2015-102 CDP CU SPP, 601 Ocean Front Walk, Venice
Submitted by John Stein, 20 Sunset Ave, Venice, Nov 23, 2015
To: Venice Neighborhood Council and Land Use and Planning Committee,
Because the above identified project is complex, pushing the envelope in many directions and
touching on many issues, and because I have now contributed voluminous Exhibits to the file which
might be more than can be digested, discussed and voted upon in the limited time VNC and LUPC will
have to discuss this project, therefore I am taking the liberty of composing some sample wording that
LUPC and/or VNC might choose to use to come to terms with some or all of the aspects of this project.
This project is scheduled to be heard before LUPC on November 30th, and before VNC on December 1st.
Respectfully Submitted,
John Stein
Possible Clauses for Inclusion in a LUPC or VNC Motion
Recommend full EIR
Coastal Commission CEQA process in 1992 stated that any expanded development at
this site would require a cumulative impact study of Speedway traffic. (See Exhibit A: Selected
Quotations from Final Revised Findings, Coastal Commission, A5-90-789, 1/15/92, in file.) This has yet to
occur. EIR is needed to determine sensitive and critical balance between i) commercial property rights
along Ocean Front Walk (OFW), ii) quality of life in adjacent Walk Street residential Historic District, and
iii) beach access for general public.
Applicant’s Traffic Impact Study analysis of single-project impact, if multiplied by the number of
developable properties along Speedway and OFW (6 sections of OFW), would show a traffic impact that
rises to the level of “significant impact” at study intersections, and such cumulative impact then requires
an EIR if it can’t be mitigated.
Recommend requiring Cumulative Impact Study of Potential Speedway Alley build-out
Require revised Traffic Impact Study from applicant and/or DOT, as per Coastal Commission
1992 findings and as per requirements of Traffic Impact Study guidelines. It is not sufficient, as
applicant’s Traffic Impact Study has done, to study just the “cumulative impact” on signaled
intersections on Pacific Ave and on Main Street of currently proposed projects spread around Venice as
far away as Lincoln Blvd. (See Exhibit B: Cumulative Impact Analysis, in file.)
Recommend Denying Project as Proposed
Recommend Denial of Applicant’s request for 1.5:1 FAR residential bonus
Project’s residential component, a security guard’s live/work space according to the project
architect, should be deemed insufficient to qualify project for 1.5:1 FAR bonus as a residential project.
Recommend project be reduced in scale so as to mitigate cumulative impact on speedway. As
proposed, project degrades values of adjacent properties across Sunset Ave. and across Speedway alley,
adversely affects adjacent Walk Street Historic District neighborhood, and impinges on public access.
(See Exhibit F: Parts I,II and III Mass and Scale, in the file.)
Or more particularly:
Recommend Floor Area and Floor-Area-Ratio (FAR) measurements be checked for conformity with
code. At Thornton Lofts, “Buildable Area” was reduced from “Lot Area” by subtraction of setbacks.
“Floor Area” must include terraces-mechanical-toilets-stairs, as opposed to applicant’s reported
measure of “leasable” floor area. Both adjustments would increase currently proposed FAR above
allowable limits.
Recommend removal of 5ft mechanical roof screen around roof perimeter, and dropping HVAC units to
flat deck at 33ft, as architect said he would favor. Recommend flat deck central portion at 33’ height
(not visible inside perimeter sloped roof at 33’-35’), and recommend “Specific Plan Adjustment” for 10%
height bonus from flat roof permitted height of 30’. Lowered central flat deck would be easier for
mounting HVAC units. 5ft high mechanical screen around perimeter (on top of 35ft roof peak=40ft
height) blocks ocean views from neighboring properties and adversely effects and degrades adjacent
neighborhood. (Disclosure: proposed roof deck on my own house overlooks this project.) (See Exhibit
F.1, in the file.)
Recommend 5ft height bonus for “varied roofline” be denied. Proposed roof is simply a series of 2ft
corrugated ridges at the required pitch-slope between building heights of 33ft and 35ft, but which
provide an overall roofline that will appear perfectly flat for over 80% of the building’s width/length on
all 4 sides. Project would have just a minimal camber from 33ft to 35ft for 12ft around the edge, but
intention of “varied roofline” 5ft height bonus in Specific Plan was to allow architectural variety and
some roof projections, and not to serve as means to raise overall building height to 33 or 35ft.
Recommend 3ft or 6ft South side yard setback to 615 Ocean Front Walk apts (instead of 0-ft proposed),
to mitigate severe degradation of precious modest-income rental housing stock at 615 OFW, which
would be adversely affected by loss of air and light. Instead of 0ft setback and 3ft building separation as
proposed, recommend 3ft or 6ft setback and 9ft building separation, as per recent Thornton Ave Lofts
project on other side of 615 OFW. (See Exhibit F.2, in the file.)
