General Information About the Contents of This File
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GENERAL INFORMATION ABOUT THE CONTENTS OF THIS FILE Submissions by the public in compliance with the Commission Rules and Operating Procedures (ROPs), Rule 4.3, are distributed to the Commission and uploaded online. Please note that “compliance” means that the submission complies with deadline, delivery method (hard copy and/or electronic) AND the number of copies. Please review the Commission ROPs to ensure that you meet the submission requirements. The ROPs can be accessed at http://planning.lacity.org, by selecting “Commissions & Hearings” and selecting the specific Commission. All compliant submissions may be accessed as follows: • “Initial Submissions”: Compliant submissions received no later than by end of day Monday of the week prior to the meeting, which are not integrated by reference or exhibit in the Staff Report, will be appended at the end of the Staff Report. The Staff Report is linked to the case number on the specific meeting agenda. • “Secondary Submissions”: Compliant submissions received after the Initial Submission deadline up to 3:00 p.m. Thursday of the week prior to the Commission meeting are contained in this file and bookmarked by the case number. • “Day of Hearing Submissions”: Compliant submissions after the Secondary Submission deadline up to and including the day of the Commission meeting will be uploaded to this file within two business days after the Commission meeting. Material which does not comply with the submission rules is not distributed to the Commission. ENABLE BOOKMARKS ONLINE: **If you are using Explorer, you need will need to enable the Acrobat toolbar to see the bookmarks on the left side of the screen. If you are using Chrome, the bookmarks are on the upper right-side of the screen. If you do not want to use the bookmarks, simply scroll through the file. If you have any questions, please contact the Commission Office at (213) 978-1300. SECONDARY SUBMISSIONS The following submissions by the public are in compliance with the Commission Rules and Operating Procedures (ROPs), Rule 4.3b. Please note that “compliance” means that the submission complies with deadline, delivery method (hard copy and/or electronic) AND the number of copies. The Commission’s ROPs can be accessed at http:// planning.lacity.org, by selecting “Commissions & Hearings” and selecting the specific Commission. All materials in response to a Recommendation Report or additional comments which were received by the Commission Executive Assistant electronically no later than 3:00 p.m. Thursday of the week prior to the Commission meeting AND which do not exceed ten (10) pages including exhibits are included in this file. Material which does not comply with the submission rules is not distributed to the Commission. ENABLE BOOKMARKS ONLINE: **If you are using Explorer, you need will need to enable the Acrobat toolbar to see the bookmarks on the left side of the screen. If you are using Chrome, the bookmarks are on the upper right-side of the screen. If you do not want to use the bookmarks, simply scroll through the file. If you have any questions, please contact the Commission Office at (213) 978-1300. Craig Lawson & Co., LLC Land Use Consultants February 14, 2019 VIA E-MAIL South Los Angeles Area Planning Commission Department of City Planning City of Los Angeles 200 N. Spring Street, Rm 532 Los Angeles, CA 90012 RE: 3235 Hutchison Avenue Office Addition APCS-2017-3071-CPIOE-ZV-CPIOA-WDI Agenda Item #6, February 19, 2019 Agenda Rebuttal to Recommendation Report Dear Members of the South Area Planning Commission: We represent Walter N. Marks, Inc (the "Applicant") with respect to entitlement matters pertaining to an office addition to the roof of an existing parking garage at the Helms Bakery District (the "Project") located at 3235 Hutchison Avenue in the City of Los Angeles (the "Project Site"). We have reviewed the Recommendation Report prepared by the Department of City Planning staff for your hearing on Tuesday, February 19, 2019, which is Item 6 on your agenda. While we appreciate the staff recommends your Commission support most of the requests for discretionary approval, we respectfully disagree with the staff recommendation to deny the requested Exception from the Community Plan Implementation Ordinance (CPIO) for the West Adams-Baldwin Hills-Leimert Community Plan. We believe that the findings for the CPIO Exception can be made, as further discussed in this letter. The Helms Bakery District is a unique campus in the City of Los Angeles The Helms Bakery District has been a catalyst for the creative office renaissance surrounding the Culver City Metro Station since the Applicant's family purchased the Helms Bakery warehouses in the 1970's. During three generations of family ownership, the Applicant's family has converted the iconic warehouse buildings into a thriving design district and creative office industry cluster. As home to HD Buttercup, Room & Board, and several 3221 Hutchison Avenue, Suite D, Los Angeles, CA 90034 (310) 838-2400 Phone (310) 838-2424 Fax other high-end furniture stores, the