ARMBRUSTER GOLDSMITH & DELVAC LLPLAND USE ENTITLEMENTS □ LITIGATION □ MUNICIPAL ADVOCACY

12100 WILSHIRE BOULEVARD, SUITE 1600 LOS ANGELES, CALIFORNIA 90025TODD NELSON

DIRECT DIAL: 310-254-9058Tel: (310) 209-8800 Fax: (310) 209-8801

E-MAIL: Todd@AGD-LandUse.com WEB: www.AGD-LandUse.com

October 29, 2019

VIA E-MAIL

Chair Harris-Dawson and Honorable Members of the Planning and Land Use Management Committee

Los Angeles City Council 200 N. Spring Street, Room 395 Los Angeles, CA 90012

clerk.plumcommittee@lacity.org

CEQA Appeal for 2136-2140 Westwood Boulevard; PLUM Committee Meeting of October 29, 2019, Agenda Item No. 8;Council File No. 19-0319

Re:

Dear Honorable Members of the PLUM Committee:

Yesterday, this firm submitted a brief letter on behalf of Westwood3, LLC (the “Applicant”) in response to the above-referenced CEQA appeal. That letter attached a copy of the supplemental CEQA findings and the Applicant’s voluntarily prepared traffic study that were considered by the City Planning Commission when it denied the appellant’s prior appeal on January 24, 2019. Our letter inadvertently omitted the Department of Transportation’s letter approving that traffic study, which is attached as Exhibit A, so that it may be included in the Council File for this matter.

We again respectfully request that your committee recommend denial of this appeal, as no substantial evidence supports the appellant’s claims.

Thank you for your consideration, and please contact me with any questions.

Sincerely,

Todd Nelson

Jordann Turner, Department of City Planning Nick Hendricks, Department of City Planning Azeen Khanmalek, Council District 5

cc:

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CITY OF LOS ANGELESDa FORM GEN. 160A (Rev. 1/82)

INTER-DEPARTMENTAL CORRESPONDENCE

2138 South Westwood Boulevard DOT Case No. WLA18-107436

Date: January 18, 2019

Luciralia Ibarra, Senior City Planner Attention: Heather Bleemers, Senior City Planner Department of City Planning .

To:

Hamed SandoghdaffTransportation Engineer Department of Transportation

From:

Subject: TRAFFIC IMPACT ASSESSMENT FOR THE PROPOSED 77-UNIT APARTMENT BUILDING TO BE LOCATED AT 2138 SOUTH WESTWOOD BOULEVARD

Pursuant to the West Los Angeles Transportation Improvement and Mitigation Specific Plan Ordinance No. 171,492 (WLATIMP), the Department of Transportation (DOT) has completed its review of the traffic study analysis prepared by Overland Transportation Consultants, Inc. dated November, 2018 and subsequent revision dated January 2019, for the proposed apartment building project to be located at 2138 South Westwood Boulevard. After a review of the pertinent data, DOT has determined that the analysis conducted adequately describes the project-related impact of the proposed development.

PROJECT DESCRIPTIONThe project proposes the construction of a 6-story, 77-unit apartment building over a ground level parking lot and a 1-level subterranean parking garage. The project site is generally bounded by commercial uses to the north and to the south, by single family residential units to the east, and by Westwood Boulevard to the west. The project site is currently occupied by a 2-story commercial building and adjacent parking lot which will be demolished to accommodate the project Access to the surface parking lot will be provided via one existing shared driveway on Westwood Boulevard located at the south end of the project site. Access to the subterranean parking garage will be provided via another existing driveway along Westwood Boulevard located at the north end of the site. The project is proposing to provide 22 parking spaces in the ground level parking area and 48 parking spaces in the subterranean parking garage. The project is expected to be completed by 2021.

DISCUSSION AND FINDINGS

Trip GenerationThe project is estimated to generate a net increase of 353 daily trips, a net increase of 24 a.m. peak hour trips and, a net increase of 31 p.m. peak hour trips. The trip generation estimates are based on the trip rate requirements of the WLA TIMP, Appendix "A" and formulas published by the Institute of Transportation Engineers (ITE) Trip Generation, 10th Edition, 2017. A copy of the report trip generation table (Tables 2) can be found in Attachment "A".

Traffic ImpactTraffic impact analysis was conducted at six (6) signalized study intersections surrounding the proposed project site. Based on DOT'S traffic impact criteria1, the proposed development would not create a

1 Per the DOT Traffic Study Policies and Procedures, a significant impact is identified as an increase in the Critical Movement Analysis (CMA) value, due to project related traffic, of 0.01 or more when the final ("with project") Level of Service (LOS) is LOS E or F; an increase of 0.020 or more when the final LOS is LOS D; or an increase of 0.040 or more when the final LOS is LOS C.

