Errata to the EIR

1 Introduction

Project Title: 2110 Bay Street Mixed-Use Project

Document Type: Errata to the EIR for a new mixed-use residential and commercial in-fill development (the Project).

Environmental No.: ENV-2016-3480-EIR

State Clearinghouse: 2017031007

Project Location: 2100, 2130 Bay Street and 2141 Sacramento Street, Los Angeles, CA 90021 (Project Site or Site)

Lead Agency: City of Los Angeles, Department of City Planning 221 N. Figueroa Street, Suite 1350, Los Angeles, CA 90012

Applicant: Bay Capital Fund, LLC

Prepared By: CAJA Environmental Services, LLC 15350 Sherman Way, Suite 315, Van Nuys, CA 91406

The City of Los Angeles (City) prepared an Environmental Impact Report (EIR) pursuant to the California Environmental Quality Act (CEQA) for the 2110 Bay Street Mixed-Use Project (Project) to assess potential environmental impacts of the Project, as described below.

The EIR is comprised of two parts, the Draft EIR and the Final EIR. A Draft EIR was made available and circulated for public review and comment, pursuant to the provisions of CEQA, for a 46-day public review period from November 8, 2018 to December 26, 2018.1 The Final EIR was released on April 2, 2019, and included responses to comments and text revisions to the Draft EIR based on input received.2

The EIR concluded that with mitigation, all of the Project’s environmental impacts would be less than significant, with the exception of a significant and unavoidable environmental impacts related to traffic (intersection impact at Soto Street and Whittier Boulevard).

On May 6, 2019 the Southwest Regional Council of Carpenters filed an appeal against the Project’s Vesting Tentative Tract Map. The appeal focused on three reasons:

• Improper Spot Zoning.

1 https://planning.lacity.org/eir/2110_Bay_Street/deir/DEIR%202110%20Bay%20Street%20Mixed%20Use%20Project.html 2 https://planning.lacity.org/eir/2110_Bay_Street/FEIR/FEIR%202110%20Bay%20Street%20Project.html

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• Inconsistent findings with relevant policies regarding preservation of industrial-zoned land.

• Cumulative displacement of industrial developments from the Project and Related Projects.

The Appeal relies upon and refers to a trial court statement of decision in Arts District Community Council Los Angeles, et al. v. City of Los Angeles et al. (Case No. BS172014). This Errata contains detailed responses to all of the points raised in the Appeal based upon that statement of decision. It is important to note that the statement of decision is not legal precedent or in any way binding on the City. That case has been dismissed with prejudice. Neither a writ nor a judgment was entered in that case. Nonetheless, this Errata addresses and resolves the concerns raised in the statement of decision.

The City has prepared this Errata to provide responses to the various issues raised in the Appeal along with providing clarifications to the Project that will be considered by the decision makers prior to approving, approving with conditions, or disapproving the Project.

In support of the Appeal responses, the Applicant retained CBRE to address the issues raised in the Appeal relative to the Project’s requested land use changes and the potential effects of that change on neighboring and regional land uses, and on the opportunities for manufacturing employment. The resulting “CBRE Report” is provided as “Consulting Report, CBRE, September 30, 2019”, and included as Attachment A to this Errata.

In addition, the Applicant’s representative, Craig Lawson & Company (CLC), provided information regarding existing land uses within proximity to the Project Site to understand the extent to which complementary/compatible non-manufacturing uses have evolved alongside traditional industrial and manufacturing uses. Non-manufacturing uses are uses also permitted in the City of Los Angeles Commercial or Residential zoning districts, as opposed to traditional manufacturing uses which are only permitted in Industrial or Manufacturing zoning districts. The resulting “CLC Memo” is provided as “Memo to Bay Capital Fund, LLC, from Craig Lawson & Co., LLC, October 7, 2019”, and included as Attachment B to this Errata. This information and data has been independently reviewed and verified in preparation of this Errata, prior to its inclusion. 2 Regulatory Information

This Errata makes minor technical corrections and clarifications to the EIR for the Project. These modifications clarify and refine the EIR and provide supplemental information to the City decision-makers and the public. CEQA requires recirculation of a Draft EIR only when “significant new information” is added to a Draft EIR after public notice of the availability of the Draft EIR has occurred (refer to California Public Resources Code Section 21092.1 and CEQA Guidelines Section 15088.5), but before the EIR is certified. Section 15088.5 of the CEQA Guidelines specifically states:

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New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation includes, for example, a disclosure showing that:

• A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.

