ZA 2007 3557: Plans showing Retaining
Walls are incomplete, misrepresent
information, and contain errors
This project has potential to endanger adjacent property.
It proposes extensive excavation and a complex retaining
wall system, and fails to meet required setbacks.
Furthermore, there is very little in the project documents
to reassure neighbors about this danger.
First, although the case includes a GEOLOGY AND SOILS
REPORT APPROVAL LETTER (LOG #52404-02) from LADBS, this
letter states only that the Geology/Soils reports for this
project “are conditionally acceptable, provided the
following the following conditions are complied with during
site development”, and then imposes 40 conditions for
further review and approval by a geologist, soils engineer,
and grading/building inspector.
Which geological and soils experts will back up this
design?
Alfred V. Holz, the designer, is not an engineer.
Is someone with engineering credentials willing to
underwrite this plan, and speak with the neighbors? Why
should the neighbors believe that this design is not
dangerous?
The Hillside Development Project Description, Hillside
Development Project Master Land Use Findings, and Master
Land Use Application submitted for this project offer
little to eliminate doubt. The answers to most of its
questions appear insincere or unresponsive, and many are
brazenly so. Some answers are evasive and even incorrect
or false. This situation has angered some neighbors.
Furthermore, as we will show here, the plans have errors
and misrepresentations, and none of them provides an
accurate 3D picture of the retaining wall system. For
example, in the Southern Elevation plan, there is only an
abstract rendering of key retaining walls, the true heights
of walls are misrepresented, the shapes and heights of the
planters appear misrepresented, and there are errors
involving topography. It also feels as if the wall designs
try to meet requirements by inches, manuevering to reduce
glaring violations of retaining wall regulations.
To summarize: the plans look dangerous and applicants’
answers to questions raise more doubt than they eliminate.
Furthermore the plans provided are incomplete, misrepresent
information, and contain errors.
1. The Plans provide no Elevation that gives an
overall view of the Retaining Walls
For example, the South Exterior Elevation plan for ZA 2007
3557 includes a diagram with retaining walls (“fences”) at
the southwest corner:
860'
abstra
ct
vertic
al
scale
861'
“TOP OF
FENCE”
Wal
l
#22
848.31'
abstra
ct
wall
design
826'
Wal
l
#8
815'
ZA 2007 3557
SOUTH EXTERIOR ELEVATION
However, this South Elevation is “abstract”: it does not
give an accurate 3D view of these walls. For example it
omits Wall #22 (whose top is sketched in red), although it
is important in this elevation. Wall #8 is also rendered
abstractly. The Planter retaining walls at the base of
Wall #8 are only partly displayed.
The Plans from 2005
were much more detailed.
2. The Plans have inaccuracies about some
retaining walls.
For example: Walls # 8, 15, and 22 are important, since
they all need to retain semi-vertical parts of the hill.
These walls all have inaccuracies in the plans. They are
described in the Grading Plan:



Wall #8:
one fence of variable height 9'-9'' high point 3'-0''
low point.
Wall #15: one fence of variable height 4.29' high point 1'-0''
low point.
Wall #22: one fence of variable height 12'-0'' high point 3'-0''
low point.
The South Exterior Elevation plan can be augmented to show
all these:
860'
861'
“TOP OF
FENCE”
Wal
l
#22
848.31'
45'
drop
835'
830'
826'
Wal
l
#8
21'
dro
p
Wal
l
#15
815'
ZA 2007 3557
SOUTH EXTERIOR ELEVATION
809'
Wall #22 is a truly massive retaining wall that retains the
topmost part of the hill along the West and North sides of
the lot. Although claimed to be at most 12 feet high, its
vertical extent ranges from the Planters at street level
(about 818') to a peak near the center of the West side of
the lot (about 861'). This wall therefore has a vertical
range of about 45 feet.
Wall #15 is a strange little wall on the street. Although
supposedly 4.29 feet high, as discussed below it seems a
higher wall would be required.
Wall #8 is another massive wall, fronting on the street.
Structurally it is the main wall on the South side, yet has
no supporting caissons. It also looks much higher than the
claimed maximum 9'-9''. In fact, the diagram above shows
that this is not an illusion: at the point indicated, the
top of Wall #8 has at least a 21 foot vertical drop to
street level.
These walls are visible in the Fence Elevations Facing West
from West Property Line:
“TOP OF FENCE”
861'
860'
856'
Wall
#22
850'
847'
840'
841'
834'
Wall
#8
830'
826'
Wall
#15
820'
815'
Planter
wall
Street level in the southwest corner is
at 815'
A closeup of the left of these Fence Elevations (at the
southwest corner of the lot) shows some problems:
“TOP OF FENCE” closeup (at
street)
Along the face of
Wall #8,
Wall #22 has height
13' (although plan
says  12')
Wall
#22
Unnamed
Wall ?
