has indicated its preference for Alternative 6, which will reduce building heights within the project site. Specifically, the residential tower would be reduced from 40 stories to 28 stories and approximately 315 feet from the street to the top of the highest habitable floor and approximately 335 feet to the top of the architectural features (as compared to 487 feet with the project). The office tower, which would be located in the southeast portion of the project site fronting Gower Street, would be 17 stories with a height of approximately 246 feet from the street to the top of the highest habitable floor and approximately 260 feet to the top of the architectural features (the same height as the project).

The towers will also have an environmental impact casting shadows over the existing neighborhood during the day but also glowing with light into the evening. On Sunset the verticality of the towers will have a jarring effect as they are not compatible in design, size, scale or massing with the existing horizontal resources on the boulevard.

COMMENT NO. 7-9




As discussed in the Draft EIR, the proposed project would not result in significant impacts associated with shading or lighting. Specifically, the project would not shade shadow sensitive uses for more than three hours between 9:00 A.M. and 3:00 P.M. Pacific Standard Time nor more than four hours between 9:00 A.M. and 5:00 P.M. Pacific Daylight Time.

RESPONSE NO. 7-9

With regard to lighting, exterior light sources would consist of low level lighting for security, wayfinding, architectural, and landscaping purposes. Lighting would be directed onto the areas to be lit (e.g., building details, landscape elements, signs, and pedestrian areas) and shielded to minimize light spillover effects. Interior light spillage from windows of the proposed uses would contribute to an increase in ambient nighttime lighting levels, but such an increase would not be substantial as the project area is already characterized by medium-high nighttime lighting levels primarily due to the existing street lights, restaurant, retail, and entertainment uses throughout the Hollywood area. The nearest light-sensitive uses are the residential uses to the east. The office tower at Columbia Square would not include exterior lighting techniques such as facade floodlighting, billboard floodlighting, internally-illuminated glass elements, and exposed neon or LED. Furthermore, the proposed residential tower and associated guest amenities atop the podium would not impact (i.e., increase the existing ambient light level) the residential neighborhoods to the east of the project. Specifically, the nighttime light from the podium would be blocked from direct view by architectural walls (the residential townhomes) and landscaping elements, preventing light from trespassing onto adjacent residential neighbors. The proposed residential tower is located between 350 and 650 feet from the neighboring residential community sufficiently far that no marked increase in existing light levels in the residential neighborhood would be measurable.

Based on a subsequent light analysis that was conducted for the project (see Appendix B of the Final EIR), the project would increase the ambient light levels by a maximum of 0.5 footcandle (FC) in the nearest sensitive land areas. Light levels at Selma Ave. and Harold Way only increase by a maximum of 0.5 FC. The west façades of the houses on Selma Ave. and Harold Way show light increases that are an average of 0.2 FC. Therefore, only negligible amounts of project specific lighting would spill off the project site and affect adjacent light sensitive areas. Therefore, the increase in ambient light would not alter the character of the area and would not interfere with nearby residential uses. Project impacts related to light would be less than significant.

In addition, as indicated above, the project Applicant has indicated its preference for Alternative 6, which will provide for reduced building heights when compared with the proposed project. Thus, potential impacts associated with shading and lighting would be reduced when compared with the project.




This comment is noted for the administrative record and will be forwarded to the decision-makers for review and consideration.

COMMENT NO. 7-10

1. Once again these impacts lead Hollywood Heritage to suggest that the development be concentrated on the northern portion of the site with the larger vertical elements being placed at the northwest corner, closer to the higher densities and new construction along Vine Street.

Recommendations to Minimize Impacts:

As discussed above in Response No. 7-2, Alternative 5, which would place both high-rise buildings within the northern portion of the site was evaluated in the Draft EIR. However, this Alternative does not meet many of the key objectives of the project and as indicated above, placing both the residential and office uses within the portion of the site would not be practical.

RESPONSE NO. 7-10

2. Hollywood Heritage would also suggest an analysis of having all of the aboveground parking be moved underground, thus freeing up space for square footage that would otherwise contribute to the height and density of the two towers.

COMMENT NO. 7-11

Placement of all of the underground parking below grade is not feasible because of the high cost associated with grading nine levels of subterranean parking. In addition, the substantial amount of grading would result in a longer construction period, which would increase the duration of construction air quality and noise impacts. Furthermore, placing all of the parking below grade would reduce the proposed building heights by approximately 75 feet. This reduction would not eliminate the significant impacts on historic resources that are associated with proposed building heights.

RESPONSE NO. 7-11

3. Reduction of the height of the towers to greater reflect existing approximate 150ft precedent set by the CIM Tower at Sunset and Vine, the House of Blues Tower and the new W Hotel.

COMMENT NO. 7-12




As discussed above, the project Applicant has indicated its preference for Alternative 6, which will reduce building heights within the project site. Specifically, the residential tower would be reduced from 40 stories to 28 stories and approximately 315 feet from the street to the top of the highest habitable floor and approximately 335 feet to the top of the architectural features (as compared to 487 feet with the project). The office tower would be 17 stories with a height of approximately 246 feet from the street to the top of the highest habitable floor and approximately 260 feet to the top of the architectural features (the same height as the project). Thus, under the proposed Alternative, building heights would not substantially contrast with existing and approved building heights in Hollywood (including the CIM Tower (approximately 297 feet) and House of Blues Tower (approximately 275 feet) and the new W Hotel (which will be approximately 141 feet in height). A substantial reduction in building heights from that proposed by Alternative 6 would not be feasible. It should also be noted that the three towers referenced by the commenter do not in fact adhere to a 150 foot precedent.

RESPONSE NO. 7-12

In conclusion it is the mission and primary concern of Hollywood Heritage that the historic resources of the site be preserved and adaptively re-used. It is our hope that the applicant will continue to refine this project so that the various concerns related here will be addressed. Hollywood Heritage is eager to continue working with AREA Property Partners at Columba Square to ensure the preservation of the historic buildings in perpetuity as well as to assist in finding a design solution which will not only forward Hollywood's development but enhance it architectural landscape as well.

COMMENT NO. 7-13

As discussed above, the preservation of historic resources has been made considered within the project as a large portion of the Columbia Square Complex would be rehabilitated in accordance with the Secretary of Interior Standards. In addition, the project incorporates various design elements that reference the original design of the CBS Complex.

RESPONSE NO. 7-13




Frank A. Stephan Senior Managing Director The Clarett Group 1901 Avenue of the Stars, Suite 1465 Los Angeles, CA 90067

LETTER NO. 8

This letter is in response to the Columbia Square Draft EIR dated May 2009. The Clarett Group represents Clarett Hollywood, LLC, on the Blvd6200 project.

COMMENT NO. 8-1

Clarett Hollywood, LLC, holds a ninety nine (99) year lease on two properties in the immediate vicinity of the proposed Columbia Square project. 6201 Hollywood Boulevard is located north of Hollywood Boulevard, and 6200 Hollywood Boulevard is located south of Hollywood Boulevard. Together, these properties make up Blvd6200.

The Blvd6200 Project EIR, which includes both blocks, was certified in July 2007. The project will be developed in two phases. The North Block phase is proceeding through plan check and is expected to commence construction in 2010. The South Block phase construction is expected to proceed within the next few years.

This comment introduces the commenter and provides information with regard to Blvd6200 located in the vicinity of the proposed project. Blvd6200 is identified as Related Project No. 41 in the Draft EIR.

RESPONSE NO. 8-1

We have identified one error, and one omission in the Columbia Square Draft EIR document.

COMMENT NO. 8-2

Identified Error:

The Columbia Square Draft EIR, Volume I, Item III, Environmental Setting, List of Related Projects, page III-17, Map Number 41. 6200 Hollywood Boulevard contains an error. This is our project, Blvd6200. The total approved number of rental dwelling units is 1,042 not 952, as noted in the document. The north block contains 535 dwelling units, and the south block, 507 dwelling units.




In response to this comment, a revision has been made in Section II, Corrections and Additions, of this Final EIR, to correct the number of dwelling units of Related Project No. 41 from 952 to 1,042 dwelling units.

RESPONSE NO. 8-2

While the number of residential units for Related Project No. 41 was incorrectly noted, the traffic analysis provided in the Draft EIR does correctly analyze this related project in terms of trips. Based on the Draft EIR for the Blvd6200 Project, Related Project No. 41 would result in a net increase of 9,387 daily trips with 477 A.M. peak hour and 806 P.M. peak hour trips. These numbers are the number of trips that were used in the traffic study and traffic analysis provided in Section IV.I, Transportation and Circulation, of the Draft EIR. Therefore, the correction of the description of Related Project No. 41 does not change the traffic analysis provided in the Draft EIR.

The correction for the number of units for Related Project No. 41 also does not alter the conclusions for cumulative impacts provided in Section IV.H, Public Services or any other section of the Draft EIR. As indicated in Section II, Corrections and Additions, even accounting for the correction in number of units, cumulative impacts with regard to police protection, fire protection, parks and recreation, schools, and libraries would be less than significant.

Identified Omission: The Columbia Square Draft EIR fails to identify Blvd6200 as a residential area in its shade and shadow studies. Attached please find our markup, identifying Blvd6200, North and South blocks,

COMMENT NO. 8-3

on the Winter Solstice Shadow map

The high rise tower is the primary producer of shade and shadow. As a significant stakeholder in the area, we would like to see this problem remediated through design.

, Figure IV.A-27. The map clearly shows that the Blvd6200 South block residences will be engulfed in shadow from 9 AM to 12 PM. Although the EIR identifies anything in excess of a three hour window as significant, we feel that this level of shade and shadow will significantly impact the quality of life of our future residents.

In response to this comment, Figures IV.A-27 through IV.A-30 has been revised to show Related Project No. 41 (Blvd6200) as shadow sensitive residential uses. These revised figures are provided in Section II, Corrections and Additions, of this Final EIR. Per the City of L.A. CEQA Thresholds Guide, a project would have a significant shading impact if shadow sensitive uses would be shaded by project-related structures for more than three

RESPONSE NO. 8-3




hours between 9:00 A.M. and 3:00 P.M. Pacific Standard Time or more than four hours between 9:00 A.M. and 5:00 P.M. Pacific Daylight Time. As shown in Revised Figure IV.A-27, residences within Related Project No. 41 (Blvd6200) on the south block would be shaded by the project’s high-rise residential tower during the winter only from 9:00 A.M. to 11:00 A.M. Furthermore, as shown in Revised Figures IV.A-28 and Revised Figure IV.A-29, the project would only shade the residences of Related Project No. 41 from approximately 9:30 A.M. through 12:00 P.M. during the spring and during the summer. Additionally as shown in Revised Figure IV.A-30, the project would shade the residences of this related project from approximately 9:30 A.M. to 12:00 P.M. during the fall. In addition, individual residential units would be shaded for only a portion of these timeframes. Thus, the project would not shade these residences longer than three hours between 9:00 A.M. and 3:00 P.M., Pacific Standard Time or longer than four hours between 9:00 A.M. and 5:00 P.M. Pacific Daylight Time. Thus, the project’s shading impacts on the residences of Related Project No. 41 (Blvd6200) would be less than significant.

