March 14, 2024
Mr. Ray Fukuda
LA City Planning Associate
Department of City Planning
221 N. Figueroa Street, Room 1350Los Angeles, CA 90012
VIA EMAIL: ray.fukuda@lacity.org
RE: ENV-2023-1819-EIR, FOX FUTURE Project
10201-10275 West Pico Boulevard, Los Angeles, CA 90064
Dear Mr. Fukuda:
This letter is submitted on behalf of the board and stakeholders of Westwood South of Santa Monica
Blvd. Homeowners Association (WSSM) in response to the Notice of Preparation of Draft Environmental Impact Report issued February 14, 2024. Our WSSM community represents over 3800 single family and condominium homeowners in the area bounded by Santa Monica and Pico Boulevards on the north and south, and by Beverly Glen and Sepulveda Boulevards on the east and west. We are due west of the Century Glen HOA which lies closest to the Fox Studio property. As you might imagine, many of our constituents travel along the Pico and Olympic corridors regularly and depend upon these major arterials for their east/west travel. Many of our residents work in Century City. They and we realize that the safety of our streets has a direct relationship to nearby Century City, a major Los Angeles employment hub. As our streets lie in a grid format, they carry Century City cut-through traffic daily as commuters seek to avoid congestion on the major arterials to access their final destinations along with the 10 and 405 freeways.
I am pleased to note that a number of our members attended the February 28 scoping meeting and have reviewed the Notice of Preparation. Our Board was invited to a WSSM presentation by Fox staff on their proposed project. There is much to consider with a project of this magnitude and we trust that our concerns and those of our neighboring associations will be seriously explored in the project DEIR. This project will add to the traffic in the area by creating new sources of trips and peak hour trips at a location already bottlenecked with traffic. While we expect that some Century City commuters will utilize the subway when it arrives to Avenue of the Stars and Constellation Blvd, we also know that those studio employees with irregular/late work hours and those in higher income positions are not likely to utilize public transit and will utilize local streets as they seek to access the Santa Monica Freeway, San Diego Freeway or merely get across town – in all directions. Our questions and concerns involve far more than issues related to traffic and roadway safety. We would like those concerns to be fully addressed in the future EIR documents for this project.
Century City South Specific Plan
Many of our residents remember the 1993 process and hearings that resulted in the current land use plan and expanded studio and ancillary uses for this very property. That was at a time when the studio was threatening to leave the City for another location. Significant concessions were made to alter the CCSSP at that time. The expectation in the community was that the conditions established in that plan would remain in place. Yet, we see in the proposed Fox Forward plan that significant changes are being sought.
We would appreciate a point by point discussion of the changes proposed to the Century City South Specific Plan (CCSSP) and the impacts that these changes will bring, in addition to an analysis of and the charting of just those project pieces that are possible without changes to the Specific Plan. On page 46 of the IS, Figure 14 shows all of the Proposed CCSSP Allowable Building Heights but FAILS to compare them to the ACTUAL ALLOWABLE building heights now required. This is an important error of omission and the DEIR should be clear in its description of all changes and their potential impacts and benefits that it will bring to the project applicant. It is important to summarize all of the benefits the proposed project would enjoy should the CCSSP be changed to benefit this project as they will be important in future discussions around the concept of community benefits (although some/many changes cannot be offset by any community benefits). On page 47, again, the proposed setbacks are given but they are not compared to existing requirements. This makes it difficult for the public to easily “see” or understand the nature of the actual proposed changes. A change to the General Plan and to a community plan for a specific project at the request of a developer/property owner appears to be akin to spot zoning, is it not? Is it proper to generate a General Plan change as a result of a project application?
The potentially significant environmental impact due to the project’s many conflicts with the existing land use plan policies and documents must be thoroughly disclosed, discussed and evaluated in the DEIR. As proposed the project is not consistent with the General Plan, WLA Community Plan, CCSSP and its Q Conditions. It seeks additional permits and agreements (alcoholic beverages, Development Agreement, Parcel Map, haul route approval and many additional discretionary and ministerial permits in order to implement the Project. We will look forward to a complete analysis of these conflicts and impacts.
