Santa Monica Coalition for a Livable City

February 1, 2010

To: Planning Commission

From: Bd of Directors, Friends of Sunset Park (supported by the Santa Monica Coalition for a Livable City)

RE: February 3, 2010 agenda item 7-A -- Paseo Nebraska Development Agreement Float-Up

The FOSP Board opposes the Paseo Nebraska development agreement "float up" as currently proposed. It is simply too big, and it does not provide meaningful, sufficient benefit to the community to justify moving the proposal forward.

The FOSP Board took a position in 2005, at the time of the Lantana Campus expansion on Olympic/Exposition, that we would oppose all large developments unless traffic impacts on residential neighborhoods could be mitigated. Paseo Nebraska, at 356,793 square feet, is a development that would have a negative effect on the preservation of the surrounding residential areas for the following reasons:

1. Too close proximity to other large traffic-generating projects.
2. Existing traffic is already at saturation levels.
3. Nearby intersections are already congested.
4. Pending development projects will further impact local streets and intersections.
5. There are no meaningful public benefits that justify the size of the project. In addition, entering into a Development Agreement will limit the City’s ability to change the project to protect the community’s interests in the future.
6. There is no guarantee that the office space will actually be used for "creative arts."
7. The proposal's 5-story, 58-foot maximum height, and 2.5 FAR exceed the current LMSD standards (4 stories, 45 feet, and 1.5 FAR), and it lacks the open space that is expected under the Draft LUCE.

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Additional information:
1) Too close proximity to other large traffic-generating projects (See SMCLC map of projects proposed as DAs in this area, attached.)
a. Paseo Nebraska is located at 3025 Olympic, between Stewart and Centinela, with the property extending north to Nebraska Avenue.
b. Its adjacent neighbor to the east, New Roads/Herb Alpert Educational Village, is in the process of expanding. With 213 parking spaces, it might possibly generate 1,200 daily car trips.
c. Its eastern border, on Berkeley/31st, is only 2 short blocks west of the Centinela/33rd side of the Bundy Village & Medical Park. The Draft EIR for that project estimates 20,073 new daily car trips.
d. Its western border, on Stanford/30th, is only 2 short blocks east of the Stewart/28th side of the Bergamot/Papermate project. With 1,600 workers, 450 residents, and shoppers in the 1st floor retail stores, and at 969,000 sq ft (¾ the size of the proposed Bundy Village & Medical Park), it might possibly generate 15,000 daily car trips.
e. Agensys, Inc., 1800 Stewart, proposes 300 parking spaces and might possibly generate 1,200 daily car trips.
f. The SMC Academy for Entertainment and Technology, 1660 Stewart, is expanding to 450 parking spaces and might possibly generate 2,700 daily car trips.
g. 1834 Colorado Creative Studio Project, at the SE corner of Stewart and Colorado, will have about 584 parking spaces. The Draft EIR estimates 1,796 net new daily car trips.
h. Roberts Business Center, 2848-2912 Colorado (between Stewart and Stanford), will have 583 parking spaces and might possibly generate 2,100 daily car trips.
i. Village Trailer Park, 2930 Colorado (between Stewart and Stanford), will have 738 parking spaces and might possibly generate 2,900 daily car trips.

2) Existing traffic is already at saturation levels -- 24-hour traffic counts in 2006 showed 33,880 daily car trips on Olympic Blvd. between 26th & Centinela. How many daily car trips can be added from Paseo Nebraska, Bergamot Transit Village Center, Bundy Village and Medical Park, Agensys, New Roads School, and the SMC Academy of Entertainment and Technology before traffic on Olympic grinds to a halt, as has happened during PM rush hour on other east-west streets in Santa Monica?
a. Wilshire Blvd. ----------- 39,806 daily car trips
b. Santa Monica Blvd. --- 28,159
c. Olympic Blvd. ---------- 33,880
d. Pico Blvd. ---------------- 26,663
e. Ocean Park Blvd. ----- 27,189

3) Nearby intersections are already congested -- A 2004 summary of intersection level of service (LOS) ratings showed the following. ("A" is good, "F" is bad.)
a. Olympic & 20th -- D in the AM, F in the PM
b. Olympic & Cloverfield -- F in the AM, F in the PM
c. Olympic & Stewart (28th) -- D in the PM
d. Cloverfield & the westbound I-10 freeway off-ramp -- F in the AM
e. Centinela & Colorado Avenue -- D in the PM
f. Centinela & the I-10 freeway westbound off-/on-ramps -- F in the AM, F in the PM