January 18, 2019Luciralia Ibarra -2-

significant impact at any of the study locations. A copy of the impact analysis summary tables (Table 6 and 9) can be found in Attachment "B".

Congestion Management Program (CMP)In accordance with the state-mandated Congestion Management Program (CMP), an increase in the freeway volume by 150 vehicles per hour during the A.M. or P.M. peak hours in any direction requires further analysis. A substantial change in freeway segments is defined as an increase or decrease of 2% in the demand capacity ratio when at LOS F. For purposes of CMP intersections, an increase of 50 vehicles or more during the A.M. or P.M. peak hour requires further analysis. The intersection of Westwood Boulevard and Santa Monica Boulevard (CMP Station No. 62 and study intersection No. 3), located approximately 0.43 miles north-west of the project site is the nearest CMP intersection. Based on the distribution of Project trips, it is anticipated that fewer than 50 project trips during the A.M. peak and the P.M. peak would likely travel through this location. Additionally, the study indicates that the maximum number of project-related trips to occur along the nearest CMP freeway segments of the I- 405 Freeway north of Venice Boulevard (CMP Station No. 1070) and 1-10 Freeway east of Overland Avenue (CMP Station No. 1011) are well below the 150 trips threshold for potential CMP Freeway Segment impact and therefore, no further analysis is needed.

Freeway Screening AnalysisTo comply with the Freeway Analysis Agreement executed between Caltrans and LADOT in October 2013, the study also included a screening analysis to determine if additional evaluation of freeway mainline and ramp segments was necessary. Exceeding one of the four screening criteria would require the applicant to work directly with Caltrans to prepare a more detailed freeway analysis. However, the project did not meet or exceed any of the four thresholds defined in the agreement; therefore, no additional freeway analysis is deemed required at this time. A copy of the project freeway screening analysis table (Table 11) is provided as Attachment "C" to this report.

PROJECT REQUIREMENTS

Covenant and AgreementPursuant to Section 4.B of the WLATIMP, the owner(s) of the property must sign and record a Covenant and Agreement prior to issuance of any building permit, acknowledging the contents and limitations of the Specific Plan is a form designed to run with the land.

A.

Highway Dedication And Street Widening RequirementsPursuant to Section 4.E.2 of the WLA TIMP, and in order to mitigate potential access and circulation impacts, the applicant may be required to make highway dedication and improvements. The applicant shall consult the Bureau of Engineering (BOE) for any highway dedication or street widening requirements. These requirements must be guaranteed before the issuance of any building permit through the B-permit process of the BOE. They must be constructed and completed prior to the issuance of any certificate of occupancy to the satisfaction of DOT and BOE.

B.

Pedestrian ConnectivityThe applicant shall consult with the City's Planning Department for any additional requirements pertaining to pedestrian walkability and connectivity, as described in the Walkability Checklist.

C.

Construction ImpactsDOT recommends that a construction work site traffic control plan be submitted to DOT for review and approval prior to the start of any construction work. The plan should show the

D.

January 18, 2019Luciralia Ibarra -3-

location of any roadway or sidewalk closures, traffic detours, haul routes, hours of operation, protective devices, warning signs and access to abutting properties. DOT also recommends that all construction related traffic be restricted to off-peak hours.

Site Access and Internal CirculationThe proposed site plan is acceptable to DOT; however, review of the study does not constitute approval of the driveway dimensions and internal circulation schemes. Those require separate review and approval and should be coordinated with DOT'S West LA/Coastal Development Review Section (7166 W Manchester Ave, @ 213-485-1062). In order to minimize potential building design changes, the applicant should contact DOT for driveway width and internal circulation requirements so that such traffic flow considerations are designed and incorporated early into the building and parking layout plans. Final DOT approval should be obtained prior to the issuance of any building permits. All new driveways should be Case 2 driveways and any security gates should be a minimum 20 feet from the property line. All truck loading and unloading should take place on site with no vehicles backing into the project via any of the project driveways.

E.

Development Review FeesAn ordinance adding Section 19.15 to the Los Angeles Municipal Code relative to application fees paid to DOT for permit issuance activities was adopted by the Los Angeles City Council in 2009 and updated in 2014. This ordinance identifies specific fees for traffic study review, condition clearance, and permit issuance. The applicant shall comply with any applicable fees per this ordinance.

F.