The proposed office buildings and needed land use designation changes must be fully explored as the height limits currently attached to the properties in question would not allow such structures to be built. Their impacts on all facets of the environment must be analyzed. Given the past history of divestiture of the Fox Plaza office building, is there a policy matter that can be crafted that would require any office structures built be specifically limited to studio uses? It appears that the buildings are being proposed to allow Fox to be either an office landlord or a developer of office buildings to be sold at a later date. The CCSNP was crafted to favor studio/industrial uses and not office uses in either of the two locations identified for office structures. What impact will those offices have on current Century City and Westside office buildings? What role does an EIR document have in exploring the appropriateness of constructing office buildings on what is meant to be studio/manufacturing land? While we know that offices in Century City are among THE most desirable office in the City (and commanding among the higher office rents in the City), that should not serve as the rationale for changing established zoning – to generate profit for a landholder?
We would like additional attention paid to the retention of the Zanuck Theatre which, to our eyes, should be considered to be a “Preserved Building” or one worthy of preservation. Why would it not be preserved? We are much relieved to learn that the Commissary is to be retained and trust that no project alternative will consider its demolition. The protection of the sites noted in the Historic District should be respected in all project alternatives presented. Minimizing impacts on the Historic District and reusing Project contributing historic features should be a guiding principle for the project and any identified alternatives. The public should have full access to any updating of the HPP and the opportunity to give input into the preparation of that process/re-evaluation. The DEIR should show what buildings proposed to be demolished led to the “potentially significant impact” noted on page 85, Cultural Resources V. How can project alternatives increase the number of historical resources saved/retained on the lot?
Additional Development Standards 3.3.6.1.4
The Olympic Corridor between Century Park West and just east of Avenue of the Stars is currently an urban oasis with trees lining the street and little commercial intrusion. Any construction on the lot on Olympic will have a very significant impact on the aesthetics of that streetscape. The DEIR must look at the appropriateness of placing any billboard structures on Olympic Blvd. which has residential structures directly across the Boulevard. The proposed loss of large mature trees is already a major proposed degradation of the street to be replaced with proposed parking and an office structure. Any proposed entry to the studio on Olympic, if approved, should be respectful of the residential nature of the street in that area. Evaluation of billboard blight should be included in the assessment of project aesthetics and lighting impacts. It would be inappropriate to consider the placement of any billboards on Avenue of the Stars which, as noted on page 68 of the IS, is a designated scenic highway/roadway. Such roadways are protected under the Mobility Element of the General Plan. The replacement of lost trees at higher ratios than 2:1 should be part of project review/mitigation measures to offset the loss particularly of trees greater than 4” in diameter.
How much of the lot is currently considered to be unpaved open space? What will that number be after the proposed project is built out? What plans does the project have to capture rainwater from structures and /or the ground for percolation into the water table?
Sustainability 3.3.13
The IS (page 64) lists a number of sustainability measures that “may be incorporated” into the project. How will the DEIR evaluate these and determine which are most appropriate and which additional measures should be incorporated? Will there be sustainability goals for the project to meet?
Vehicular Access 3.3.7.1.1
The project’s traffic study must model for changes in traffic patterns with the proposed opening of an Olympic Blvd. gate as well as the impacts of increased numbers of employees, guests and tenant users. The DEIR must address the saturation of the WLA area in general along with freeway and arterial capacity. While levels of service are no longer used as a measure to assess congestion, the configuration of Century City streets, all of which DEAD END at Olympic, Pico or Santa Monica Blvd. is a design unlike any other. It shifts Century City north / south traffic to nearby residential streets. Motor Avenue negotiated a cap on vehicle use some years ago in a privately negotiated agreement that harmed nearby neighborhood streets such as Overland Avenue in our community and the streets adjacent to it when vehicles fail to wait for the signal at Overland Avenue. The traffic study should look at the Motor Avenue agreement and explore ways to equally share any new traffic among all neighbors/neighborhoods. It is inherently unfair for Motor to continue to avoid absorbing any new traffic when others must not only take their own share, but also Motor Avenue’s.
The ambient growth in the DEIR must include projections for full occupancy and use of all existing and proposed structures. We would request that traffic counts, traffic distribution and other traffic-related topics be consistent with past EIRs for the area (and when not, contain an explanation as to why not).
We ask that any mitigation proposed to address project impacts be proven effective by independent analysis before it is considered for adoption in the project.