4) Pending large development projects will further impact local streets and intersections –
From June 15, 2009 “Comments on DEIR for Bundy Village & Medical Park Project”:
“The City of Santa Monica is ‘deeply concerned’ about the impacts of the Bundy Village and Medical Park on Santa Monica streets.”
“Based on the City of Los Angeles (LADOT) impact criteria, 15 out of the 25 intersections within or bordering on the City of Santa Monica are significantly impacted. These intersections include:
1. Colorado Avenue/Stewart Street
2. Olympic Boulevard/20th Street
3. Olympic Boulevard/Cloverfield Boulevard
4. Olympic Boulevard/26th Street
5. Olympic Boulevard/Stewart Street
6. Olympic Boulevard/Centinela Avenue (north leg)
7. Olympic Boulevard/Centinela Avenue (south leg)
8. Centinela Avenue/I-10 WB On-/Off Ramps
9. Pico Boulevard/23rd Street
10. Pico Boulevard/Cloverfield Boulevard
11. Pico Boulevard/I-10 EB On-Ramp
12. Pico Boulevard/Centinela Avenue
13. Centinela Avenue/I-10 EB On-Ramp
14. Ocean Park Boulevard/23rd Street
15. Ocean Park Boulevard/Centinela Avenue
“An additional 2 intersections would be impacted under the Critical Movement Analysis, according to LADOT significance criteria:
1. Santa Monica Boulevard/Cloverfield Boulevard
2. Pico Boulevard/Lincoln Boulevard”
Adding more over-sized development projects within the LMSD zone will exacerbate these impacts.

5) Community benefits -- There are no meaningful public benefits that justify the size of the project. In addition, entering into a Development Agreement will limit the City’s ability to change the project to protect the community’s interests in the future.
a. Creating transit-oriented development when no rail line has been constructed does not confer any community benefit.
b. Provision of tax revenues will be offset by pressure on our aging infrastructure, including rising costs for sewer, water, and electricity, and rationing of declining resources, such as water.
c. Provision of new Class A office space in a city that already has a serious jobs/housing imbalance promotes regional growth, but does not confer any community benefit.
d. The mix of housing is a problem: It's not clear that the addition of "moderate" income (100% of median household income) and "workforce" housing (130% and 150% of median household income) will be affordable for "nurses, teachers, police, firefighters, and others." Have studies been done to ascertain whether nurses, teachers, police, and firefighters working in Santa Monica actually want to live in apartments such as these?
e. There is apparently an existing need for "low income" and "very low income" housing units in Santa Monica, yet none are shown in the proposal.
f. The city’s Total Cumulative Development summary shows that over 11,000 residential units are now pending in Santa Monica and surrounding communities. Is there a city policy as to how rapidly we want the city’s population to grow?
g. It’s not clear that residents will use the Expo Line when it’s built, or that traffic will be reduced. From a June 30, 2007 article by Sharon Bernstein and Francisco Vara-Orta in the L.A. Times entitled “Near the rails but still on the road: Research casts doubt on the region’s strategy of pushing transit-oriented residential projects to get people out of cars” comes this quote: “The reporting showed that only a small fraction of residents shunned their cars during morning rush hour. Most people said that even though they lived close to transit stations, the trains weren't convenient enough, taking too long to arrive at destinations and lacking stops near their workplaces.”
Another complaint was that they weren’t comfortable riding slow, crowded MTA buses from the transit terminals to their job sites. Finally, it appears that the shops and cafes that are sometimes included in mixed-use developments at transit stations can actually bring more cars to neighborhoods, bringing worse traffic congestion to neighborhoods that expected traffic to improve.
h. Constructing necessary internal passageways ("paseos") in the project provides tenant incentives and enables higher rents, but they do not constitute a public benefit because these areas are not public facilities or parks. By definition, “publicly accessible private spaces” do not dedicate land for a public purpose. Is there an example of "publicly accessible private space" in Santa Monica that would be comparable to the Paseo Nebraska paseos and common areas?
i. Requiring a developer to contribute to street extensions, sidewalks, and landscaping, which would be necessary for a project of any size to work in these surroundings, confers an insufficient community benefit if the result is that the project’s size and mix imposes an equal or greater burden on the community.
j. It's not clear that extending Berkeley and Stanford to Olympic Blvd. will benefit residents living north of Nebraska on those two streets.

6) "Creative arts office space" -- What's the definition of “creative arts office space,” what are the building requirements, and what's to prevent, for example, a health insurance firm from renting Paseo Nebraska office space and using it to figure out "creative" ways of denying coverage to clients?

7) FAR and building height -- The proposal's 5-story, 58-foot maximum height, and 2.5 FAR exceed the current LMSD standards (4 stories, 45 feet, and 1.5 FAR), and it lacks the open space that is expected under the Draft LUCE.

Conclusion:
The proposed Paseo Nebraska is simply too big! It does not provide meaningful, sufficient benefit to the community to justify moving the proposal forward.

FOSP & SMCLC