DOT ASSESSMENT APPEAL PROCESSPursuant to Section 8.A of the WLAT TIMP, an applicant or any other interested person adversely affected by the proposed project who disputes any determination made by DOT pursuant to this Ordinance may appeal to the General Manager of DOT. This appeal must be filed within a 15 day period following the applicant's receipt date of this letter of determination. The appeal shall set forth specifically the basis of the appeal and the reasons why the determination should be reversed or modified.

if you have any questions, please contact me or Pedro Ayala of my staff, at (213) 485-1062.

HS:pa

Attachments

Faisal Alserri, Jay Greenstein, Council District No. 5 Sean Haeri, Mo Blorfroshan, Rudy Guevara, DOT Kevin Azarmahan, BOEJerry Overland, Overland Traffic Consultants, Inc.

c:

Attachment "A it2138 S. Westwood Blvd.: 77-Unit Apartment (WLA18-107436)

V Overland Traffic Consultants, Inc.

PROJECT TRAFFICCHAPTER 4

Project Traffic GenerationTraffic - generating characteristics of land uses have been studied by the Institute of Transportation Engineers (ITE). The results of the traffic generation studies have been published in Trip Generation. 10th Edition Handbook. This publication of traffic generation data has become the industry standard for estimating traffic generation for different land uses. In addition, LADOT has adopted traffic rates for affordable apartments and the West La Transportation Corridor Specific Plan provides afternoon peak hour traffic rates to be used when preparing traffic impact studies in the TIMP area. These trip rate for residential uses are shown below in Table 1.

Table 1Project Trip Generation Rates

(ITE 10th Edition, LADOT & Coastal Specific Plan)

PM Peak HourDaily T raffic

AM Peak HourITEOut Total In Out TotalInDescriptionCode

61% 39% 0.4926% 74% 0.36Apartments (per unit)

Affordable Apartments (per unit)

5.44221

55% 45% 0.344.08 40% 60% 0.50LADOT

Note: PM Trip rates per West LA TIMP Specific Plan, Appendix A, and affordable rates per LADOT Transportation Impact Study guidelines, December 2016, Table 5 page 14.

Table 2 contains the project trip generation estimates using the Table 1 trip rates.Table 2

Estimated Project Traffic Generation

PM Peak HourDailyTraffic

AM Peak HourITEIn Out TotalSize In Out TotalDescriptionCode

Proposed Project Apartments (per unit) 21 13 34

(3) (2) (5)70 units

15%381 6 19 25221

Transit *Affordable Apartments (per unit)

Total Proposed without transit

Total Proposed with transit

(57) (1) (3) (4)7 units 2 3 1 1 229 1LADOT

22 14 36410 7 21 28

18 24 19 12 31353 6

* Rapid BBB 12 Transit along Westwood Boulevard with stops at Olympic Boulevard and Westwood Boulevard.

January 2019Project Traffic

Page 242138 - 50 Westwood BoulevardTraffic Impact Study

Attachment "B" (1 of 2)2138 S. Westwood Blvd.: 77-Unit Apartment (WLA18-107436

Overland Traffic Consultants, Inc.

Table 5City of Los Angeles Significant Traffic Impact Criteria

Increase in V/C Value equal to or greater than 0.040 equal to or greater than 0.020

equal to or greater than 0.010

LOS Final V/C ValueC 0.701 - 0.800

0.801 - 0.900 > 0.900

DE and F

By applying the CMA procedures, the V/C ratios and the corresponding LOS for

“existing + project” traffic conditions were determined for each intersection. The V/C

intersection ratios and the corresponding LOS values for the “Existing + Project Traffic

Impact Analysis” are summarized in Table 6 which indicates no significant project traffic

impacts.

Table 6Existing + Project Traffic Conditions

Existing + ProjectPeak

HourExisting

CMA LOS________SignificantImpact ImpactNo. Intersection CMA LOS

NO1 Westwood Boulevard and

Olympic Boulevard

AM 0.971 E 0.9730.974

E + 0.002

+ 0.003 NOPM 0.971 E E

2 Westwood Boulevard and

La Grange Avenue

AM 0.363

0.540

A 0.365 A + 0.002 NOPM NOA 0.541 A + 0.001

NO3 Westwood Boulevard and AM 0.963 E 0.963 E + 0.000

+ 0.000Santa Monica Boulevard PM 0.867 D 0.867 D NO

Olympic Boulevard and Overland Avenue

AM 0.834 D + 0.001 NO4 0.835 DPM NO0.852 D 0.852 D + 0.000

NOOlympic Boulevard and Veteran Avenue

AM 0.573 A 0.573 A + 0.0005PM 0.623 B 0.624 NOB + 0.001

Pico Boulevard and AM 0.549 NO6 A 0.551 A + 0.002PM NOWestwood Boulevard 0.673 B 0.675 B + 0.002

Existing + project peak hour traffic volumes at the study intersections are illustrated in

Figure 10 for the morning peak hour and Figure 11 for the afternoon peak hour.

