General Information About the Contents of This File

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.

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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. Since there is limited space where new buildings can be added, the flat roof of the automated parking garage is a viable site for revitalization.

B. There are exceptional circumstances or conditions applicable to the subject property that do not apply generally to other properties in the CPIO District.

According to the Venice/National TOD Subarea Chapter of the CPIO, "the intent of the Supplemental Development Regulations in this Chapter is to facilitate revitalization of properties that can capitalize upon proximity to the Culver City Station of the Metro Expo Line ... " The City of Culver City has undergone a massive revitalization effort in the last five years including the Platform retail/office complex located at Washington Boulevard and Landmark Street, the Ivy Station mixed-use development located at Washington Boulevard and National Boulevard and the Apple TV headquarters located at Washington Boulevard and National Boulevard.

But, unlike the other lots of the same Subarea, the Project Site is improved with a brand new fully automated parking garage. The two-year construction of the automated parking facility

Page 3 of 7 was finalized in 2017 and accommodates 254 parking spaces (both required and non required) for employees of the Helms Bakery District. The benefits of automated parking structures are that more parking can be accommodated in a smaller amount of space and the volume and visual impact of the parking structure is minimalized due to the lack of need for parking ramps, back up clearance, and internal circulation. The automated parking structure created a surplus of parking spaces on the Project Site and consequently, parking for the new office space is already available so tenants would not be forced to park in the nearby residential neighborhood.

The Applicant's property, in which an existing large scale commercial use sits across the street from residential uses, is unlike any other properties within the CPIO area. Here, the long-extant commercial campus enjoys uses and building heights that pre-date the CPIO, and the transitional height requirements here, on top of an existing structure, would not provide any practical benefit to the Hutchinson residential uses.

C. An exception from the CPIO regulation is necessary for the preservation an enjoyment of a substantial property right or use generally possessed by other property within the CPIO District in the same zone and vicinity.

The Project Site is located within Parcel Group C of the Venice/National TOD Subarea of the CPIO District. Parcel Group C is a Neighborhood Commercial land use subarea that consists of a portion of the Helms Bakery District between Helms Avenue and a 0.2-mile stretch of the north side of Venice Boulevard between Curtis Avenue and Hutchison Avenue.

The portion of Parcel Group C on the north side of Venice Boulevard consists of small lots, approximately 100 feet in depth, ranging in size from approximately 1, 700 square feet to approximately 2,500 square feet and improved with surface parking, a non-profit community facility and one-story commercial buildings. This area is either adjacent to residentially zoned lots or across an alley from residentially zoned lots. The Project Site, however, is a 48,845 square foot lot improved with a 45-foot automated parking garage and office/retail uses and across the street from residentially zoned lots.

The regulation for Parcel Group C adjacent to residentially zoned lots is more lenient than for the Project Site, which is across the street from residentially zoned lots. For adjacent lots, the regulation states that buildings must be stepped back one foot for every one foot in building height as measured 15 feet above grade at the shared property line. In effect, the rest of Parcel Group C can achieve 30 feet in height at 15 feet from the residential property line.

However, this is not the case for the Helms Bakery District. The regulation is to set new construction greater than 30 feet in height back from the residentially zoned properties a total of 100 feet, which would include 50 feet of public right-of-way and 50 feet of private property. If the same rule was applied to the other properties in Parcel Group C, no development would be permitted above 30 feet since the lots north of Venice Boulevard are only 100 feet long to begin with. Thus, the lots in the same Parcel Group of the Subarea

Page 4 of 7 would be permitted to build to a higher maximum building height than the Project. So, the Exception is necessary for the Applicant to utilize a substantial property right possessed by the other properties in the same Parcel Group.

D. The granting of an exception will not be detrimental to the public welfare.

The requested CPIO Exception would not interfere with the existing development in the residential zone across the street. The residential area is generally bound by commercial corridors on Venice Boulevard and Washington Boulevard and the Helms Bakery District, which has been a commercial/industrial area since the 1930s. This area is located in the RD2-1 zone and improved with a mix of single-family homes and duplexes. Residents who purchased or rented these homes and duplexes did so with the full knowledge that they would be living across from a light industrial and commercial complex.

As detailed in the Shade and Shadow Study dated September 25, 2017, the height request would not be detrimental to the existing development in the residential zone. Shadow lengths are dependent on the height and bulk of the project's structural elements from which they are cast and the angle of the sun. The angle of the sun varies with respect to the rotation of the earth (i.e., time of day) and elliptical orbit (i.e., change in seasons). The longest shadows are cast during the winter months and the shortest shadows are cast during the summer months. Shadow impacts are dependent upon several factors, including local topography, the height and bulk of the project's structural elements, the sensitivity of adjacent land uses to shadow impacts, and the duration of shadow projections. Based on the Shade and Shadow Study, no shadow-sensitive uses would be shaded by project related structures for more than one hour in the winter or for more than two hours in the fall.