In response to public input and community outreach, the project Applicant has announced its preference for Alternative 6 described in Section V, Alternatives, of the Draft EIR. Alternative 6 would result in a reduction in overall development within the site when compared with the project. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, Studio B/C (4th

As compared to the proposed project, Alternative 6 would reduce the height of the residential tower. The residential tower would be reduced from 40 stories to 28 stories and approximately 315 feet from the street to the top of the highest habitable floor and approximately 335 feet to the top of the architectural features (as compared to 487 feet with the project). The office tower, which would be located in the southeast portion of the project site fronting Gower Street, would be 17 stories with a height of approximately 246 feet from the street to the top of the highest habitable floor and approximately 260 feet to the top of the architectural features (same as the project).

Wing) would be removed and a total of approximately 105,510 square feet of the existing Columbia Square Complex space would be rehabilitated. The rehabilitated space would include 91,110 square feet for office use and 14,400 square feet for retail and restaurant/bar uses. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 26,900 square feet of new retail and restaurant/bar uses.

2

2 It should be noted that the height of the 17-story office tower for Alternative 6 has been increased from 233 feet to the top of highest habitable floor (253 feet with architectural projections) as described in Section V.F, Alternative, Draft EIR to approximately 246 feet to the top of highest habitable floor (260 feet with architectural projections). This change is noted in Section II, Corrections and Additions, of this Final EIR.




Revised Figures Alternative 6 – Figures 17 through 23 in Section II, Corrections and Additions, of this Final EIR show the shadow impacts of Alternative 6. As shown in Revised Figure Alternative 6 – Figures 17 and 18, residences of Related Project No. 41 (Blvd6200) on the south block would be shaded by the high-rise residential tower during the winter from 9:00 A.M. to 11:00 A.M. (similar to the project). Thus, Alternative 6 would not shade these residences longer than three hours between 9:00 A.M. and 3:00 P.M., Pacific Standard Time. Additionally, as shown in Revised Figures Alternative 6 – Figure 19 through Figure 21, the project would only shade the residences of Related Project No. 41 from approximately 9:30 A.M. through 12:00 P.M. during the spring and during the summer (similar to the project). Additionally, as shown in Revised Figure Alternative 6 – Figures 22 and 23, the project would shade the residences of this related project from approximately 9:30 A.M. to 12:00 P.M. during the fall (similar to the project). In addition, individual residential units would be shaded for only a portion of these timeframes. Thus, Alternative 6 would not shade these residences longer than four hours between 9:00 A.M. and 5:00 P.M. Pacific Daylight Time. Thus, shading impacts of Alternative 6 on the residences of Related Project No. 41 (Blvd6200) would be less than significant and similar to those impacts analyzed for the project as initially proposed.

In general, Clarett Hollywood, LLC supports the development of high-quality projects, and is in favor of the appropriate redevelopment of this site. We appreciate the opportunity to comment on this Draft EIR. If there are any questions about these comments, please contact me.

COMMENT NO. 8-4

Attachment: Columbia Square Draft EIR, Winter Solstice Shadows, Figure IV.A-27, marked up by The Clarett Group, indicating the location of the approved Blvd6200 project

This comment indicates the commenters’ support of high quality projects and redevelopment of the project site. This comment is noted for the administrative record and will be forwarded to the decision-makers for review and consideration.

RESPONSE NO. 8-4




Mike Buhler Director of Advocacy Los Angeles Conservancy 523 West Sixth Street, Suite 826 Los Angeles, California 90014

LETTER NO. 9

On behalf of the Los Angeles Conservancy, thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the Columbia Square Project in Hollywood [sic] The Los Angeles Conservancy is the countywide historic preservation organization for the Los Angeles area and is the largest local historic preservation organization in the United States with over 7,000 members. We applaud the applicant for its commitment to rehabilitate the William Lescaze-designed Radio Building, Studio A and Commercial/Television Building as part of the proposed project, but believe that additional refinements can further mitigate the project's adverse impacts on historic resources and help assure that the early history of the entertainment industry in Hollywood has a place in the new development.

COMMENT NO. 9-1

A. Impacts on Historic Resources

As described in the DEIR, the Columbia Square complex embodies the development of Hollywood as the West Coast center for radio and television production from its 1938 construction until 1952 when CBS moved its major television production off site. Columbia Square is important as a physical manifestation of historic changes within the entertainment industry and the technological leadership of CBS, as reflected in the cutting- edge International Style design by renowned modernist architect William Lescaze. In addition to the six-story Radio Building, the live-studio auditorium in Studio A, and the two-story Commercial/Television Building, a fourth major component was added in 1940 around the central courtyard, but not visible from Sunset Boulevard. Known as Studio B/C, this later addition was designed by the celebrated Los Angeles-based firm Parkinson and Parkinson to compliment Lescaze's design and enhance the facility's production capacity.

As noted in the DEIR, the entire Columbia Square complex "is a rare intact example of this dynamic period in entertainment history, and a lasting symbol of the interconnection of entertainment technologies in Hollywood."1 The complex has long been identified as eligible for listing in the National Register of Historic Places, and was designated a City of Los Angeles Historical-Cultural Monument in December 2008. Although Studio B/C has been substantially altered over the years and is not considered a character-defining element by the City, as well as the DEIR describing it as "lesser in provenance and integrity than the Lescaze-designed buildings," the DEIR nonetheless concludes that Studio B/C is, "a physical manifestation of the development of the site ... [and] its removal will impact the complex's ability to convey its historic development.”2 Accordingly, the proposed




demolition of Studio B/C would result in significant adverse impacts on historic resources under CEQA, warranting detailed consideration of alternatives and mitigation measures in the DEIR to lessen or avoid such impacts. 1 Columbia Square Project Draft EIR (May 21, 2009), Historic Resources Technical Report, p. 2. 2 DEIR, Historic Resources Technical Report, pp.61 and 75.

This comment provides an overview of the role of the Los Angeles Conservancy and a summary of the conclusions regarding impacts to historic resources reached in Section IV.C, Cultural Resources and in the Historic Resources Technical Report provided in Appendix C of the Draft EIR.

RESPONSE NO. 9-1

B. Long-Term Viability of Historic Elements

COMMENT NO. 9-2

In addition to significant adverse impacts on historic resources, the Conservancy is concerned that the loss of Studio B/C may render Columbia Square unusable as a production facility and thereby further erode, rather than revitalize, the motion picture industry in Hollywood. One of the stated project objectives is "to promote economic well being and public convenience through encouraging the revitalization of the motion picture industry," which is also a priority of Hollywood Community Plan. Although the project description includes office space that "would likely include entertainment-related office and studio uses considering the site's location in Hollywood," the various alternatives that retain Studio B/C do not examine the feasibility of the complex's continued use as a studio or production facility, instead noting the difficulty of re-programming the space into a viable use.3

The Secretary of the Interior's Standards for Rehabilitation, Standard 1, states that "a property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces, and spatial relationships." The Columbia Square complex had been in continuous use as a production facility - whether radio, television or movie programming, music or sound recording, or news broadcast - for close to 70 years. While the entertainment industry has changed over time, production facilities of various types and sizes continue to be in demand in Hollywood. In order to maintain the site's historic use, the proposed project should maximize opportunities to reprogram the existing Columbia Square buildings for entertainment-related uses compatible with their historic function. Likewise, the Final EIR should consider the feasibility of continuing these uses when evaluating alternatives and impacts on historic resources. For example, will the loss of the studio space in Studio B/C affect the viability of Studio A and production facilities in the Radio Building to continue their historic use? Alternatively,

In fact, no studio-related use is mentioned when examining alternatives in relation to the office uses proposed on site.




will Studio A be converted to office space, as currently indicated in the DEIR, or can it be reused as a production space, theater, screening room, or other use more compatible with its original design and remaining historic fabric? 3 DEIR, p. II-21

The commenter is correct that one of the objectives of the project is to "to promote economic well being and public convenience through encouraging the revitalization of the motion picture industry." Several additional community and economic objectives have also been set forth for the project with the key purpose of attracting entertainment-related businesses that have been historically present in Hollywood. The “office” land use category used within the Draft EIR is a broad category that was used in order to provide a conservative analysis of potential traffic impacts and to account for the difficulty in defining office space expected to be used for entertainment-related purposes in such a way that would exclude non-entertainment-related office uses In fact, both the project’s approximately 288,890 square feet of new state-of-the-art office space as well as the 91,110 square feet of office space to be rehabilitated in accordance with the Secretary of Interior Standards would be geared towards attracting such entertainment-related businesses. Thus, even with the loss of approximately 30,000 square feet of space within Studio B/C, the project would provide for a substantial net increase in the amount of space available to entertainment-related businesses in Hollywood.

RESPONSE NO. 9-2

As described in Section II, Project Description, of the Draft EIR, approximately 105,000 square feet of the existing Columbia Square Complex would be rehabilitated in accordance with the Secretary of Interior Standards. While approximately 14,400 square feet of this existing area is anticipated to be used for retail and restaurant uses, the remaining 91,110 square feet is of a sufficient size and configuration to be used for a wide variety of entertainment-related uses, including but not limited to studio, broadcast, and production uses.

Studio B/C has been historically used for studio and production uses and most recently has been used for short-term production-related uses. Based on a comprehensive review of Studio B/C, it was determined that due to its location within the rear of the Columbia Square complex and configuration that Studio B/C would be difficult to program in the context of the proposed project. Studio B/C lacks direct public access to the internal workings of the building and would create circulation problems as well as potential exiting issues arising from a different use. The exterior of the building may have to be substantially modified in order to allow proper entry. In addition, as indicated in the Draft EIR, if Studio B/C were to be retained, several of the key objectives of the project would not




be met. For example, the retention of Studio B/C would require the elimination of the proposed new ground level open space plaza. In addition, the mid-block crossing that promotes access within the site would be eliminated and through pedestrian connectivity would not be provided. The Sunset Boulevard plaza would also be isolated from other project ground level linkages. The structural underpinning to provide subterranean parking below may not be viable, thus a reduction in parking could result if Studio B/C were to be retained. Furthermore, the removal of Studio B/C would not compromise the ability of the remaining portions of the Columbia Square complex to accommodate entertainment-related uses. Rather, the new office tower is, due to its location in central Hollywood, anticipated to potentially house broadcast, entertainment or media uses. The new floor plates and ceiling heights could accommodate more technologically sophisticated uses than the existing studio.

For informational purposes, three development alternatives that retain Studio B/C (Alternatives 3, 4, and 5) were evaluated in Section V, Alternatives, of the Draft EIR. These alternatives included replacing the office uses with residential uses, development of an all-commercial land use plan and relocating the office tower to the northern portion of the site. As summarized in Response No. 7-2, these alternatives would not meet the objectives identified above, nor would they meet many of the community, development and site design, and economic objectives of the project, including those that relate to providing for entertainment-related uses within Hollywood.

Finally, given the market-driven schedule for future phases of construction, a new mitigation measure should be added to safeguard against preemptive demolition of Studio B/C, deferring issuance of demolition permits until a permanent replacement project is pending and the applicant has demonstrated the financial resources necessary to complete the project within a reasonable timeframe.