Recommend 15ft set-back on Speedway (instead of 10ft proposed), in conformity with 15ft setbacks at
adjacent 615 OFW and next-adjacent Thornton Lofts at 619 OFW. Extra setback needed because
Speedway is a bottleneck to the neighborhood and to commercial, residential and beach access. New
projects should take the opportunity to set a new precedent for widening Speedway to increase light,
air, and public beach access. As proposed, 10ft setback adversely affects light and air on Speedway and
degrades beach access. (See Exhibit F.4, in the file.)
Recommend 10ft setback from Sunset Ave walk street (instead of proposed 6ft). Walk Streets views are
to be protected, as per the Specific Plan. Extra setback (above 6ft required by code) is needed because
35-40ft high building would loom over modest scale residential properties across Sunset Ave and
deprive them of sunshine. Adjacent 523 OFW is historically protected by covenant. 9 Sunset Ave is one
of the oldest houses in Venice. No’s 9 and 13 Sunset Ave are residential. All three modest sized
properties on modest lots adjacent across Sunset Ave would be degraded and adversely affected by loss
of sunshine from the project’s high profile as proposed. Also, project’s main entrance to 2nd and 3rd floor
offices and retail is from Sunset Ave. at the corner of Speedway. The pedestrian traffic in and out of this
large building, including deliveries, would adversely affect and degrade properties across Sunset Ave,
and needs mitigation with a widened Sunset Ave. setback. Sunset Ave. setback should be increased to
at least 7ft 8in, as per precedent set at Thornton Ave., one block to south. Both subject project and
Thornton lofts are similarly zoned C-1 Community Commercial. But a wider 10ft setback is what is really
needed, because the pedestrian traffic impact of these entrances on the residences across Sunset Ave
would be very large.
Recommend more parking be required: (See Exhibit G: Bike and BIZ Parking, in file.)
Recommend fewer spaces traded for bicycle parking. Trade-off of 32 spaces for 128 bike spaces
is not acceptable. The result will be increased pressure on limited parking in the area. The result will be
increased pressure on the already pressured rental housing stock for 128 apartments within bicycle
distance.
Recommend BIZ parking be required for office level in addition to ground floor retail, just as was
provided at Thornton Lofts, where BIZ parking for both ground floor retail and main (second) floor
residential. The1992 Coastal Development Permit, as conditioned, a CDP still in effect, required 14 BIZ
parking. (See Exhibit G: Parking, in the file.)
Recommend denial of 50% buyout of required BIZ spaces. The 1992 the Coastal Commission
findings recommended burden of BIZ and beach “replacement parking”, i.e. when an existing parking lot
is developed, be put on shoulders of larger projects, because smaller projects are unable to do so.
Therefore BIZ parking buyout of 50% of spaces should be denied in this case. (See Exhibit G: Parking,
containing a selected quotation from the Final Revised Findings, Coastal Commission, A5-90-789,
1/15/92.)
Recommend 50% replacement of existing general use parking lot spaces, or 22
replacement parking of existing 43 spaces, as per Coastal Commission Final Findings, 1992.
Operation:
Hours of Operation:
Recommend limiting hours of operation to 8am to 10pm. Project is surrounded by residential
uses on 3 sides.
Recommend prohibition of parties on terraces after sundown. Commercial tenants at 523
Ocean Front Walk, the “Blue House” also owned by the same applicant, have for many years given
frequent parties. Project is surrounded on 3 sides by residential uses.
Parking Operation:
Recommend requiring nighttime and weekend parking be made available to neighbors on a
monthly basis.
Recommend requiring more spaces for community night-time monthly use. CDP A5-90-789 in
1992 required 16 spaces reserved for community night-time use.
Recommend requiring more spaces for community day-time monthly use. There is no longer
any community, public or beach parking at 619 OFW or at 701 OFW, ever since those properties became
leased by and now reportedly sold to Snapchat. There is currently a 60 person waitlist for monthly
community parking at 801 OFW, according to the parking attendant there. The removal of the 43
existing spaces from the community inventory at this project site will be traumatic to neighbors, to
commercial vendors along OFW and to beachgoers.
Other Mitigating Measures
Recommend requiring applicant to pay for installation of automatic garage doors at 18 Sunset,
across Speedway, because entering and exiting 18 Sunset with doors operated manually temporarily
blocks Speedway.
Recommend applicant pay into a fund to underground utilities along Speedway, to remove poles
and thereby make extra room and ease traffic.
Recommend requiring construction hours to be limited to between the hours of 8am and 6pm.
Mitigation needed because project is surrounded on 3 sides by residential uses.