Dear Mr. Netburn, the VCHC's proposal is too tall, too dense, has too little parking, and is way out of character with Venice. It is extremely out of step with both the Venice Specific (land-use) Plan and the desires of residents for Venice to remain a low-rise community. Approving its 45-foot height and almost no parking will set a dangerous precedent. Send it back to the drawing board!
The hearing is Wednesday at 9:30 AM, so please email your message by the end of business Tuesday.
More details are provided below.
Thanks for helping stop this classic example of over-development.
Dear Mr. Netburn,
I am writing on behalf of the Venice Stakeholders Association to oppose the Rose Apartments project proposed for the former site of the offices of Venice Community Housing Corporation (VCHC) unless the project’s height, setbacks, façade, landscaping and parking are modified.
As is readily evident from elevations of the project presented on VCHC’s website, the project will tower over all nearby structures. Further, the massing, height and lack of required parking stand in extreme violation of the Venice Local Coastal Specific Plan.
I am writing on behalf of the Venice Stakeholders Association to oppose the Rose Apartments project proposed for the former site of the offices of Venice Community Housing Corporation (VCHC) unless the project’s height, setbacks, façade, landscaping and parking are modified.
As is readily evident from elevations of the project presented on VCHC’s website, the project will tower over all nearby structures. Further, the massing, height and lack of required parking stand in extreme violation of the Venice Local Coastal Specific Plan.
To start with, the project
description, as declared on the CPC’s hearing notice and elsewhere, is
incorrect:
Demolition of commercial office uses
and the construction, use maintenance of a four-story, 35 unit permanent
supportive housing complex with ancillary administrative office.
This is a mixed-use project with ground
floor commercial offices to be occupied by Venice Community Housing Corp., a
private corporation, with a 35% plus 20% density bonus project totaling 35 residential
units. The commercial component is
not ancillary to the residential housing because VCH intends on conducting
their own separate corporate business - which is now conducted in a structure
on the same site – within the new structure - unrelated to the housing
component. Outlined below are several facts which call for the modification of
the project to conform with the VLCSP, city ordinances, Coastal Commission
precedents, environmental best practices, and a variety of community
concerns.
1. Number of stories and height of the building: The applicant has not designed the project within the
California state standard density bonus guidelines but has requested “off menu
incentives.” Off menu incentives are requests that exceed the “by right”
incentives permitted under the density bonus laws. As an example, the SB
1818 state density law permits an applicant to exceed the height limit by one
story and not more than 11 feet. This applicant is requesting two
additional stories and 20 additional feet of height. As proposed this
building would be the only four-story building in the entire Oakwood subarea of
the Venice Land Use Plan. The permitted height in the coastal zone for this
project is 25-feet for a flat roof and the proposed project is 45 feet high. Thus,
this project represents a dangerous precedent both for future developments under
the existing Specific Plan and for the message its approval would send to city
planners now engaged in drafting the Venice Local Coastal Plan and revising the
Specific Plan. Venetians support the
low-rise nature of our community and want it maintained.
2. Parking The
required parking for this project under the VLCSP is 89 spaces. In the past the
Coastal Commission has determined that state density bonus laws DO NOT override
the California Coastal Act. Numerous affordable housing projects within
the Coastal Zone have been required to provide one parking space per
unit. The proposed project as designed and presented to the Venice
Neighborhood Council provides only 12 parking spaces for the 35 residential
units of which seven parking spaces are proposed off-site. Based on the Los
Angeles Municipal Code section 12.26E5 and documentation from the property
owner who owns the offsite parking lot located at 225 Lincoln Boulevard, these seven
off-site parking spaces will not be available for the new project, as explained
below.
3. Off-Site Parking Affidavit Parking affidavit 4123, which was
recorded on October 11, 1973, was an agreement signed between a building
tenant, Safeway No. 45, located at 225 Lincoln Boulevard, and The Children’s
Center for Educational Therapy, located at 718-720-722 Rose Avenue. Parking
affidavits are required to be signed by the legal owners of the real property
of both properties and not tenants. Safeway No. 45 was not the legal property
owner and had neither the authority, permission nor right to sign said
agreement. Parking affidavit 4123 should be deemed null and void. Furthermore, per
city policy, parking affidavit 4123 will no longer continue in effect once the
existing structures on 718-720-722 Rose are demolished. The seven
offsite parking spaces which VCHC has publicly claimed will be satisfied by the
affidavit are non-existent.