COMMENT NO. 9-3

Thank you for the opportunity to comment on the Draft Environmental Impact Report for the Columbia Square Project. Please feel free to contact me at (213) 430-4203 or [email protected] should you have any questions.

The project Applicant has agreed to accept the proposed limitation on the demolition of Studio B/C as a Condition of Approval as follows: The project Applicant is prepared to commence construction of the new office building, which may be evidenced by the project Applicant submitting plans for plan check for the office building, and to complete construction in a reasonable period of time.

RESPONSE NO. 9-3




Darryl Ford 1821 1/2 Winona Boulevard Los Angeles, CA 90027 [email protected]

LETTER NO. 10

Thank you for the opportunity to comment on the DEIR for the Columbia Square Project (Project) located at 6121 Sunset Boulevard. The Project proposes to develop 400 residential units, a 125 room hotel, 380,000 square feet of office space, and 41,300 square feet of retail/restaurant/bar space on a 4.68 site located in the center of Hollywood.

COMMENT NO. 10-1

This comment reiterates the components of the proposed Columbia Square Project as described in the Draft EIR.

RESPONSE NO. 10-1

In response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. Alternative 6 would result in a reduction in overall development within the site when compared with the project. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 41,300 square feet of retail, bar and restaurant floor area. Studio B/C (4th Wing) would also be removed and approximately 105,510 square feet of the existing 136,233 square foot Columbia Square Complex located along Sunset Boulevard would be retained and renovated to meet the Secretary of Interior Standards for office, retail and potential studio uses. Under this Alternative, at least 1,770 parking spaces would be provided within a parking structure comprised of up to nine levels. Up to the three lower levels would be subterranean while the remaining upper levels would form the podium upon which the residential tower and town homes would be located (the podium level would thus comprise the seventh floor).

I am writing as a resident of Hollywood to express my concern with the impacts that the Project, as currently proposed, would have on the Hollywood Community.

COMMENT NO. 10-2





RESPONSE NO. 10-2

*Page IV.F-16 - Land Use Project Impacts*

COMMENT NO. 10-3

The DEIR states that *"the determination of consistency with applicable land use policies and ordinances is based upon a review of the previously identified planning documents that regulate land use or guide land use decisions pertaining to the project site" *and that *"CEQA Guidelines Section 15125(d) requires that an EIR discuss inconsistencies with applicable plans that the decision-makers should address.'" This DEIR document makes no attempt to analyze the Project's consistency with the *currently adopted* land use documents and policies as the City of Los Angeles CEQA Thresholds Guide requires. The analysis in the DEIR is based on the assumption that the requested discretionary actions will be approved. To be clear, without the requested General Plan Amendment and Zone Change this project *is not consistent* with the Hollywood Community Plan nor applicable LAMC requirements. Essentially, the Project proposes to change the existing land use to fit the project as designed. Therefore, the DEIR does not give decision makers a proper analysis of the project and the project's environmental impacts on existing land use goals and policies.

Section IV.F, Land Use, of the Draft EIR provides an analysis of the project’s consistency with currently adopted land use document and policies. Specifically, pages IV.F-31 through IV.F-34 provides an analysis of the project’s consistency with the currently adopted Hollywood Community Plan. As discussed therein, the current land use designation for the site is Commercial Manufacturing. The project’s proposed commercial uses (including office, hotel, and retail/restaurant uses) are permitted under the current land use designation. In order to construct a residential development, the project would require a General Plan Amendment to change the land use designation to Regional Center. As indicated by the commenter, the project would be inconsistent with the current land use designation. However, as noted in the Draft EIR, the current land use designation is inconsistent with the site’s C4 commercial zoning. Thus, the project Applicant has requested a General Plan Amendment. Furthermore, as analyzed in Table IV.F-2, the project would be generally consistent with the applicable policies of the Hollywood Community Plan.

RESPONSE NO. 10-3

Additionally, pages IV.F-38 through IV.F-40 analyzes the project’s consistency with the LAMC. The project site is currently zoned [Q]C4-1VL-SN. The [Q] condition prohibits




residential uses per Ordinance No. 165,662. The project as proposed would be inconsistent with the existing zoning. However, pursuant to LAMC Section 12.32F, the project includes a Zone Change to eliminate the [Q] condition to develop the project’s proposed residential uses. Furthermore, the project proposes a Height District Change from IVL to Height District 2. The Height District Change would permit unlimited building heights and a maximum floor area ratio of 6:1.

Overall, with approvals of the requested General Plan Amendment and Zone Change, the project would be consistent with the currently adopted Hollywood Community Plan and LAMC and impacts relative to land use consistency would be less than significant.

Furthermore, it should be noted that the City released the draft update of the Hollywood Community Plan on July 1, 2009 (after circulation of the Draft EIR), although this has not yet been adopted by the City and may yet be modified. As indicated in Map 24 of the draft update Hollywood Community Plan, the City proposes to change the existing land use designation of the project site to Regional Center, consistent with the project. Furthermore, with this proposed Regional Center designation, a floor area ratio of 45:1 would be permitted with up to a 6:1 floor area ratio permitted on a case-by-case basis. Thus, the project’s proposed General Plan Amendment and Zone Change would be aligned with what the City proposes for the project site.

*Page IV. F-23 - Analysis of Project Consistency with General Plan Framework Policy 3.1.3*

COMMENT NO. 10-4

Contrary to the analysis provided, the Project is not consistent with Policy 3.1.3. Policy 3.1.3 is to *"identify areas for the establishment of new open space opportunities to serve the needs of existing and future residents. These opportunities may include a citywide linear network of parkland and trails, neighborhood parks, and urban open spaces."* The project is proposing to provide none of these amenities. The project's two public courtyards and "pocket" park will serve more as pedestrian pathways, building access points, and seating areas for retail establishments than as recreational amenities. The "recreation areas" located on the podium level, which constitutes the "the majority of these open space and recreation areas," consist only of swimming pools and sunning areas. It is difficult to argue that these amenities alone are sufficient to provide for the "needs of existing and future residents;" specifically children, youth, or senior residents

The project would be generally consistent with Policy 3.1.3 of the General Plan. It should also be noted that Policy 3.1.3 of the General Plan does not specifically apply to new development projects, but is a Citywide policy. As stated in Section IV.F, Land Use, of

RESPONSE NO. 10-4




the Draft EIR, the project would provide publicly accessible landscaped open space that would consist of two public courtyards and a pocket park on the ground level. These areas would serve as open space and recreational space for project residents, employees, and visitors. Project residents and/or guests would have access to additional recreational amenities that would include fitness and recreation rooms, large central courtyards and gardens on the podium level, two swimming pools, entertaining patios, sunning areas, and landscaped recreational areas. The variety and range of recreational opportunities offered by the project’s urban open space and recreational amenities would be sufficient to provide for the needs of project residents. Additionally, Mitigation Measure H-6 on page IV.H-62 of the Draft EIR has been proposed to require that the project Applicant develop recreational and park amenities, pay in-lieu fees, or provide a combination of such that the project would provide a total of 3 acres per 1,000 residents would satisfy the parkland dedication requirements of Section 17.12, the City’s implementing ordinance for the Quimby Act.

*Page IV.F-26 - Analysis of Project Consistency with General Plan Framework Policy 3.10.5*

COMMENT NO. 10-5

Contrary to the analysis provided, the Project is not consistent with Policy 3.10.5. Policy 3.10.5 is to *"support the development of small parks incorporating pedestrian oriented plazas, benches, other streetscape amenities and, where appropriate, landscaped play areas." *Again, the project is not proposing the development of any small parks nor any play areas. The project is proposing the development of two small plazas designed to serve as access and entry points for residents and to serve future retail establishments. Additionally, the Sunset Boulevard plaza would not connect to any other public "green spaces on-site and creat[e] a walkable district." There are no green spaces on site or anything besides retail establishments to walk to within the "district."

It should be noted that General Plan Framework Policy 3.10.5 does not specifically require new development projects to develop small parks, but is a Citywide policy.

RESPONSE NO. 10-5

As stated in Section IV.F, Land Use, of the Draft EIR, the project would provide publicly accessible landscaped open space that would consist of two public courtyards and a pocket park on the ground level. These areas would be pedestrian-oriented and would include benches and other similar amenities, and thus, would serve as open space and recreational space for project residents, employees, and visitors. The project’s ground level open space would be connected via landscaped pedestrian pathways and thus, much of the ground level of the project site would be walkable.




Furthermore, project residents and/or guests would have access to additional recreational amenities that would include fitness and recreation rooms, large central courtyards and gardens on the podium level, two swimming pools, entertaining patios, sunning areas, and landscaped recreational areas.

*Page IV.F-27 - Analysis of Project Consistency with General Plan Framework Policy 4.1.1*

COMMENT NO. 10-6

Contrary to the analysis provided, the Project is not consistent with Policy 4.1.1. Policy 4.1.1 is to *"provide sufficient land use and density to accommodate an adequate supply of housing units by type and cost within each City sub-region to meet the twenty-year projections of housing needs. 'While the project is proposing to provide 400 residential units of various sizes and layouts, it is not proposing to provide any affordable housing or income restricted units. To be consistent with this policy, the Project needs to develop units of various "costs" that are affordable to people with a variety of incomes.

The project would provide much needed housing in the Hollywood area of the City. Specifically, the project would provide 400 residential units that would include a mix of residential units varying in sizes and design (one, two, and three bedroom units). While the project does not provide affordable housing or income restricted units as the commenter states, the mix of units would vary in costs and would increase the overall supply of housing available to meet the demands of the resident population. Therefore, the project would be generally consistent with Policy 4.1.1 of the General Plan Framework.

RESPONSE NO. 10-6

As stated in Response No. 10-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 41,300 square feet of retail, bar and restaurant floor area. Even with the reduction in residential units, Alternative 6 would still be consistent with this policy of the General Plan Framework.

*Page IV. F-30 - Analysis of Project Consistency with General Plan Framework Policy 4.1*

COMMENT NO. 10-7

Contrary to the analysis provided, the Project is not consistent with Policy 4.1. Policy 4.1 is to *''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." *The project would create a significant impact at 13 intersections (page 1-87). The project would result in significant and unavoidable impacts to a total of 7 intersections (page 1-96). The project is forecast to generate a net increase of 9,226 trips (page 1-87). The project would create a significant impact at three of the four neighborhood street segments (page 1-95). No feasible mitigation measures have been identified for the impacted neighborhood street segments (page 1-95). Travel on nearby residential collector streets would not be necessary to access the Project but the streets would be impacted by the traffic generated by the project which would make it more difficult for residents to access their homes and businesses. Per the May 15, 2009 letter from the LADOT, the LADOT recommended that "to further reduce the number of unmitigated traffic impacts, special consideration should be given to a project alternative (other than the proposed) that is of a reduced density and would, therefore, generate less traffic and result in less traffic impacts" (page 4).

In response to this comment, a revision has been made to state that the project would be inconsistent with Policy 4.1 of the General Plan Framework. This revision is provided Section II, Corrections and Additions, of this Final EIR. This revision does not change the Draft EIR’s conclusion that land use impacts would be less than significant.