• A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted to reduce the impact to a level of insignificance.

• A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it.

• The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

CEQA Guidelines Section 15088.5 also provides that “[r]ecirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR... A decision not to recirculate an EIR must be supported by substantial evidence in the administrative record.

The information added pursuant to this Errata does not disclose a new significant environmental impact that would result from the Project or from a new mitigation measure or substantial increase in the severity of an environmental impact. Nor does it contain significant new information that deprives the public of a meaningful opportunity to comment upon a substantial adverse effect environmental effect of the Project or a feasible way to mitigate or avoid such an effect that the Applicant has declined to adopt. Additionally, information provided in this Errata does not present a feasible Project alternative or mitigation measure considerably different from others previously analyzed in the EIR. All of the information added pursuant to this Errata merely clarifies, corrects, adds to, or makes insignificant modifications to information in the EIR. The City has reviewed the information in this Errata and has determined that it does not change any of the basic findings or conclusions of the EIR, does not constitute “significant new information” pursuant to CEQA Guidelines Section 15088.5, and does not require recirculation of the Draft EIR. 3 Appeal Issue Responses 3.1 Spot Zoning

The 2006 L.A. CEQA Thresholds Guide includes as one of its land use screening criteria: “Would the project result in a ‘spot’ zone”. If the answer to the screening question is yes, further analysis is required in an Initial Study, MND, or EIR. Even if a project could involve a spot zone,

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that does not in and of itself result in a significant land use impact.

The L.A. CEQA Thresholds Guide defines spot zoning as occurring "when the zoning or land use designation for only a portion of a block changes, or a single zone or land use designation becomes surrounded by more or less intensive land uses."3 Spot zoning arises where a small parcel is restricted and given lesser or greater rights than the surrounding property, creating an "island" in the middle of a larger area of other uses.4

In this case, the Project would be developed on a large 1.78-acre site, and not on a small site. The requested General Plan Amendment from Heavy Industrial to Commercial Industrial and the elimination of floor area constraints creates a development site consistent, in terms of uses and intensities, with recent successful developments in the area. These developments, both conversion and ground up, are consistent with the Central City North Community Plan’s description of the Artists-in-Residence Subarea District, whose southern boundary is one block north of the Project Site at Violet Street, as an area “primarily made up of old warehouses now converted to artists lofts and studios.” The description of the Artists-in-Residence District also notes that the Community Plan “encourages the continued and expanded development of a thriving artists-in-residence community.”5

The Appeal does not address the legal standard for the spot zone claim, which provides that the City’s rezoning would be upheld unless it is arbitrary, capricious, or entirely lacking in evidentiary support. (Foothill Communities Coalition v. County of Orange (2014) 222 Cal.App.4th 1302, 1309.) The Courts recognize that "the essence of spot zoning is irrational discrimination," and that spot zoning usually "involves a small parcel of land." (Id. at 1311.) The "larger the property" and if the property "is not an island but is connected on some sides to a like zone," the harder it is to sustain an allegation of spot zoning. (Id.)

The Project Site is approximately 1.78 acres and the nearby area contains a mix of industrial, residential, and commercial uses, including former industrial sites that have been redeveloped or replaced with arts-focused live-work projects within 0.5 mile, as noted in the related projects listed in Section III, Environmental Setting, Table III-2, of the Draft EIR and shown in Figure III-2 of the Draft EIR. In addition, the CBRE Report and CLC Memo both provide evidence of the substantial number of specific projects and the evolution of the light industrial and manufacturing land use patterns in the area with compatible and complementary non-industrial land uses.

Thus, given the Project Site's size and surrounding uses that are similar to the Project's mix of uses, amending the Project Site's zone would not create a "small island" subject to more or less restrictive uses than those currently surrounding the site. As a result, there would be no "spot zoning."

3 L.A. CEQA Thresholds Guide, page H.2-2. 4 Foothill Communities Coalition v County of Orange (2014) 222 CA4th 1302 5 Central City North Community Plan P. 1.3.