4. Building Setback Requirements from Rose Avenue The Specific Plan,
in the Oakwood subarea, requires “any portion of the roof that exceeds 25 feet be
set back from the required front yard at least one foot in depth for every foot
in height above 25 feet.” The proposed project does not comply with this step
back requirement and proposes a 45-foot high wall with no windows facing Rose
Ave at the 2nd, 3rd and 4th floors. The
proposed design does not provide a varied and articulated facade with visual
interest to pedestrians. The primary ground floor entrance to the residential
entrance does not face the street and is accessed from a narrow side yard and a
14-foot passageway and is located more than 75 feet from the sidewalk.
All of
these design elements violate the Specific Plan, thus precluding the CPC’s
granting of a Project Permit under the plan.
Further, the ground floor office space, which is not a visitor serving
use, is set two feet below the grade of the sidewalk, which is
inconsistent with the Los Angeles Citywide Design Guidelines.
5. Environmental Categorical Exemption The applicant is unacceptably proposing no environmental
review for the proposed project despite requesting a project with density
almost double that permitted in the zone, the tallest building in Oakwood by an
entire floor, inadequate parking, no loading zone, blank walls facing Rose Avenue,
no required step backs from the street, all of the mass of the building facing
the adjacent neighbors’ properties, and has not provided a detailed
explanation of what services will be provided on-site to residents and in the
ground-floor corporate office for nonresidents, which may generate vehicular
traffic. Your department should call for a full environmental review.
6. The City of Los Angeles and California Coastal Commission
have already set a precedent for mixed-use projects with a residential density
bonus on Rose Avenue and this project is inconsistent with that precedent.
On
August 9, 2005 The California Coastal Commission approved a precedent-setting
mixed-use project which included a density bonus project with 70 residential
units located at 512 Rose Avenue after an appeal was filed and a substantial
issue was found. The De Novo Permit Special Conditions relating to the project
set various building design conditions; these same conditions should apply to the
720 Rose Project and the design should be modified as follows:
Building Design: The 720 Rose
project should be designed with a varied and articulated facade that provides
visual interest to pedestrians. Frequent windows and the primary ground floor
entrances for the residential units shall face the streets. Porches, bays and
balconies are encouraged, consistent with the City's setback requirements
- Building Height: The 720 Rose project should be limited to three stories with a 33-foot high flat roof. Placing the residential portion of the project on top of the commercial portion does not give the applicant a right under the density bonus to a 40 foot height, just a 30 foot height. The applicant should be told to remove the corporate office space or remove one floor of residences.
- Landscaping: The 720 Rose project should be designed with landscaping in order to enhance visual quality. To preserve water, the side of the project facing the public street, Rose Avenue, should be landscaped with large canopy street trees and low water use plants, consistent with City requirements.
- Parking: With a reduction to 33 feet in height as recommended above, the number of units would be reduced to 22, so project parking requirement should be:
a.
VCHC
corporate ground floor offices - 10 spaces
b.
one space for
each resulting affordable unit or 22 spaces
c.
two (2) spaces
for the manager’s unit, and
d.
¼ guest
parking space per unit - equaling 6 parking spaces - for a total of 40 spaces.
The additional required parking should be provided
below grade.
Having managed 160 units of
affordable housing in the San Fernando Valley for five years I know from
experience that while homeless individuals usually move in without a vehicle,
this does not remain the case in many instances. As they stabilize their situation, receive
benefits and job training, and eventually obtain employment, one of their first
purchases is a vehicle. There also is
the likelihood that some of the eventual residents of the Rose Apartments will
be former “car campers;” by definition they will arrive with a vehicle. We have seen this here in Venice before. During Councilman Bill Rosendahl’s tenure,
one of the first vehicle dwellers that PATH moved into an apartment in a Breezes
del Mar building on California Avenue at Electric Avenue parked his empty camper
across the street from the building for months, taking two parking spaces away
from residents.
Thank you for your consideration of our views on this project.
Sincerely,
Mark Ryavec
Mark Ryavec, President