RESPONSE NO. 10-7

As discussed in the Appendix I of the Traffic Study, mitigation of the neighborhood traffic intrusion impacts identified in the Draft EIR on the four street segments listed above would require development and implementation of a neighborhood traffic management plan that would identify measures to make local routes less attractive to through traffic, such as speed reduction measures, movement prohibitions, physical mitigations, and parking restrictions. Implementation of the neighborhood traffic control program will take into account Selma Avenue east of Gower Street and will be implemented on an areawide basis with all affected parties, including neighborhood residents, council representatives, planners and traffic engineers, involved in development of the plan.

The City of Los Angeles has a neighborhood traffic management process in place that includes a number of specific steps. In the event that neighbors are concerned with the potential impact of the proposed project, they may petition LADOT for a neighborhood traffic study. If traffic conditions have changed and if LADOT staff believes the changes are attributable to the project, LADOT staff will work with the neighbors to identify traffic calming/traffic management improvements that would address the traffic problem. If the neighbors agree that the suggested solutions are workable, the improvements would be installed on a trial basis. Improvements that could be considered include speed reduction measures speed humps and stop signs, movement prohibitions (e.g., restricted turns), physical measures (e.g., road narrowing, curb extensions), and parking controls. Since the project applicant cannot unilaterally impose these measures, the measures are not




considered by LADOT to be feasible and therefore, the project’s impacts on neighborhood street segments are considered significant and unavoidable at this time. It should be noted that after project development, measures could be developed by LADOT and the neighbors to mitigate project impacts.

As stated in Response No. 10-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 41,300 square feet of retail, bar and restaurant floor area. As provided on pages V-150 through V-156 of the Draft EIR, Alternative 6 would result in approximately 8,584 net new daily trips which would be less than the project’s 9,200 net new daily trips. With implementation of mitigation measures, this Alternative would result in significant and unavoidable impacts at the same seven intersections as the project and on the same three neighborhood street segments as the project.

*Page IV.F-34 - Analysis of Project Consistency with the Hollywood Community Plan Circulation Policy*

COMMENT NO. 10-8

Contrary to the analysis provided, the Project is not consistent with this Hollywood Community Plan Circulation Policy. The circulation policy is '''no increase in density shall be effected by zone change or subdivision unless it is determined that the local streets, major and secondary highways, freeways, and public transportation available in the area of the property involved, are adequate to serve the traffic generated." * The project is proposing a zone change. The project would create a significant impact at 13 intersections (page I-87) and would result in significant and unavoidable impacts to a total of 7 intersections (page I-96). Clearly the local streets and highways are inadequate to serve the traffic generated by the project; therefore, no increase in density shall be allowed.

As noted by the commenter and as discussed in Section IV.I, Transportation and Circulation of the Draft EIR, prior to mitigation, the project would create significant impacts at 13 intersections. After implementation of mitigation measures, the project would result in significant and unavoidable impacts at 7 intersections. As indicated on page IV.I-4 of the Draft EIR, traffic conditions at intersections are measured by level of service (LOS), which ranges from LOS A to LOS F. LOS A through LOS D are generally considered acceptable levels while LOS E and F are generally considered unsatisfactory levels. Table IV.I-12 on pages IV.I-45 through IV.I-47 indicates that of the 7 intersections that would be significantly

RESPONSE NO. 10-8




impacted by the project, 5 would operate at LOS D or better (which are considered acceptable levels) after implementation of mitigation measures. With regard to the remaining 2 significantly impacted intersections, as shown in Table IV.I-12, these intersections would operate at LOS E even without implementation of the project.

Furthermore, as discussed in the Draft EIR, while the project would increase density through a zone change and would generate additional traffic, the project’s proximity to public transit would support regional mobility goals and local policies that encourage development near public transportation facilities. The project would also implement mitigation measures and a transportation demand management program to reduce traffic impacts to the maximum extent feasible, and thus would be generally consistent with the intent of the Community Plan that such transportation systems are adequate.

It should also be noted that, although this has not yet been adopted by the City and may yet be modified, the draft update of the Hollywood Community Plan (which was released on July 1, 2009 after circulation of the Draft EIR) does not include this policy.

*Page IV.F-34 - Analysis of Project Consistency with the Hollywood Community Plan Service System Policy*

COMMENT NO. 10-9

Contrary to the analysis provided, the Project is not consistent with this Hollywood Community Plan Service System Policy. The circulation policy is *''no increase in density shall be effected by zone change or subdivision unless it is determined that such facilities are adequate to serve the proposed development."* The project is proposing a zone change. As discussed below the project would create a significant impact to the City's park and recreation system; therefore, no increase in density shall be allowed.

The project would increase the site density through a zone change. However, as discussed further below in Response No. 10-15, with implementation Mitigation Measure H-6, the project would not create a significant impact on parks and recreation. As such, the project would be consistent with the Hollywood Community Plan Service System Policy.

RESPONSE NO. 10-9

*Page IV. F-43 - Analysis of Project Consistency with the Hollywood Redevelopment Plan Goal 9*

COMMENT NO. 10-10

Contrary to the analysis provided, the Project is not consistent with the Hollywood Redevelopment Plan Goal 9. The goal is to *''provide housing choices and increase the supply and improve the quality of housing for all income and age groups, especially for




persons with low and moderate incomes; and to provide home ownership opportunities and other housing choices which meet the needs of the resident population."* As discussed above, the project is not proposing the development of housing for all income and age groups as the project is not proposing the development of any units specifically for those with low or moderate incomes. There is an identified need for additional low and moderate income units in Hollywood.

The project would provide housing choices and increase the supply of housing in the Hollywood area by providing 400 residential units of varying sizes (one, two, and three bedroom units) to meet the needs of the resident population. While the project does not provide affordable housing or units that are specifically reserved for those with low to moderate incomes, the project’s residential units would vary in costs and would be available to all age groups. Restricting the supply of housing would drive up the cost of housing in the area. Therefore, the Project would be generally consistent with Goal 9 of the Hollywood Redevelopment Plan.

RESPONSE NO. 10-10

Goal 9 is intended to apply on a redevelopment area-wide basis and is not intended to apply to each project.

As stated in Response No. 10-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 41,300 square feet of retail, bar, and restaurant floor area. Even with the reduction in residential units, Alternative 6 would still be consistent with this goal of the Hollywood Redevelopment Plan.

*Page IV.F-43 - Analysis of Project Consistency with the Hollywood Redevelopment Plan Goal 14*

COMMENT NO. 10-11

Contrary to the analysis provided, the Project is not consistent with the Hollywood Redevelopment Plan Goal 14. The goal is to *''promote and encourage development of recreational and cultural facilities and open spaces necessary to support attractive residential neighborhoods and commercial centers."* As discussed, the project is not proposing the development of any recreational facilities accessible (nor visible) to non-residents, nor any cultural facilities. The "open space" being proposed consists of two small




plazas designed to serve as access and entry points for residents and to serve future retail establishments.

As stated in Response No. 10-4, the project would provide publicly accessible landscaped open space that would consist of two public courtyards and a pocket park on the ground level. These areas would serve as open space and recreational space for project residents, employees, and visitors. Furthermore, project residents and/or guests would have access to additional recreational amenities that would include fitness and recreation rooms, large central courtyards and gardens on the podium level, two swimming pools, entertaining patios, sunning areas, and landscaped recreational areas. Therefore, the project would be generally consistent with Goal 14 of the Hollywood Redevelopment Plan.

RESPONSE NO. 10-11

*Page IV.F-50 - Analysis of Project Consistency with SCAG Open Space and Conservation Chapter Recommendations*

COMMENT NO. 10-12

Contrary to the analysis provided, the Project is not consistent with SCAG Open Space and Conservation Recommendations. The recommendation is to *''provide adequate land resources to meet the outdoor recreation needs of the present and future residents in the region and to promote tourism in the region"* As discussed, the project is not proposing the development of any outdoor recreation facilities. The mitigation measure proposed in the DEIR in Section IV.H.4 is completely inadequate to meet the recreational needs of the project residents. A detailed discussion of this issue is below.

As stated in Response No. 10-4, the project would provide publicly accessible landscaped open space that would consist of two public courtyards and a pocket park on the ground level. These areas would serve as open space and recreational space for project residents, employees, and visitors. Furthermore, project residents and/or guests would have access to additional recreational amenities that would include fitness and recreation rooms, large central courtyards and gardens on the podium level, two swimming pools, entertaining patios, sunning areas, and landscaped recreational areas. Therefore, the project would be consistent with SCAG’s Open Space and Conservation Chapter Recommendations in the Regional Comprehensive Plan and Guide (RCPG).

RESPONSE NO. 10-12

Additionally, it should be noted that the 2008 Regional Comprehensive Plan (RCP) was accepted by SCAG's CEHD Committee and the Regional Council. The 2008 RCP




replaced SCAG’s RCPG, which is now considered defunct. The Regional Council directed staff to not use the 2008 RCP for consistency reviews of regionally significant projects. Rather, the policies provided in the Regional Transportation Plan and Compass Blueprint shall be used in consistency reviews for regional significant projects. This 2008 RCP is noted in Section II, Corrections and Additions of this Final EIR.

*Page IV.H-51 - State Quimby Act*

COMMENT NO. 10-13

The DEIR states that "*under the Quimby Act, dedications of land are not to exceed three acres of parkland per 1 ,000 persons residing within a subdivision, and in-lieu fee payments shall not exceed the proportionate amount necessary to provide 3 acres of parkland per 1 ,000 persons, unless the amount of existing neighborhood and a community parkland exceeds that limit" *and that *"as the parkland standard is not exceeded in the project area, the maximum exaction for the project under the Quimby Act is 3 acres of parkland per 1 ,000 persons. *This analysis is incorrect. The State Quimby Act does not define what a neighborhood or a community park is. As such, all parkland in the City of Los Angeles under the control of the City's Department of Recreation and Parks meets the definition of neighborhood and community parkland. Further, the State Quimby Act indicates that if the amount of existing parkland exceeds 3 acres per 1,000 then the local jurisdiction can request additional parkland to a level not to exceed 4 acres per 1,000 persons. The City of Los Angeles has over 4 acres of parkland per 1,000 residents. Therefore, per the State Quimby Act, the City of Los Angeles could request 4 acres of parkland per 1,000 persons.

Based on written correspondence provided by the Los Angeles Department of Recreation, and Parks on July 26, 2007, the City of Los Angeles has 0.70 acres of neighborhood and community parkland per 1,000 residents and the Hollywood Community Plan area has 0.41 acre per 1,000 residents.

RESPONSE NO. 10-13

Regardless, within the City of Los Angeles, the parkland dedication requirements of the State Quimby Act are implemented through Section 17.12 of the LAMC. Per Section 17.12, the area of land that is required to be dedicated for park and recreation uses is based on a site’s gross subdivision area and the maximum density permitted by the zone within which the site is located (not by acres per 1,000 residents). Park fees may be paid in lieu of the dedication of all or a portion of all of the land. According to Section 17.12, projects at a maximum density of over 100 dwelling units per acre would be required to dedicate 32 percent of the project site’s gross subdivision area as parkland. Thus, the project, which would be developed on 4.68 acres (203,861 square feet) would be required to dedicate 65,236 square feet (1.50 acres) of land and/or pay in-lieu fees.