While our entire area is of concern in assessing traffic impacts, streets of heightened concern include: –Overland Avenue between Santa Monica and Pico Blvds. where Overland carries one lane of traffic in each direction. The first two blocks south of Santa Monica Blvd. are zoned for multi-family housing and the blocks between LaGrange and Pico have single family homes. Vehicles seeking to enter the 10 freeway often use Overland Avenue to access the onramp at National and the 10. Westwood Charter Elementary School is located on Overland Avenue between LaGrange and Mississippi Avenues. –Patricia Avenue between Olympic and Pico Blvds. This street carries peak hour traffic as a result of having a traffic signal at Pico Blvd. Vehicles avoiding Motor Avenue often use Patricia to head toward Cheviot Hills and the Manning 10 freeway entrance.
We would request that the project continue to be analyzed with trip caps established. (It is difficult to address the trip cap subject not knowing how the current figures relate to the current caps.) We would request that the traffic study commissioned by the applicant be reviewed by an independent traffic engineer.
Bicycle and Pedestrian Access 3.3.7.1.2
The IS notes on page 56 the plans for bicycle routes in the area. A new traffic signal that is ped/bike activated at Tennessee and Westwood is soon to be installed to assist street users (and not vehicles) to cross Westwood. There will be challenges as to where the bicycles will go once they reach Beverly Glen Blvd. The DEIR can address this challenge with alternatives for further review.
Our community supports keeping bikes off of major arterials already overburdened with capacity traffic and buses, so it is preferable to create neighborhood bike routes to provide safer passage for bike riders. We would like to see the project address the need to make connections for bike riders.
Frontages
We request precise comparisons of existing frontage requirements and proposed frontages.
Air Quality/Noise Pollution
While the City is currently in the process of attempting to halt the evaluation of construction noise impacts under CEQA, with a project that is of such long duration, it is important that construction noise impacts be considered in the DEIR to be completed, particularly given the proximity of the project to residences along Fox Hills and Orton as well as across Olympic Blvd. The long period of construction / build out envisioned speaks to a very long term set of impacts in the Century City general area. Understanding that there was oil drilling in the area in the not-too-distant past (BHHS Olympic Blvd. oil well recently dismantled) does this suggest the need to assess any related conditions or impacts?
Emergency Services
Growing response times of fire and police to our area are an issue of great concern to our community. With increased densification, increasing traffic, shortfalls of City budget dollars to support adequate staffing, etc. there should be a comprehensive analysis of increased first-responder requirements as part of the DEIR process.
Additional public services/resources
While the IS notes a number of public parks in the vicinity, accessing those recreational facilities is a challenge, particularly during evening peak travel hours when children engage in after-school sporting activities. Any additional traffic added in the vicinity of Motor/Pico intersection will make access to Rancho Park even more difficult with multiple light signals passing in order to come and go to the park. Likewise, Overland Avenue traffic that seeks access to the 10 freeway makes accessing Palms Park and the WLA Library there difficult for many hours of the afternoon and into early evening. How will this project add to those difficulties?
The Century Glen HOA raises a number of points in regard to the CCSSP. As they are the association in closest proximity to the Project, we support their concerns and the points raised. We are particularly interested in their comment related to proposed lot splitting and the impacts of such an act, development of NON-studio uses, impacts of rezoning of the C2-2-0 Specific Plan Area A parcel subject to the Q condition now within the CCSSP. One of their comment letters noted that the project is being proposed in response to the need for studio space/soundstage and production space. Yet, much of this plan is much in addition and different from these uses. What kinds of precedents will be established by the carving out of commercial zoned land from the studio lot and how/when might it continue or be stopped?
Project Description / Housing Concerns / Project Alternatives
In the Initial Study’s Overview of Existing Conditions (3.2.2, page 20) there is a discussion of the changes in the topography on the lot. While references are made to the similarities in slope to adjacent properties on Avenue of the Stars and on Pico, no mention is made of the similarity in slope to the Olympic side of the property as it relates to the also elevated housing north of Olympic. On both sides of Olympic under current conditions, there is a similar height/elevation that has not been addressed in the initial study. All that is said is that “an area of greater slop exists along the Olympic Blvd. frontage within the CSS Specific Plan” without any reference to adjacent properties across Olympic as was done for the other adjacent streets. Better discussion of adjacent uses regarding the Olympic Blvd. frontage is needed in the EIR.