Wall
#8
Wall #8 is shown here
as having a height of
12' (although plan
says  9'9'')
12'
Hill’s semivertical
slope is
approx 4:1
here; see
below
Wall
#15
Plante
r Wall
#13
7'
This matters:
if Wall #8 is above
12' it violates LAMC
12.21A8(a); if below
10' it is eligible to
When
meet the
LAMC“Planters” are
filled
with soil, the
12.21A8(a)(ii).
base of Wall #8
increases, and its
height decreases. So a
critical aspect of this
design is the use of
soil
“Planters”.
This in
815'the
base
was 820' in the
previous plans
(from 2005).
This shows some inconsistencies and inaccuracies in the
plans; there appear to be many. Here, the Fence Elevations
suggest that both Wall # 8 and Wall # 22 exceed their
stated maximum heights.
street
level
3. The “Planters” are actually tiered Retaining
Walls.
The “Planters” look decorative, but actually are tiered
retaining walls that serve to raise the base of Wall #8 by
at least 7 feet, and in some places raise the base of Wall
#8 more than 11 feet. As shown earlier, in the South
Elevation plan these Planter walls appear modest, limited
to something like 3.5’ in height:
Wall
#8
“Planter
s”
Wall
#8
3' 4
3/4''
This elevation is a strange drawing – it is hard to read
and omits important details. It seems to misrepresent the
shape, layout, and scale of the “Planters”, which are
actually a system of retaining walls in front of Wall #8:
Wall
#8
Wall
#8
“Planter
s”
The retaining walls (specifically from Walls # 7, 9, 10,
11, 12, 13, 14) are paired walls that are specified as
ranging from 3' to 7.25' individually in maximum height.
Variances are being requested for these walls.
The West Elevation plan shows that tiering the walls
permits them to reach quite high, despite their maximum
stated heights.
By tiering the walls, using sloped earth
between walls, and only counting wall height from the level
of the earth, these paired-wall tiers are enough to raise
Wall #8 by more than 12' at the point portrayed in the West
Elevation:
The top of Wall
#8
is more than
21'
above street
Wall
level
#8
9'
12
'
2 “Planters”
(2 retaining
walls)
“Planters”
raise
Wall #8 by
more than 12'
So these tiers of walls are actually TALL.
The combined
height of the planters is more than 10' (ignoring the
sloped dirt above). If these tiers of planters were not
present in the design, the height of Wall #8 would be 9' +
12' = 21' here.
It is also interesting that, if the earth in the higher
“Planter” is not sloped steeply as drawn here (i.e., it is
more like an actual “Planter”), then Wall #8’s foundations
become exposed, and the height of Wall #8 increases to over
11’.
To be totally clear about the nature of the “Planters”, we
can look at them in detail. Below is an enlarged portion
of the West Elevation in which the “Planter” measurements
are shown explicitly.
831.00'
Wall #8
9'
0''
824.99'
more
than
12'
6' 4
1/2''
Wall
#13
The slope of this
dirt is crucial for
the height of Wall
#8.
If it were
flat instead of
sloped (as in most
“Planters”), the
height of Wall #8
would increase from
9' to 11'.
814.63'
Wall #11
(?)
3' 3
3/4''
809.29'
Notice that this arrangement involves three stacked
retaining walls, and in fact the design includes other
walls behind these.
4. The Project Application (and the ZA Public
Hearing Notice) omits some variances required by
the design.
The portion of the West Elevation just above shows that
there are three stacked retaining walls at the front of the
house, where LAMC 12.21A8(a) limits retaining walls to two.
The ZA Hearing Notice does not seem to include this as a
variance, including only one request for a variance
involving Wall #13:
3) pursuant to Section 12.24-X.7 of the Los Angeles Municipal
Code, a Zoning Administrator’s Determination from Section 12.21C,1(g) to permit the construction, use, and maintenance of wall
#8, wall #9 wall #13, wall #14, and wall #15 to be located in the
front yard in lieu of the permitted 3 feet 6 inches;
This requested ZAD does not mention Section 12.21A8(a).
It would be worthwhile to make a careful inventory of ALL
retaining wall variances required by the current plans.
The list of requests proposed in the Application differs
from the ZA list, and some variances are omitted by both
lists.