While the project would not dedicate 1.50 acres of parkland, the project would provide would provide publicly accessible landscaped open space that would consist of two public courtyards and a pocket park on the ground level. Nonetheless, the project would not meet the parkland dedication requirements of Section 17.12, the City’s implementing ordinance for the Quimby Act. Therefore, Mitigation Measure H-6 on page IV.H-62 of the Draft EIR has been proposed to require that the Project Applicant develop recreational and park amenities, pay in-lieu fees, or provide a combination of such that the project would provide a total of 3 acres per 1,000 residents would satisfy the parkland dedication requirements of Section 17.12. Thus, with implementation of Mitigation Measure H-6, impacts on parks and recreation would be mitigated to less than significant.

*Page IV.H-53 - Public Recreation Plan*

COMMENT NO. 10-14

The DEIR only briefly discusses the Public Recreation Plan's short and intermediate range standards. A couple of important details have been omitted. The Public Recreation Plan does not indicate what the "life of the plan" is, so it is impossible to determine when to use the long, medium or short range standards when analyzing a project. In any case, the City's Department of Recreation and Parks consistently utilizes the long-range standards of 2 acres of neighborhood parks and 2 acres of community parks per 1,000 persons when analyzing projects. The long-range standard is the only standard that should be used.

The Public Recreation Plan (PRP) sets forth the desired long-range standards of two acres per 1,000 persons for neighborhood parks with a service radius of 0.5 mile and two acres per 1,000 persons for community parks with a service radius of 2.0 miles. However, the PRP states that these long-range standards may not be reached during “the life of the plan”, and therefore, includes more attainable short and intermediate-range standards of one acre per 1,000 persons for neighborhood parks and one acre per 1,000 persons for community parks. The commenter is correct in stating that the PRP does not indicate what the “life of the plan” is. Therefore, Section IV.H.4, Parks and Recreation, provides an analysis of the project’s consistency with

RESPONSE NO. 10-14

both

As indicated on page IV.H-59, the project would exceed the PRP’s short and intermediate-range standards for neighborhood parks. However, the project would fall short of the long-range standard for neighborhood parks. Additionally, the project would not meet the PRP’s long range standard or short and intermediate range standards for community parks. With the implementation of Mitigation Measure H-6, the project would comply with the parks and recreational requirements set forth by the City.

the long-range and short/intermediate range standards.




It should also be noted that the PRP standards are Citywide standards and not requirements for specific development projects, such as the proposed project. Rather specific, residential development projects are subject to Sections 12.21 and 17.12 of the LAMC. Please refer to Response Nos. 10-15 and 10-20, below for a discussion of the project’s consistency with Sections 12.21 and 17.12 of the LAMC, respectively.

*Page IV. H-53 - Los Angeles Municipal Code* The DEIR discusses LAMC section 12.21 open space requirements. LAMC 12.21 has nothing to do with Parks and Recreation and this discussion does not belong in this section. Further, including a discussion of LAMC 12.21 in this section only serves (intentionally or not) to blur the distinction between "open space" areas and parks and recreation areas. The two are separate and should be treated and analyzed as such.

COMMENT NO. 10-15

The stated purpose of Section 12.21 of the LAMC is to:

RESPONSE NO. 10-15

“establish reasonable and uniform regulations to provide usable open space as a means to fulfill the following objectives: afford occupants of multiple residential dwelling units opportunities for outdoor living and recreation; provide safer play areas for children as an alternative to the surrounding streets, parking areas, and alleys…. and provide a more desirable living environment for occupants of multiple residential dwelling units by … improving pedestrian circulation and providing access to on-site recreation facilities”.

Section 12.21 requires that all residential developments containing six or more dwelling units on a lot provide, at a minimum, usable open space area based on dwelling units to be developed. As defined, by the LAMC, usable open space is defined as areas which are designed and intended to be used for active or passive recreation. Therefore, the discussion of Section 12.21 is appropriate in Section IV.H, Parks and Recreation, of the Draft EIR. Additionally, on page IV.H-60 of Section IV.H.4, Parks and Recreation, of the Draft EIR does provide a separate analysis of the project’s consistency with the open space requirements of LAMC Section 12.21.

*Page IV. H-55 - Existing Conditions*

COMMENT NO. 10-16

The development of Seily Rodriguez Park is complete and the park is open and available to the public. The DEIR is incorrect.




The commenter is correct in stating that the development of Seily Rodriguez Park is complete and available to the public. This correction has been made in Section II, Corrections and Additions, of this Final EIR.

RESPONSE NO. 10-16

*Page IV. H-58 - Project Design Features*

COMMENT NO. 10-17

The project's two public courtyards and "pocket" park will serve more as pedestrian pathways, building access points, and seating areas for retail establishments than as recreational amenities. While the proposed public courtyards may be beneficial design elements they are not recreational amenities and should not be counted as such. The "pocket" park is a park in name only; there are no recreational elements or open green space proposed for this "park." The "recreation areas" located on the podium level, which constitutes the "the majority of these open space and recreation areas," consist only of swimming pools and sunning areas.

It is important to note that the definition of open space provided in this DEIR is based on LAMC section 12.21; which includes both common and private open space areas. Again, LAMC section 12.21 has nothing to do with Parks and Recreation and does not belong in this section.

As stated in Response No. 10-4, the project’s two public courtyards and pocket park on the ground level would serve as open space and recreational space for project residents, employees, and visitors. Furthermore, project residents and/or guests would have access to additional recreational amenities that would include fitness and recreation rooms, large central courtyards and gardens on the podium level, two swimming pools, entertaining patios, sunning areas, and landscaped recreational areas.

RESPONSE NO. 10-17

As stated in Response No. 10-15, Section 12.21 of the LAMC requires that all residential developments containing six or more dwelling units on a lot provide, at a minimum, usable open space area based on dwelling units to be developed. As defined, by the LAMC, usable open space is defined as areas which are designed and intended to be used for active or passive recreation. Therefore, the discussion of Section 12.21 is appropriate in Section IV.H, Parks and Recreation, of the Draft EIR.




*Page IV.H-59 - Public Recreation Plan*

COMMENT NO. 10-18

Again, the City's Department of Recreation and Parks consistently utilizes the long-range standards of 2 acres of neighborhood parks and 2 acres of community parks per 1,000 persons when analyzing projects. The long-range standard is the only standard that should be used.

Given that the Project "would generate approximately 908 new residents," to meet the City's standards, ·the project is required to provide 1.8 acres of neighborhood parks and 1.8 acres of community parks' in order to provide sufficient parkland to meet the needs of project residents. Contrary to the analysis provided in the DEIR, the "open space" provided by the project would not meet the Public Recreation Plan's definition of neighborhood park space. Neighborhood parks provide indoor and outdoor recreational space, and include features such as recreation buildings, sports fields, picnic areas, playgrounds, and game courts. The project is not proposing to provide any such improvements.

As stated in Response No. 10-14, the PRP sets forth the desired long-range standards of two acres per 1,000 persons for neighborhood parks and two acres per 1,000 persons for community parks. However, the PRP states that these long-range standards may not be reached during “the life of the plan”, and therefore, includes more attainable short and intermediate-range standards of one acre per 1,000 persons for neighborhood parks and one acre per 1,000 persons for community parks. Therefore, Section IV.H.4, Parks and Recreation, provides an analysis of the project’s consistency with

RESPONSE NO. 10-18

both

The PRP defines a neighborhood park as one that provides “space and facilities for outdoor and indoor activities” and is intended to “serve residents of ages in its immediate neighborhood”. The project would include 59,000 square feet (approximately 1.35 acres) of common open space that include space and facilities for outdoor and indoor activities and would serve Project residents. Thus, the project’s open space would be considered as “neighborhood parks”, and as such would meet the short-range standard for neighborhood parks. However, the project would fall short of the long-range standard for neighborhood parks. Additionally, the project would not meet the PRP’s long range standard or short and intermediate range standards for community parks.

the long-range and short/intermediate range standards. As noted by the commenter and indicated in the Draft EIR, the project would generate approximately 908 new residents. Thus, in order to meet the PRP’s long-range standard for neighborhood parks and community parks, the project would be required to provide 1.8 acres of neighborhood parks and 1.8 acres of community parks.




It should also be noted that the PRP standards are Citywide standards and not requirements for specific development projects, such as the proposed project. Rather specific, residential development projects are subject to Section 12.21 and Section 17.12 of the LAMC.

As stated in Response No. 10-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. Alternative 6 would reduce the project’s proposed residential uses from 400 units to 200 units. With the reduction in residential units, Alternative 6 would result in approximately 454 residents. Thus, in order to meet the PRP’s long-range standard for neighborhood parks and community parks, the project would be required to provide 0.9 acres of neighborhood parks and 0.9 acres of community parks. Alternative 6 would provide 68,200 square feet of open space (representing approximately 33 percent of the site area) consisting of 59,650 square feet of common open space (courtyards, gardens, and recreation area) and 8,550 square feet of private open space (consisting of balconies). Thus, with the 59,650 square feet (1.34 acre) of common open space, this Alternative would meet the long-range standards (as well as the short/intermediate range standards) for neighborhood parks. However, this Alternative would not provide community parks and thus, would not meet the long range standard or short and intermediate range standards for community parks.

*Page IV.H-60 - Los Angeles Municipal Code*

COMMENT NO. 10-19

Again, LAMC section 12.21 has nothing to do with Parks and Recreation and does not belong in this section.

The DEIR discusses the parkland dedication requirements of LAMC section 17.12. Unless the Project proposes to dedicate land for parks and recreational purposes the Project's "open space" areas cannot be credited against the dedication requirements of LAMC 17.12. In fact, LAMC 17.12 provides credits for low-intensity and high-intensity recreational elements based on the square feet of said recreational elements that the project provides.

As stated in Response No. 10-15, Section 12.21 of the LAMC requires that all residential developments containing six or more dwelling units on a lot provide, at a minimum, usable open space area based on dwelling units to be developed. As defined, by the LAMC, usable open space is defined as areas which are intended and designed to be used for active or passive recreation. Therefore, the discussion of Section 12.21 is appropriate in Section IV.H, Parks and Recreation, of the Draft EIR.

RESPONSE NO. 10-19




As analyzed on pages IV.H-60 through IV.H-61 of the Draft EIR, per Section 17.12 of the LAMC, the project would be required to dedicate 65,236 square feet (1.50 acres) of land. As discussed above, the project would provide 59,000 square feet (1.35 acres) of common open space that would include two public courtyards and a pocket park. These areas would serve as open space and recreational space for project residents, employees, and visitors. However, this land would not be dedicated as required to satisfy Section 17.12 requirements but rather would be owned and maintained by the Project Applicant.

Section 17.12 states that:

“where private facilities for park and recreational purposes are provided in a proposed subdivision and such facilities are to be privately owned and maintained by the future residents of the subdivision, the areas occupied by such facilities shall be credited against the requirement of dedication of land for park and recreational purposes of the payment of fees in lieu thereof, provided the Advisory Agency finds it is in the public interest to do so and that the following standards are met: (1) that each facility is available for use by all the residents of the subdivision and (2) that the area and the facilities satisfy the recreation and park needs of the subdivision so as to reduce the need for public recreation and park facilities to serve the subdivision residents”.