Rather, the Project would benefit the public welfare by attracting new high-paying jobs to the area and creating new tax revenue for the City of Los Angeles. New employees in the area would contribute to the pedestrian foot-traffic throughout the area and focus new commercial uses near transit. Additionally, new employees in the area would frequent the surrounding commercial businesses and uplift the local neighborhood economy.

Lastly, as part of the Helms Bakery District, the Project would support the maintenance of the historic-eligible warehouses that define the character of the neighborhood.

E. The granting of an exception will be consistent with the principles, intent and goals of the CPIO District and/or Subarea and any applicable element of the General Plan.

The CPIO outlines its purposes and intention. Some of the purposes listed in Section 3 of the CPIO are: * "To provide supplemental development regulations tailored to the Community Plan Area to ensure that development enhances the unique architectural, environmental and cultural qualities of the Community Plan Area," (Purpose A).

Page 5 of 7 * ''To promote and facilitate revitalization of properties that can capitalize upon close proximity to the La Brea, Farmdale, La Cienega and Culver City stations along the Mid-City Exposition Light Rail Transit Corridor (Expo Line)" (Purpose D).

* "To support transit-oriented business districts outside of the City Center where emerging and innovative commercial, office, and "clean-tech" uses can locate within contextually appropriate medium intensity transit hubs." (Purpose S).

The CPIO regulations were drafted to encourage revitalization along the Expo Line transit corridor and facilitate the creation of new unique architecture that supports emerging industries. The Project, which would be constructed within 1,500 feet of the Culver City Metro Station, addresses the purposes detailed in the CPIO. By creating new architectural experience within a historic warehouse district, the Project would attract emerging industries. The architectural design would create an enhanced internal experience. The office would have an open quality that new industries prefer, designed with long-spanned roof to allow a flexible layout and generous use of glazing.

The general purposes and intent of the Venice/National TOD Parcel Group CPIO District and its regulations is outlined in the Overview section of Chapter VI of Ordinance 184,794, which states:

"The Venice/National Transit Oriented District (TOD) CPIO District Subarea facilitates the continued formation of a vibrant community commercial center that serves as both a gateway entrance into the City as well as a destination where a mix of uses including restaurant, retail, commercial office, and "high-tech" uses can be found within a medium to high intensity TOD area.

The intent of the Supplemental Development Regulations in this Chapter is to facilitate revitalization of properties that can capitalize upon proximity to the Culver City Station of the Metro Expo Line ... "

The purpose of the Venice/National TOD Subarea and associated supplemental development regulations are to facilitate revitalization of properties to capitalize upon proximity to the Culver City Station of the Metro Expo Line. The Project would facilitate viable, Class A commercial space accommodating new industries identified by the CPIO like "high-tech." Project features designed to attract these industries include limited columns to create a flexible office space, innovative roof structure and ornamental trellis, and expansive views of the City of Los Angeles and the Santa Monica Mountains.

Thus, granting the CPIO Exception will be consistent with the principles, intent and goals of the CPIO District and the Venice/National TOD Subarea.

Page 6 of 7 For the above stated reasons, we submit that the factual circumstances support the findings necessary for an Exception to the CPIO. The Applicant has not encountered community opposition to its proposed office use, the Project received support from the South Robertson Neighborhood Council and the neighboring residents have stated that they prefer completely enclosed office uses atop the existing building rather than set back offices that might incorporate outdoor activities and other sources of noise and disruption. A determination that the facts support the necessary findings will allow the Applicant to continue to provide for the revitalization of the community and address the demand for creative office space in an orderly, well-planned and measured fashion.

Thank you for your attention to this matter. Please do not hesitate to contact me at any time with any questions or comments you may have.

Sincerely,

Jamie Poster Craig Lawson & Co., LLC

CC: The Honorable Herb Wesson, Council District 11 Jordan Beroukhim, Council District 11 Alan Como, Department of City Planning Craig Lawson, Craig Lawson & Co., LLC

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Page 7 of 7 DAY OF HEARING SUBMISSIONS

The following submissions by the public are in compliance with the Commission Rules and Operating Procedures (ROPs), Rule 4.3c. 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 submissions distributed to the Commission during the Commission Meeting are included in this file.

Material which does not comply with the submission rules is not distributed to the Commission.