Specifically, the notice of the Public Hearing for this
case lists the 24 retaining walls of this project and
requested variances from retaining wall regulations:



3) pursuant to Section 12.24-X.7 of the Los Angeles
Municipal Code, a Zoning Administrator’s Determination from
Section 12.21-C,1(g) to permit the construction, use, and
maintenance of wall #8, wall #9 wall #13, wall #14, and
wall #15 to be located in the front yard in lieu of the
permitted 3 feet 6 inches;
4) allow wall #3, wall #8 and a portion of wall #21 to be
in the required side yards in lieu of the permitted 6 feet;
and
5) pursuant to Section 12.28 of the Los Angeles Municipal
Code, a Zoning Administrator’s adjustment to allow walls
#1, #2, and #3, and a portion of walls #21, #22 and #23 to
be in the required rear yard in lieu of the permitted 6
feet.
The role of the “Planters” (Walls # 7, 9, 10, 11, 12, 13,
14) is vital here. They violate the Hillside Retaining
Wall regulations in the Los Angeles Municipal Code
(specifically LAMC 12.21A8):
8. Retaining Walls in Hillside Areas. (Added by Ord. No. 176,445, Eff.
3/9/05.) This subdivision applies to retaining walls that meet all of the following
criteria: located in the A or R Zones (including the RA Zone), located on land
designated as a Hillside Area on the Bureau of Engineering Basic Grid Map No.
A-13372, and located on a lot developed or to be developed with dwelling units.
For purposes of this subdivision, a "retaining wall" shall be defined as a
freestanding continuous structure, as viewed from the top, intended to support
earth, which is not attached to a building. Retaining walls are subject to the
following restrictions:
(a) A maximum of one free standing vertical or approximately vertical
retaining wall may be built on any lot with a maximum height of 12 feet as
measured from the top of the wall to the lower side of the adjacent ground
elevation. However, as shown in the diagram below, a maximum of two vertical
or approximately vertical walls or portions of a wall can be built if they comply
with the following:
(i) The minimum horizontal distance between the two walls is three feet,
(ii) Neither of the two walls exceed a height of 10 feet measured from the
top of each wall to the lower side of the adjacent ground elevation at each wall,
and
(iii) In no case shall the height of a wall located in a required yard exceed
the height allowed by Section 12.22 C.20.(f) of this Code.
(b) Landscaping. For retaining walls of eight feet or greater in height, the
applicant must submit a landscape plan designed to completely hide the retaining
wall from view within a reasonable amount of time. The landscape plan shall be
subject to the approval of the Director of Planning in accordance with Sections
12.40 through 12.43 of this Code and any Landscape Guidelines established by
the City Planning Commission.
(c) Zoning Administrator approval for taller walls or additional walls.
Retaining walls that exceed the heights or the maximum number allowed in
paragraph (a) of this subdivision shall be subject to the approval of a Zoning
Administrator under Section 12.24 X.26. of this Code.
It seems likely that further analysis of the Plans will
uncover more problems with these retaining wall
regulations.
5. It is not clear how the design can meet the
Retaining Wall Landscaping regulation (LAMC
12.21A8(b))
The Landscaping regulation (LAMC 12.21A8(b)) reproduced
just above seems hard to satisfy for Wall #8 in the plans.
This regulation requires the developer to submit a
landscape plan designed to completely hide the retaining
wall from view within a reasonable amount of time. It will
be difficult to hide Wall #8, which fronts on the street,
has an elevation of 21 feet and is over 50 feet long.
Although the South Elevation apparently includes this text
to deal with the Landscaping regulation for Wall #8:
ONE COAT OF EXTERIOR CEMENT PLASTER OVER
EXPOSED MASONRY OR CONCRETE – TYPICAL
This design strategy is unlikely to satisfy the Landscaping
regulation.
861'
“TOP OF
FENCE”
Wal
l
#22
848.31'
835'
“ONE COAT OF EXTERIOR
CEMENT PLASTER OVER
EXPOSED MASONRY OR
CONCRETE – TYPICAL”
Wal
l
Wal
l
#8
#8
ZA 2007 3557
SOUTH EXTERIOR ELEVATION
830'
21'
dro
p
809'
Wal
l
#8
Wal
l
#8
It may be possible for the design to fix Wall #8 to meet
this regulation, but Wall #8 is only one landscaping
problem in a design with 24 retaining walls.
6. The Southwest Corner of the design is based on
topography that understates the steepness of the
terrain.
The southwest corner of the project is a semi-vertical
hill, well-known to the neighbors. Wall #22 and Wall #15
are supposed to retain this hill, but Wall #15 is only 4
feet high. To appreciate this point, here is a portion of
the Plot Plan that shows the position with Wall#15:
Propert
y
Line
Semivertical
topography
of the
natural
slope here
(outside the
property
line) is
much steeper
than claimed
by this
plan.