2138 - 50 Westwood BoulevardTraffic Impact Study

Page 35 January 2019Traffic Conditions Analysis

2138 S. Westwood Blvd.: 77-Unit Apartment (WLA18-107436 Attachment "B" (2 of 2)

Overland Traffic Consultants, Inc.

The results of the future LOS and project traffic impact analysis is provided in Table 9.

Table 9Future Cumulative Traffic Conditions With Project

Future (2021) Without Project

Future (2021) With Project_______ Significant

Impact ImpactPeakHour CMA LOS CMA LOSNo. Intersection

NOWestwood Boulevard and

Olympic Boulevard

AM 1.149 F 1.152 F + 0.0031

NOPM 1.072 F 1.075 F + 0.003

NO0.397 A + 0.0022 Westwood Boulevard and

La Grange Avenue

AM 0.395 ANOPM 0.575 A 0.576 A + 0.001

NO3 Westwood Boulevard and Santa Monica Boulevard

AM 1.096

0.970

F 1.097 F + 0.001NOPM E 0.971 E + 0.001

NO4 Olympic Boulevard and

Overland Avenue

AM 1.028 F 1.028 F + 0.000

NOPM 0.922 E 0.922 E + 0.000

NOOlympic Boulevard and

Veteran Avenue

AM 0.6290.685

B 0.629

0.686

B + 0.000

+ 0.001

5NOPM B B

NOC 0.714 C + 0.0026 Pico Boulevard and AM 0.712

C NOWestwood Boulevard PM 0.748 0.749 C + 0.001

As shown in Table 9, none of the study intersections are impacted by project traffic volume

using the significant impact criteria established by LADOT.

Future cumulative “with project” peak hour traffic volumes are shown in Figures 15 and 16

for the morning and afternoon, respectively. Appendix H contains the level of service

worksheets.

2138-50 Westwood BoulevardTraffic Impact Study

Page 46 January 2019Traffic Conditions Analysis

Attachment "C it2138 S. Westwood Blvd.: 77-Unit Apartment (WLA18-107436)

V Overland Traffic Consultants, Inc.

Table 11Caltrans Screening

% INCREASE# of Lanes

Project TripsLOCATION Capacity AM PMDIR AM PM

FREEWAY SEGMENT <2.000 vehicles per hour per lane)

Santa Monica Fwy (1-10) west of Centinela Avenue 0.0% 0.0%EB 4 8,0008,00010,0008,00013,60013.60011.600 11,600

0 11 0.0% 0.0%WB 4 1

Santa Monica Fwy (1-10) east of Overland Avenue 2 0.0% 0.0%EB 5 30.0%3 0.0%WB 4 1

San Diego Fwy (I-405) north of Olympic Blvd 6+HOV6+HOV5+HOV5+HOV

1 0.0% 0.0%NB 22 0.0% 0.0%SB 1

San Diego Fwy (I-405) south of National Blvd 1 2 0.0% 0.0%0.0%

NBSB 3 2 0.0%

OFF RAMP SEGMENT f850 vehicles per hour per lane)Santa Monica Freeway eastbound bound off ramp at Centinela Av 1 0.0% 0.0%EB 3 2,550 0

Santa Monica Freeway westbound bound off ramp at Overland Av 2,550 1 3 0.0% 0.1%WB 3

San Diego Freeway southbound off ramp at Sawtelle Bd SB 2 0.0% 0.1%3 2,550 1

San Diego Freeway northbound off ramp at National Bd 0.1% 0.1%NB 2 1,700 1 2

DIR = Direction

Construction OverviewAs part of the project’s construction, a Construction Traffic Management program would be implemented during the construction phase to minimize potential conflicts associated with construction activity. The project’s potential construction impacts may involve temporary construction activities within a roadway that would cause lane or street closures and a temporary loss of on-street parking.

The project applicant would be required to submit formal Work Area Traffic Control Plans for review and approval by the City prior to the issuance of any construction permits. These construction staging and traffic control plans will be reviewed and approved by the City to provide safe operations during these temporary intermittent lane closures, as well as to provide safety measures around the construction site to reduce the risk to pedestrian traffic.

Construction workers are typically expected to arrive at the project site before 7:00 am and depart before or after the weekday peak hours of 4:00 to 6:00 pm. It is also assumed

January 2019Traffic Conditions Analysis

2138 - 50 Westwood BoulevardTraffic Impact Study

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