As the adjacent uses are strictly residential, this is an added reason for one of the project alternatives to explore the potential for locating workforce and/or affordable HOUSING on the Olympic Blvd. frontage (or elsewhere within the project). Understanding that there is a significant need for workforce housing citywide and on the Westside in particular, and that such housing is not currently provided on any lots within the Century City North or South Specific Plans, it would seem to be a “no brainer” to incorporate housing into the project where it can be isolated from access to the studio proper. The Studio obtained significant benefits during the initial 1993 granting of exclusive studio industrial use rights and has already demonstrated that the first office building was not for its use or to directly support its production-related needs, but rather was divested as a real estate asset. The construction of two new office structures requires significant changes to current zoning and CCS Specific Plan designations.
The enormity of this project suggests that more should be obtained to benefit the City and this suggests that housing must be incorporated into this project (onsite or with a requirement to build and operate affordable a minimum number of dedicated and covenanted workplace housing units within a limited geographic distance from the studio lot). There are many Century City workers who could benefit from the availability of such housing. We remember well that the original plan for Century City consisted of half residential properties. There is no workforce housing in Century City. If the City seeks to place housing in “higher resource areas” it cannot ignore the need to do so in Century City which is one of the City’s employment hubs. Having available workforce housing will result in reduction of vehicle miles traveled (VMT) and greenhouse gas emissions. We request that workforce housing alternatives be analyzed as project alternatives in the DEIR.
Regarding Appendix 4: Employment Analysis
The analysis included in the initial study is based on old data and presents a very superficial set of assumptions that are not supported by current data. In addition, one model (IMPLAN) was used to estimate employment growth. In the DEIR we would expect to see additional modeling applied to identify or verify employment growth figures. Basing the Appendix on 2015 Employee Mobility Study is problematic. We would expect that new data from studio operations would be accessed and analyzed. Data that has been generated from the trip cap record-keeping must be reported to understand trip status. Annual averages may be interesting but they are not adequate alone as peaks and understanding the nature of peaks and valleys is important to understand future impacts. Have any studies been done at other studios that might be relevant to this discussion? Is it reasonable to assume that there has been zero employment growth between 2015 and 2024? We see no basis for that assumption. Was there any growth in trip counts during that period? In short, more current data and analysis must be used to assess future employment growth and the impacts of that growth.
Tree Inventory and Report Appendix IS-1 / Biological Impacts
It would be helpful if in EIR documents tables such as Table 5 identified the specific trees proposed for removal. It is difficult to understand how the proposed removal of 774 trees would not have an impact on BIOLOGICAL RESOURCES, including the wildlife that may live in, feed and/or rest upon, as part of the EIR process. The box on page 5 of the IS does not have Biological Resources checked off and the checksheet (page 78) indicates less than significant impact. What assessment has been made of nesting (seasonal or annually) in the trees along Olympic and any others to be removed? Despite being an urban area, we see birds of prey, owls, etc. who rely on tall trees in this urban environment. Will the loss of the Olympic tall trees have an impact on them or other birds?
When replacement tree plans are considered, it should be noted that the standard 2:1 replacement does not address issues related to heat island effect, nor the loss of tree canopy for decades into the future. This suggests that tree loss is to be minimized wherever possible and should be pursued. As part of the project perhaps a robust community tree planting effort will be warranted accompanied with a long-term commitment to the watering and maintenance of those trees for a period of time to guarantee establishment. What level of planting will offset the proposed loss of trees/canopy cover?
Requested Permits and Approvals 3.4
Even before the DEIR is issued, we would request a comparison of all requests being made against what the current rules/guidelines are that apply to this lot as well as a comparison of existing policies against what is being proposed and what the changes would mean. This is critical for the community to understand the project and future documents.
Conclusion
The definition of project alternatives is critically important is this DEIR and the following process is to have any worth. Too often clearly unfeasible alternatives are selected for analysis paving the way for the project in question to be approved. That should not be the case when it comes to the future of valuable Century City land and the role it plays in the entertainment industry in Los Angeles.
Thank you for your consideration.
Yours sincerely,
Barbara Broide
President, Westwood South of Santa Monica Blvd. HOA
cc: Council District 5 Office of Katy Yaroslavsky