Helms Bakery attracts patrons from all over the City. The creative office spaces cater to design firms, architects, tech start-ups and other creative economies. The Helms Bakery District has become more than just a shopping district and employment center, but it is also home to two of Los Angeles's top restaurants that have appeared year after year on Jonathan Gold's "101 Best Restaurants" list. At the Helms Walk, in the center of the Helms Bakery District, the Applicant hosts free movie nights, displays art installations, and supports a myriad of other activities creating a vibrant community center. As the surrounding area grows amidst a creative industry boom, with offices currently under construction nearby for Amazon Studios and Apple TV, the Applicant proposes to again commit to the emergence of the neighborhood by constructing new creative office space to compete with the Hayden Tract in Culver City, the Ivy Station Project (under construction) and the Culver City Steps (under construction). In order to capitalize on emerging industrial and creative office sectors, as encouraged by the West Adams - Baldwin Hills - Leimert Community Plan, the Applicant respectfully requests that you approve the CPIO Exception. We acknowledge that the Recommendation Report suggests approval of the Applicant's requests for a zone variance, overlay adjustments and waiver of dedications. Nonetheless, we strongly believe that the findings for the Applicant's requested Exception from the CPIO Guidelines relative to Transitional Height can be also be made and the Exception should be approved. A. There are practical difficulties or unnecessary hardships resulting from the regulations. The Recommendation Report suggests the necessary findings for a transitional height exception cannot be made because "the Applicant could still provide office space on top of the parking garage and comply with the transitional height regulations." We respectfully submit that this this statement is simply not true. In practical term, the Applicant must design a leasable office space, which requires the office space to achieve a certain square footage, allow for desirable office configuration and have an appealing aesthetic. It is not financially feasible to design a smaller, oddly configured office space. Thus, the Applicant cannot still provide office space on top of the parking garage and comply with the transitional height regulations. The Recommendation Report's conclusion is to set the office addition back from the edge of the parking garage "to protect existing residential properties." The Applicant has worked with the surrounding neighbors for many years as part of its operation and development of various elements of the Helms Bakery District, including the parking building that is the subject of the Application. These neighbors have unequivocally expressed that they prefer an enclosed office space to an open outdoor patio. But, the setback suggested by the Recommendation Report would open up an outdoor patios and common areas. It is physically impossible to respect the 50-foot setback, as recommended by Department of Page 2 of 7 City Planning staff, and also enclose the outdoor space as recommended by the residential neighbors. The Recommendation Report recognizes there is an existing 45-foot structure within the transitional height area, but it does not recognize the difference between ground-up construction compared to constructing an addition to the roof of an existing building. There is no evidence to support that the recommended 50-foot setback would have less of an impact than the proposed 25-foot setback. If this were new construction, one could understand how this might be the case. But, in reality, the "setback" in question would function as a stepback on the roof of a building that already exists within the transitional height area in question (this building was constructed by-right prior to the adoption of the CPIO). The Recommendation Report describes the Applicant's parking structure and office addition as "incompatible" land uses that threaten the residential uses on the east side of Hutchison Avenue. The existing parking structure provides parking to employees at the Helms Bakery District, thereby removing impacts of employees circling the streets looking for parking and freeing on-street parking spaces for the residential neighborhood. Additionally, the office use already exists throughout the Helms Bakery District and has proven to complement the residential neighborhood since the offices are typically in use during working hours when residents are not home and the offices are closed when the residents would return home from work. As a result, the existing residential uses and the proposed office uses are compatible land uses. The Applicant continues to maintain the iconic warehouse buildings that cover the majority of the Helms Bakery District with retail, restaurant and office uses. The Applicant is trying to accommodate demand for new offices, but cannot develop new office space elsewhere within the Helms Bakery District without compromising the historic eligibility of the architecturally distinct warehouses from the 1930's.