Credits may be given for high intensity development recreational areas (swimming pools and spas; tennis, paddle tennis, shuffle board, and volleyball and basketball courts; and children’s play areas) or low intensity development recreational areas (putting green, landscaped open area as may be determined by the Advisory Agency; athletic fields such as baseball and soccer fields, equestrian areas and picnic grounds).

Thus, the project’s 59,000 square feet of common open space (which include swimming pools and landscaped open areas) could be credited against the total parkland dedication requirement or the total in-lieu park fee requirement, as determined by the Department of Recreation and Parks (DRP).

As stated in Response No. 10-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. Alternative 6 would provide 68,200 square feet of open space consisting of 59,650 square feet of common open space (consisting of courtyards, gardens, and recreation area) and 8,550 square feet of private open space (consisting of balconies). The 59,650 square feet (1.34 acre) of common open space provided by this Alternative could be credited against the total parkland dedication requirement or the total in-lieu park fee requirement, as determined by the DRP.




*Page IV.H-62 - Mitigation Measures*

COMMENT NO. 10-20

Mitigation Measure H-6 is wholly inadequate to property mitigate the project's impact of park and recreation services.

Again, the City's Public Recreation Plan identifies the standards to which the project should be analyzed in order to determine if there is a significant impact of parks and recreation services. To repeat, in order to fully mitigate the impacts of the project and meet the needs of the new residents as determined by the standards of the City's Public Recreation Plan, the Project needs to provide sufficient parkland to provide 2 acres of neighborhood parks and 2 acres of community parks per 1,000 persons when analyzing projects. So, given that the Project "Would generate approximately 908 new residents," to meet the City's standards, the project is required to provide 1.8 acres of neighborhood parks and 1.8 acres of community parks.

Satisfaction of LAMC section 17.12, and/or the State Quimby Act, in and of itself does not mitigate the impact of the Project as determined by the City of Los Angeles CEQA Thresholds Guide.

Mitigation Measure H-6 should be rewritten to read as follows: *The Project Applicant shall provide 1.8 acres of neighborhood parks and 1.8 acres of community parks either on site or within a reasonable distance from the Project. The Project Applicant may, at the election of the City, dedicate 1.50 acres of this land in order to satisfy the requirements of LAMC section 17.12. *

As stated in Response No. 10-14, the PRP sets forth the desired long-range standards of two acres per 1,000 persons for neighborhood parks and two acres per 1,000 persons for community parks. However, the PRP states that these long-range standards may not be reached during “the life of the plan”, and therefore, includes more attainable short and intermediate-range standards of one acre per 1,000 persons for neighborhood parks and one acre per 1,000 persons for community parks. As noted by the commenter and indicated in the Draft EIR, the project would generate approximately 908 new residents. Thus, in order to meet the PRP’s long-range standard for neighborhood parks and community parks, the project would be required to provide 1.8 acres of neighborhood parks and 1.8 acres of community parks. As indicated above in Response No. 10-14, the project would exceed the PRP’s short and intermediate-range standards for neighborhood parks. However, the project would fall short of the long-range standard for neighborhood parks. Additionally, the project would not meet the PRP’s long range standard or short and intermediate range standards for community parks.

RESPONSE NO. 10-20




As stated in Response No. 10-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6 described in Section V, Alternatives, of the Draft EIR. Alternative 6 would reduce the project’s proposed residential uses from 400 units to 200 units. With the reduction in residential units, Alternative 6 would result in approximately 454 residents. Alternative 6 would provide 68,200 square feet of open space consisting of 59,650 square feet of common open space (consisting of courtyards, gardens, and recreation area) and 8,550 square feet of private open space (consisting of balconies). Thus, with the 59,650 square feet (1.34 acre) of common open space, this Alternative would meet the long-range standards (as well as the short/intermediate range standards) for neighborhood parks. However, this Alternative would not provide community parks and thus, would not meet the long range standard or short and intermediate range standards for community parks.

As provided on page IV.H-55 of the Draft EIR, based on the City of L.A. CEQA Thresholds Guide (2006), the determination of significance for impacts to parks and recreation is made on a case-by-case basis, considering the following factors:

• The net population increase resulting from the proposed project.

• The demand for recreation and park services anticipated at the time of project build-out compared to the expected level of service available. Consider, as applicable, scheduled improvements to recreation and park services (renovation, expansion, or addition) and the project’s proportional contribution to the demand.

• Whether the project includes features that would reduce the demand for recreation and park services (e.g., on-site recreation facilities, land dedication or direct financial support to the Department of Recreation and Parks).

The analysis provided in Section IV.H.4, Parks and Recreation, of the Draft EIR does consider all three factors in determining significance of impacts to parks and recreation. Section 17.12 of the LAMC allows developers to satisfy the parkland requirements set forth within via either the dedication of parkland, the payment of fees, or a combination of both. Thus, Mitigation Measure H-6 on page IV.H-62 of the Draft EIR which would require that the project Applicant develop recreational and park amenities, pay in-lieu fees, or provide a combination of such that the project would provide a total of 3 acres per 1,000 residents would satisfy the parkland dedication requirements of Section 17.12. Thus, with implementation of Mitigation Measure H-6, impacts on parks and recreation would be mitigated to less than significant.




Doug Haines P.O. Box 93596 Los Angeles, CA 90093-0596

LETTER NO. 11

I.

COMMENT NO. 11-1

Please note the following comments on the Draft Environmental Impact Report ("DEIR") for the proposed Columbia Square mixed-use project. If developed as described in the DEIR, the project would consist of a 40-story, 512-foot-tall skyscraper of 400 residential units and a 125-room hotel, plus approximately 421,000 square feet of office/retail use in a separate 260-foot tall tower and in existing, historic structures. Parking would consist of 2,004 spaces on 9-levels. Total floor area would exceed 1.1 million square feet on a 4.68-acre site (hereinafter the "Project").

INTRODUCTION

This comment reiterates the components of the proposed Columbia Square Project as described in the Draft EIR.

RESPONSE NO. 11-1

In response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. Alternative 6 would result in a reduction in overall development within the site when compared with the project. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 41,300 square feet of retail, bar and restaurant floor area. Studio B/C (4th

As compared to the proposed project, Alternative 6 would reduce the height of the residential tower from 40 stories to 28 stories and approximately 315 feet from the street to the top of the highest habitable floor and approximately 335 feet to the top of the

Wing) would also be removed and approximately 105,510 square feet of the existing 136,233 square foot CBS Complex located along Sunset Boulevard would be retained and renovated to meet the Secretary of Interior Standards for office, retail and potential studio uses. Under this Alternative, at least 1,770 parking spaces would be provided within a parking structure comprised of up to nine levels. Up to the three lower levels would be subterranean while the remaining upper levels would form the podium upon which the residential tower and town homes would be located (the podium level would thus comprise the seventh floor).




architectural features (as compared to 487 feet with the project). The office tower, which would be located in the southeast portion of the project site fronting Gower Street, would be 17 stories with a height of approximately 246 feet from the street to the top of the highest habitable floor and approximately 260 feet to the top of the architectural features (the same height as the project).3

The existing zoning is [Q]C4-1VL-SN, with the permanent "Q" restriction prohibiting residential uses not otherwise allowed in an industrial zone. The 1VL restriction limits buildings to a height of 45 feet.

COMMENT NO. 11-2

This comment reiterates the project site’s existing zoning and zoning limitations, which are discussed in Section II, Project Description, of the Draft EIR.

RESPONSE NO. 11-2

The Project as proposed is astonishingly oversized, ill conceived, and inconsistent with both the General Plan and proper land use and planning. Specifically, the Project will set a precedent for vastly exceeding the height limitations of the area's zoning that will induce other property owners to seek the same exemption. As a result, the skyline of this historic Hollywood commercial and residential district would permanently change as others seek to build above proper height limitations with excessive density.

COMMENT NO. 11-3

As analyzed in Section IV.F, Land Use, the project would require a General Plan Amendment to change the land use designation for the project site from “Commercial Manufacturing” Industrial to the “Regional Center” Commercial land use designation. In addition, the project would require a vesting zone change from [Q]C4-1VL-SN to C4-2-SN.

RESPONSE NO. 11-3

As discussed in Response No. 11-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. As compared to the

3 It should be noted that the height of the office tower for Alternative 6 has been increased from 253 feet (17 stories) as described in Section V.F, Alternative, Draft EIR. This change is noted in Section II, Corrections and Additions, of this Final EIR.




proposed project, Alternative 6 would reduce the height of the residential tower from 40 stories to 28 stories and approximately 315 feet from the street to the top of the highest habitable floor and approximately 335 feet to the top of the architectural features (as compared to 487 feet with the project). The office tower, which would be located in the southeast portion of the project site fronting Gower Street, would be 17 stories with a height of approximately 246 feet from the street to the top of the highest habitable floor and approximately 260 feet to the top of the architectural features (same as the project).

The commenter’s statement that the project will set a precedent for exceeding height limitations is noted. It should be noted that a number of projects with zone and height district changes have already been approved in the project area. Related Project No. 36, as identified in Section III, Environmental Setting, of the Draft EIR was approved with a zone change to develop a hotel up to approximately 141 feet. In addition, Related Project No. 46 was approved to change the previous zoning of the project site to develop a mixed-use building up to 260 feet.

The quality of life for existing residents would therefore dramatically deteriorate due to impacts on traffic, schools, safety, historic scenic views and other public services and infrastructure.

COMMENT NO. 11-4

The Draft EIR analyzes the project’s impacts relative to traffic in Section IV.I, Transportation and Circulation. As analyzed therein, the project would result in significant and unavoidable impacts to a total of seven intersections.

RESPONSE NO. 11-4

As analyzed in Section IV.H.3, Schools, the project’s impacts would be less than significant with implementation of Mitigation Measure H-5 which ensures that the project Applicant will pay SB 50 developer fees.

The project’s potential impacts relative to personal safety are addressed in Section IV.H.2, Police Protection. As analyzed therein, the project would include security features to ensure the safety of project residents, employees, and visitors. The project’s impacts relative to police protection would be less than significant.

The project’s impacts on historic scenic views are addressed in Section IV.A, Aesthetics. As indicated therein, the loss of views from the Selma-La Baig Historic District would be considered a significant impact. As feasible mitigation measures are not available to reduce or eliminate such impacts, view impacts would be significant and unavoidable.




With regard to public services and infrastructure, Section IV.H, Public Services, of the Draft EIR and Section IV.J, Utilities and Service Systems, the project would not result in significant impacts to public services (including police, fire protection, parks, schools, and libraries) or utilities (including water, wastewater, solid waste).

The Project's DEIR characterizes many environmental effects that will be caused by the Project as "less than significant," such that few or no serious mitigation measures are allegedly necessary. Many such determinations in the DEIR are unsupported by facts, or premised on inadequate facts, or utterly lacking of any true analysis of the facts, or consisting of a superficial "analysis" which for the most part simply assumes its conclusion.

COMMENT NO. 11-5

The Draft EIR was prepared in accordance with the State CEQA Guidelines as well as the significance thresholds and methodologies set forth within the City of L.A. CEQA Thresholds Guide (2006).