Wall #8
Wall
#22
17' 8''
Claimed natural
slope
≈ (835 - 820)/18
= 15/18 < 1/1
This does not
match reality;
the real slope
is ≈ 3/1 or 4/1
Wall #15
This wall
is outside
the
Property
Line.
The claimed contours of the slope to the West (left) of
Wall #15 have a vertical drop of 15 feet over a marked
horizontal distance of about 18 feet, giving a slope that
is less than 1:1. Contrast this with a photo of the
property line at the southwest corner:
QuickTime™ and a
decompressor
are needed to see this picture.
This photo shows the southwest corner on Seabury Lane;
dashed line leads to set nail in the street. True slope of
the (semi-vertical) hill here is about 4:1, not 1:1 as
suggested by the Plot Plan.
This lot has been viewed for years as “unbuildable” by
neighbors. Features like this semi-vertical southwest
corner make the neighbors believe that successful building
will require engineering sophistication (not for amateurs)
and a design that fits the hill.
7. The Topography for Wall #22 submitted in the
2007 Plans differs from that submitted in the 2005
Plans.
The 2005 and 2007 Plans are extremely similar, and in some
spots are identical. Generally speaking, it appears the
2005 plans made less of an effort at meeting retaining wall
regulations, since at that point the Retaining Wall
Ordinance was new.
It is interesting to compare the 2005 and 2007 Plans on the
massive West retaining wall (Wall #22 in the 2007 plans).
The most striking change is that this wall (and the natural
grade behind the hill) has shrunk in height.
865'
NATURAL GRADE
BEHIND
FENCE/WALL
855'
BEFORE
(2005)
Wall
#22
861'
AFTER
(2007)
849'
The shrinkage in wall height is important for the design,
since it makes some violations of the retaining wall
regulations less obvious. Notice that Wall #22 is never
higher than its height at the center, which is precisely
the maximum allowable 12' high. Strangely, however, the
peak height 861' in the 2007 plans is at or below grade of
the existing hill. Furthermore this West wall in 2007
appears more bowed more along the southern side than in
2005. It appears that the topography of the hill has been
changed. If so, even if this design works in theory, it
may have difficulty working in practice.
Another general point about the difference in Plans between
2005 and 2007: the Plans for 2005 are much more complete.
The Plans for 2007 are sketchy and omit details about
retaining walls. It is difficult to understand why the
plans would become more sketchy.
Generally: the 2007 Plans gives the impression of
straining to meet regulations, leaving no margin for error,
and fudging when the numbers do not quite work. Given the
errors in topography noted earlier, and the fact that NO
SOURCE IS GIVEN FOR THE TOPOGRAPHY, the validity of the
design is suspect.
Summary
To reiterate: the plans omit information (such as the
overall 3D structure of the walls in an Elevation; instead
providing only 2D schematics in the Plot and Grading Plans
in which height figures seem untrustworthy); they
misrepresent information (such as the shape and nature of
the Planters in the South Elevation, and the questionable
9'-9'' stated maximum height of Wall #8); and they rely on
erroneous information (such as inaccurate topography in the
southwest corner, and questionable unattributed topography
along the ridge for Wall #22). It is not even clear that
all variances required by the Plans are to be discussed at
the Public Hearing.
IN CONCLUSION: THIS IS A POTENTIALLY DANGEROUS PROJECT,
AND THE PROJECT DOCUMENTS RAISE MORE DOUBTS THAN THEY
ELIMINATE. CANYON PROPERTIES LLC HAS ACCUMULATED A
NEGATIVE TRACK RECORD WITH THE NEIGHBORS  A HISTORY OF
DISREGARD, MISREPRESENTION, AND SLOPPINESS  AND THIS CASE
(ZA 2007 3557), LIKE ITS PREDECSSOR (ZA 2005 4355), IS
CONSISTENT WITH THAT RECORD. THERE SEEMS GOOD REASON TO
DOUBT THE VALIDITY OF THE PLANS, AND TO DOUBT THAT THIS
PROJECT IS SAFE.
THEREFORE, NEIGHBORS REQUEST THAT THE ZONING ADMINISTRATOR:
(1) REQUIRE MORE COMPLETE INFORMATION ABOUT ALL GRADING AND
RETAINING WALLS FOR THIS PROJECT, AND (2) REQUIRE THE
DEVELOPERS TO PROVIDE AN ACCREDITED EXPERT WHO IS WILLING
BOTH TO DEFEND THIS INFORMATION, AND TO ANSWER (IN WRITING)
POINTED QUESTIONS BY THE NEIGHBORS OR THEIR DESIGNATES
ABOUT THE INFORMATION.