RESPONSE NO. 11-5

Per Section 15126.4 of the State CEQA Guidelines, mitigation measures are not required for effects which are not found to be significant. For environmental issue areas where potentially significant impacts have been identified, the Draft EIR provides mitigation measures, where such measures are feasible.

CEQA Guidelines Section 15064 states:

“the decision as to whether a project may have one or more significant effects shall be based on substantial evidence in the record of the lead agency”. Per Section 15384 of the State CEQA Guidelines CEQA, substantial evidence is defined as "enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached. Whether a fair argument can be made . . . is to be determined by examining the whole record before the lead agency. Argument, speculation, unsubstantiated opinion or narrative, evidence which is clearly erroneous or inaccurate . . . does not constitute substantial evidence."

The analysis in the Draft EIR is comprehensive and supported by substantial evidence and facts from various technical reports, publications, and other sources (e.g., public agencies, technical experts, models, etc) which are cited throughout the text and tables in the Draft EIR or provided as appendices to the Draft EIR.




II.

COMMENT NO. 11-6

The Project as proposed would create a myriad of significant adverse environmental impacts upon this community. It is respectfully submitted that in its current form, the Project should not be approved. Instead, the only appropriate development for the site as outlined in the DEIR is the recognized environmentally superior Alternative 4 - "Development in Accordance with Existing General Plan Designation with Height District Change."

ENVIRONMENTAL OBJECTIONS

The DEIR, however, dismisses Alternative 4 as not promoting "a balanced community meeting the needs of the residential, commercial, industrial, arts and entertainment sectors." Such analysis is specious, ignoring sound planning and the very purpose of the California Environmental Quality Act ("CEQA").

Under CEQA, unless the administrative record clearly demonstrates that it is infeasible for economic or other reasons, the lead agency is required to approve the environmentally superior alternative. Pub. Res. Code §§ 21002, 21081.

"It is the policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects." Preservation Action Council v. City of San Jose

"An agency may not approve a project that will have significant environmental impacts if there are feasible alternatives or feasible mitigation measures that would substantially lessen those effects."

(2006) 141 Cal.App.4th 1336, 1350.

Lincoln Place Tenants Ass'n v. City of Los Angeles. 155 Cal.App. 4th at 445.

As provided in Section V.D, pages V-102 through V-104, Alternative 4 would not fully meet the project’s underlying purpose of creating a fully-integrated, accessible, vertical community that enhances the city’s economic base and is connected to and respectful of the existing onsite historic structures and its surrounding neighborhoods. Other project objectives would not be achieved to the same extent as the project. Specifically, this Alternative would only partially assist in furthering the development of Hollywood as a major center of population, employment, retail services, and entertainment. Since this Alternative would not provide residential opportunities, it would not promote Hollywood as a center of population and would not fully encourage the expansion and improvement of public transportation service (Hollywood Community Plan Objective 6) to serve residential uses. This Alternative would not promote a balanced community meeting the needs of the residential, commercial, industrial, arts, and entertainment sectors; promote the development of sound residential neighborhoods; create a community-based

RESPONSE NO. 11-6




livable and walkable mixed-use development that accommodate growth; nor provide high-density housing. Furthermore, with the absence of residential development, this Alternative would achieve to a lesser extent the objective of creating a complete mixed-use environment where residents would be close to jobs, retail, and entertainment options. Thus, this Alternative would fail to meet most of the basic project objectives and as such, may be eliminated for consideration per Section 15126.6 of the State CEQA Guidelines.

The proposed Project is wildly out of scale with any reasonable development for the site, and the unmitigated impacts would dramatically and permanently affect the welfare of current and future residents of Hollywood. It is therefore difficult to respond directly to the skewed analysis in the DEIR, and I instead offer the following general comments:

COMMENT NO. 11-7

This comment is noted and will be forwarded to the decision-makers for review and consideration.

RESPONSE NO. 11-7

COMMENT NO. 11-8

On page I-49, the DEIR admits that the Historic Resources Technical Report "determined that the contemporary design of various project components and introduction of new materials contrast instead of complement the existing historic buildings." On page I-51, the DEIR notes that the "design, size, scale, and massing of proposed new development would significantly alter the historic relationships with the Columbia Square Complex and nearby historic resources."

Design/Scale of Project

Yet on page I-66, the DEIR claims: "The design of the proposed improvements would improve and enhance the visual character of the site, be aesthetically compatible with surrounding uses, and generally improve the identity of the site and the Sunset Blvd. commercial corridor. The project would incorporate design elements with an architectural theme that complements the existing character of the area."

Pages I-49 and I-51 of the Draft EIR provide a conclusion regarding the project’s impacts as it relates to design compatibility with the historic character of the surrounding area while page I-66 of the Draft EIR provides a conclusion regarding the project’s impacts as it relates to the design compatibility with the land use character of the surrounding area.

RESPONSE NO. 11-8




Thus, while the project would contrast with the historic character and existing historic buildings and would significantly alter historic relationships, the project would enhance the visual character of the project site, be aesthetically compatible with surrounding uses, and improve the existing character (land use relationships) of the area.

DEIR Figures IV.A-11 through 26 show simulated views of the Project, which illustrate surrounding streets that are largely empty of vehicles. The DEIR, however, determined that the Project would result in 9,200 daily trips with 13 of 27 studied intersections significantly impacted, and create significant, unmitigated impacts to 7 intersections and 3 of 4 analyzed neighborhood street segments.

COMMENT NO. 11-9

The simulated views of the project provided in Figures IV.A-11 through IV.A-26 are conceptual and intended to depict the project’s character. Including details such as the number of vehicles along the surrounding streets would not be relevant to the purpose of the simulated views and would not affect the analysis of aesthetics. The simulated views were all created by inserting renderings of the proposed project into actual photographs of the area; traffic appearing in the original photographs was only altered for the simulations insofar as anything obscured by the proposed buildings would no longer be visible in the simulations. The comment also reiterates the traffic impacts of the proposed project as analyzed in Section IV.I, Transportation and Circulation of the Draft EIR. As stated in Response No. 11-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6 described in Section V, Alternatives, of the Draft EIR. As provided on pages V-150 through V-156 of the Draft EIR, Alternative 6 would result in approximately 8,584 net new daily trips which would be less than the project’s 9,200 net new daily trips. With implementation of mitigation measures, this Alternative would result in significant and unavoidable impacts at the same seven intersections as the project and on the same three neighborhood street segments as the project.

RESPONSE NO. 11-9

And the parking for the office space and hotel, while meeting the requirements of the Hollywood Redevelopment Plan, is half the required spaces of the LA Municipal Code.

COMMENT NO. 11-10




As analyzed in Section IV.I, Transportation and Circulation, of the Draft EIR, based on Section 12.21.A.4 of the LAMC as well as the City’s Residential Parking Policy, the project would be required to provide a total of 1,910 parking spaces (800 for residents, 200 for residential guests, and 910 for commercial and hotel uses). It should be noted that in order to maintain a conservative analysis, all 400 residential units were assumed to be condominiums as the parking requirements for condominiums are higher than those of apartments. The project proposes to provide 800 parking spaces for residents and 1,204 parking spaces for residential guests, commercial uses, and hotel uses for a total of approximately 2,004 parking spaces. Therefore, the project’s parking supply would exceed parking requirements of the LAMC.

RESPONSE NO. 11-10

As stated in Response No. 11-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6 described in Section V, Alternatives, of the Draft EIR. Based on the LAMC, a total of 1,535 parking spaces would be required for Alternative 6, as follows:

• 200 dwelling units would require 400 parking spaces, which Alternative 6 would provide (LAMC § 12.21.A.4.(a));

• 200 residential dwelling units would require 100 guest parking spaces, which Alternative 6 would provide (City Advisory Agency Parking Policy, although the LAMC does not require any guest parking);

• 125 room hotel would require 67 parking spaces, which Alternative 6 would provide (LAMC §12.21.A.4.(b));

• 442,610 square feet of office space would require 886 parking spaces, which Alternative 6 would provide (LAMC §12.21.A.4.(c)); and

• Since the specific type of retail and restaurant/bar uses are not know, it is impossible to determine how many parking spaces 41,300 square feet of retail and resultant/bar space would require. However, Alternative 6 would provide at least 1,770 parking spaces. The residential uses, hotel and office square footage would only be required to provide 1,453 parking spaces, which would leave 317 parking spaces for the 41,300 square feet of retail and resultant/bar space, which is more than 7.5 spaces per 1,000 square feet, well in excess of the 2 per 1.000 square feet required by the Hollywood Redevelopment Plan or for Small Restaurants and Retail Stores as required by LAMC § 12.21.A.4.(c)(4) and (5).

Therefore, Alternative 6 would provide at least 1,770 parking spaces, more than what is required by either the Hollywood Redevelopment Plan or the City’s zoning




ordinance. It should be noted that the City zoning ordinance requires that projects within the Hollywood Redevelopment Plan, such as this project, must provide 2 parking spaces for every 1,000 square feet of combined gross floor area of commercial office, business, retail, restaurant, bar and related uses (LAMC § 12.21.A.4.x(3)).

Also, please consider DEIR Figure lV.A-27, which shows how the Project would put surrounding residential areas in shade for large segments of the day.

COMMENT NO. 11-11

As shown in Revised Figure IV.A-27 provided in Section II, Corrections and Additions, of this Final EIR, the maximum duration of shading on sensitive residential uses would be approximately 2 ½ hours. Thus, the project would not result in significant shading impacts during the winter solstice and would not “put surrounding residential areas in shade for large segments of the day” as the commenter states.

RESPONSE NO. 11-11

As stated in Response No. 11-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6, which is described and analyzed in Section V, Alternatives, of the Draft EIR. As compared to the proposed project, Alternative 6 would reduce the height of the residential tower from 40 stories to 28 stories and approximately 315 feet from the street to the top of the highest habitable floor and approximately 335 feet to the top of the architectural features (as compared to 487 feet with the project). The office tower, which would be located in the southeast portion of the project site fronting Gower Street, would be 17 stories with a height of approximately 246 feet from the street to the top of the highest habitable floor and approximately 260 feet to the top of the architectural features (same as the project). Revised Figures Alternative 6 – Figures 17 through 23 in Section II, Corrections and Additions, of the Final EIR depict the shadow impacts of Alternative 6. Alternative 6 would result in shading on sensitive residential uses for no more than approximately 2 ½ hours. As shown therein, Alternative 6 would not result in significant shading impacts on sensitive uses. Furthermore, with the reduction in building heights, Alternative 6 would shorten building shadows and associated shading impacts on sensitive uses.

The correct contextual simulations of the design and scale of the Project, therefore, would be of gridlocked streets, overcast neighborhoods and drivers endlessly circling for parking - not the rosy scenario illustrated in the DEIR.

COMMENT NO. 11-12




As stated in Response No. 11-9, the simulated views of the project provided in Figures IV.A-11 through IV.A-26 are conceptual and intended to depict the project’s character. Including details such as the number of vehicles along the surrounding streets would not be relevant to the purpose of the simulated views and would not affect the analysis of aesthetics.

RESPONSE NO. 11-12

Furthermore as stated in Response No. 11-10, the project’s parking supply would exceed parking requirements of the LAMC. Additionally, as stated in Response No. 11-11, the project would not result in significant shading impacts.

COMMENT NO. 11-13

As noted above, the DEIR concludes that 3 out of 4 street segments in the Selma-La Baig historic neighborhood district would be significantly impacted. In response to these traffic impacts, the DEIR recommends on page I-95: "In the event that neighbors are concerned with the potential impact of a project, they may petition LADOT for a neighborhood traffic study." In other words, the DEIR suggests that the neighbors deal with the problems created by the Project on their own accord.

Neighborhood Impacts

Under the heading of "Statement of Project Objectives," the DEIR on page II-11 claims that the proposed development will: "Provide a project which is fully integrated into the context of Hollywood in general and its surrounding neighborhoods specifically." Obviously, the DEIR skirts this issue when it involves the impacts to neighboring residences.

The DEIR also avoids neighborhood traffic impacts on page IV.F-34 when assessing the Project's conformance with the Hollywood Community Plan's requirement that "No increase in density shall be effected by zone change or subdivision unless it is determined that the local streets, major and secondary highways, freeways, and public transportation available in the area of the property involved, are adequate to serve the traffic generated." The DEIR claims that the Project is "generally consistent" with this policy by implementing "a transportation demand management program to reduce traffic impacts to the maximum extent feasible..."

The Project will create 9,200 additional daily trips, significantly impact 13 intersections, of which 7 cannot be mitigated, and impact 3 of 4 studied neighborhood street segments. The Project is therefore not consistent or in any manner in conformance with the policies set forth in the Community Plan to protect existing residential areas surrounding the proposed Project.




As discussed in the Appendix I of the Traffic Study, mitigation of the neighborhood traffic intrusion impacts identified in the Draft EIR on the four street segments listed above would require development and implementation of a neighborhood traffic management plan that would identify measures to make local routes less attractive to through traffic, such as speed reduction measures, movement prohibitions, physical mitigations, and parking restrictions.

RESPONSE NO. 11-13

The City of Los Angeles has a neighborhood traffic management process in place that includes a number of specific steps. In the event that neighbors are concerned with the potential impact of the proposed project, they may petition LADOT for a neighborhood traffic study. If traffic conditions have changed and if LADOT staff believes the changes are attributable to the project, LADOT staff will work with the neighbors to identify traffic calming/traffic management improvements that would address the traffic problem. If the neighbors agree that the suggested solutions are workable, the improvements would be installed on a trial basis. Improvements that could be considered include speed reduction measures speed humps and stop signs, movement prohibitions (e.g., restricted turns), physical measures (e.g., road narrowing, curb extensions), and parking controls. Since the project applicant cannot unilaterally impose these measures, the project’s impacts on neighborhood street segments would be significant and unavoidable. The project Applicant is committed to working with LADOT and the community to create and implement an appropriate neighborhood traffic management plan, but to require such a program as a mitigation measure would be impossible, since the project Applicant would not have the authority to implement such a program.

As discussed in Response No. 11-8, of the 7 intersections that would be significantly and unavoidably impacted by the project, 5 would operate at LOS D or better (which are considered acceptable levels) after implementation of mitigation measures. With regard to the remaining 2 significant and unavoidable impacted intersections, these intersections would operate at LOS E even without implementation of the project. Furthermore, as discussed in the Draft EIR, while the project would increase density through zone change and would generate additional traffic, the project’s proximity to public transit would support regional mobility goals and local policies that encourage development near public transportation facilities. The project would also implement mitigation measures and a transportation demand management program to reduce traffic impacts to the maximum extent feasible, and thus would be generally consistent with the intent of the Community Plan policy.

As stated in Response No. 11-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6 described in Section V, Alternatives, of the Draft EIR. As provided on pages V-150 through V-156 of the




Draft EIR, Alternative 6 would result in approximately 8,584 net new daily trips which would be less than the project’s 9,200 net new daily trips. With implementation of mitigation measures, this Alternative would result in significant and unavoidable impacts at the same seven intersections as the project and on the same three neighborhood street segments as the project.

COMMENT NO. 11-14

On pages IV.H-30 to 32, the Project DEIR gives additional crime estimates for Related Projects within the Hollywood Community Police Station Serve area, yet assesses office and retail developments at a

Impacts to Police Services: Estimated Crimes

zero rate

The very purpose of an EIR is to provide public agencies and the public in general with information about the effect that a proposed project is likely to have on the environment and to "identify ways that environmental damage can be avoided or significantly reduced." (Cal. Code of Regulations, Title 14, §15002(a)(2).

of additional crime. Major retailers such as the proposed Target shopping center at 5520 Sunset Blvd. are given a zero crime rate because the DEIR claims that "no crime rate for non-residential uses is available; therefore, crimes associated with the related projects' commercial uses were not quantified." The DEIR's assessment is therefore meaningless, and a gross violation of CEQA.

Per the Courts, the EIR's "purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are made. Thus, the EIR 'protects not only the environment but also informed self-government.' [Citation.]" Citizens of Goleta Valley v. Board of Supervisors

The Project DEIR must properly assess both the estimated crime impacts for the entire proposed development and cumulative impacts - per the requirements of CEQA.

(1990) 52 Cal.3d 553,564

Section IV.H.2, Police Protection, of the Draft EIR does not assess the proposed office and retail developments at “a zero rate of additional crime”. As indicated on page IV.H-27, the Draft EIR acknowledges that the project’s commercial uses would generate a non-residential population of 1,831 persons, which would also potentially generate crimes. As presented in Table IV.H-4 on page IV.H-24 of the Draft EIR, the Hollywood Community Police Station served a population of 230,383 residents and had 7,601 crimes reported in 2007. The reported crimes represent crimes involving both residential properties and commercial properties. The Los Angeles Police Department (LAPD) does not provide data regarding the commercial properties that they serve. As such, the LAPD does not provide a separate crime rate for residential and commercial properties. Without a separate crime

RESPONSE NO. 11-14




rate, it would be highly speculative for the Draft EIR to provide an estimate of crimes for non-residential uses.

Additionally, it should be noted that the City of L.A. CEQA Thresholds Guide does not require an estimation of crimes that could be generated by a project. Rather, the City of L.A. CEQA Thresholds Guide states that the methodology to determine significance with regard to a project’s impacts on police protection should:

“Consider the description and location of the project. Determine the net population increase resulting from the project.

Based on consultation with LAPD, evaluate the demand for police services anticipated at the time of project buildout compared to the expected level of service available. Consider as applicable schedule improvements (facilities, equipment, and officers) and the project’s proportional contribution to the demand;

Evaluate project security features which would reduce the expected demand for police service.”

The City of L.A. CEQA Thresholds Guide provides a similar methodology for cumulative impacts, with consideration to related projects that would be served by the same LAPD facilities as the proposed project. The analysis in the Draft EIR follows the methodology outlined and thus, properly assesses the project’s impacts on police protection. It should also be noted that based on consultation with the LAPD, as indicated on page IV.H-29, the design and character of the project as well as the proposed security features would serve to mitigate the potential significant impacts on LAPD services.

As indicated in Response No. 11-1, in response to public input and community outreach, the project Applicant has announced its preference for Alternative 6 described in Section V, Alternatives, of the Draft EIR. Alternative 6 would result in a reduction in overall development within the site when compared with the project. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 41,300 square feet of retail, bar and restaurant floor area. Similar to the project, Studio B/C (4th Wing) would be removed and approximately 105,510 square feet of the existing 136,233 square foot Columbia Square Complex located along Sunset Boulevard would be retained and renovated to meet the Secretary of Interior Standards for office, retail and studio uses. As analyzed on page V-147 of the Draft EIR, with the reduction in residential uses on the project site, overall calls for police services are anticipated to be less than under the project since residential uses typically have greater impact on police services




than non-residential uses. Therefore, impacts on policies protection services would be less than the project and less than significant.

III

COMMENT NO. 11-15

CONCLUSIONAttached at Exhibit 1 please note additional comments regarding the proposed Project from the May 2, 2008 LA Weekly article "Doomscraper?"

.

The attachment provided by the commenter does not provide any new environmental information. The comments provided in the attachment are noted for the administrative record and will be forwarded to the decision-makers for review and consideration.

RESPONSE NO. 11-15

I ask that the City recognize the negative impacts associated with this and similar projects inconsistent with our community's land use and planning, and vote to not certify or recommend for certification the DEIR for the Project.

COMMENT NO. 11-16


RESPONSE NO. 11-16

Please note that I retain the right to submit additional comments regarding the Project at a future date.

COMMENT NO. 11-17

Thank you for your courtesy and attention to this matter.

This comment is noted for the administrative record and will be forwarded to the decision-makers for review and consideration. The commenter will be included on the mailing list for future public notices relating to the project.

RESPONSE NO. 11-17




Kelly Chu-Keenan

LETTER NO. 12

[email protected]

Although I realize that this is a late response to the environmental impact report for the proposed Columbia Square project, I would like to voice my concern over the height of the proposed residential tower. I have only recently had a chance to review the EIR and while I feel that development in the neighborhood is generally a good thing, I am unhappy that my building will be affected by the long shadows cast by this 40 story behemoth. One of the main reasons I purchased my condo is because of the abundant natural light and absence of tall structures that would obstruct views of Downtown and Hollywood. I am not opposed to the tower itself, as this could become part of the view in the future, but would like to see the plans for the tower scaled down to about 20 stories or so to limit the impact of shadowing on the neighborhood. Thank you for taking this into consideration.

COMMENT NO. 12-1

The comment is noted for the administrative record and will be forwarded to the decision-makers for review and consideration.

RESPONSE NO. 12-1

In response to public input and community outreach that occurred during the preparation of the Draft EIR, the project Applicant recognized that the community is concerned about height and traffic. Accordingly, the project Applicant has announced its preference for Alternative 6, which was described and analyzed in Section V, Alternatives, of the Draft EIR. Alternative 6 would result in a reduction in overall development within the site when compared with the project. Specifically, this Alternative would reduce the project’s proposed residential uses from 400 units to 200 units and increase office uses from 380,000 to 442,610 square feet. Similar to the project, this Alternative would also result in new development of a 125-room hotel and approximately 41,300 square feet of retail, bar and restaurant floor area. Studio B/C (4th

As compared to the proposed project, Alternative 6 would reduce the height of the residential tower from 40 stories to 28 stories and approximately 315 feet from the street to the top of the highest habitable floor and approximately 335 feet to the top of the architectural features (as compared to 487 feet with the project). The office tower, which

Wing) would also be removed and approximately 105,510 square feet of the existing 136,233 square foot Columbia Square Complex located along Sunset Boulevard would be retained and renovated to meet the Secretary of Interior Standards for office, retail and potential studio uses.





would be located in the southeast portion of the project site fronting Gower Street, would be 17 stories with a height of approximately 246 feet from the street to the top of the highest habitable floor and approximately 260 feet to the top of the architectural features (the same height as the project).4

4 It should be noted that the height of the office tower for Alternative 6 has been increased from 253 feet (17 stories) as described in Section V.F, Alternative, Draft EIR. This change is noted in Section II, Corrections and Additions, of this Final EIR.

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