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In addition, the Courts uphold spot zoning "where rational reason in the public benefit exists for such a classification." (Foothill Communities, supra, 222 Cal.App.4th at 1311.) The Project has numerous public benefits, such as much-needed housing, open space, commercial and office uses. The California Second District Court of Appeal has rejected spot zoning arguments asserted against the City of Los Angeles. In Citizens Coalition Los Angeles v. City of Los Angeles (Aug. 23, 2018) Cal.App.5th, the Court confirmed that even if spot zoning is assumed, it is valid if "any" rational reason in the public benefit exists for the classification. With the comment’s failure to show any "irrational discrimination," the spot zone argument should be rejected.

As such, the Project would not constitute spot zoning. In any event, as noted, the creation of a spot zone does not on its own result in a significant land use impact; it merely requires further analysis. The Draft EIR includes such analysis and assesses whether the Project would result in a significant impact under the CEQA Appendix G thresholds. As set forth in the Draft EIR, the Project would not physically divide an established community, conflict with an applicable plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, or conflict with any applicable habitat conservation plan or natural community conservation plan. Therefore, the Project would not result in a significant land use impact even if it were to result in a spot zone.

3.2 Industrial Displacement

According to the Central City North Community Plan, there are 1,180 acres (approximately 60 percent of the 2,005-acre total) of industrially zoned property in the Community Plan area. The Project Site comprises 1.78 acres, or only approximately 0.15 percent of the industrially-zoned land and approximately 0.09 percent of the total land in the Community Plan area. The conversion of industrial land is an economic issue that is not within the scope of CEQA review unless it results in adverse impacts on the physical environment. While the Project will remove the existing surface parking lot and manufacturing building (the open-air industrial shed will be incorporated into the new development) on the Project Site, these uses are vacant (and have been since at least 2014) and do not support a business. Thus, there would be no need to relocate to other sites in the area.

Per the CBRE Report, the land use pattern, both in the immediate neighborhood of the Project Site and in the larger Arts District, has already evolved from its historic industrial and manufacturing uses to light industrial and manufacturing uses and new technologies along with compatible and complementary non-industrial uses including residential, creative office, and related retail/cultural/entertainment uses. This evolution reflects larger employment and economic trends in the City. Therefore, the Project will not have any material effect on future conversions of industrial land to compatible and complementary non-industrial uses including office, residential, or commercial uses in the Arts District. Additionally, it is unlikely that the Project Site could in fact attract any viable industrial use.

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3.3 Existing Environmental Setting

Section IV.G, Land Use and Planning of the Draft EIR provides an analysis of the changes proposed to the land uses at the Project Site and the Project’s compatibility with surrounding uses. The intent of the compatibility analysis is to determine whether the Project would be compatible with surrounding uses in relation to use, size, intensity, density, scale, and other physical and operational factors. The compatibility analysis is based on aerial photography, land use maps, and field surveys in which surrounding uses have been identified and characterized. The analysis addresses general land use relationships and urban form, based on a comparison of existing land use relationships in the vicinity of the Project Site under existing conditions at the time of the Notice of Preparation was issued, to the conditions that would occur with implementation of the Project. The L.A. CEQA Thresholds Guide requires that a project’s land use compatibility be analyzed with the surrounding existing uses. Functional compatibility can be defined as the capacity for adjacent, yet dissimilar, land uses to maintain and provide services, amenities, and/or environmental quality associated with such uses. Potentially significant functional land use compatibility impacts may be generated when a project hinders the functional patterns of use and relationships associated with existing land uses.

The surrounding area is characterized by a mix of light industrial and manufacturing uses alongside compatible and complementary non-industrial uses including commercial, office, restaurant, and residential uses. The Project would combine these compatible and complementary non-industrial uses at one site. Thus, while the Project would change the character of the land uses on the Project Site, the Project would increase housing and employment opportunities in the area, and would provide greater density near transit services, including existing bus lines. In addition, the Project would be consistent with existing uses nearby that include Joint Living and Work Quarter, commercial and office use, and would not interfere with functionality of the Site.

According to the Central City North Community Plan, there are 1,180 acres (approximately 60 percent of the 2,005-acre total) of industrially zoned property in the Community Plan area. The Project Site comprises 1.78, or only approximately 0.15 percent of the industrially-zoned land and approximately 0.09 percent of the total land in the Community Plan area.

In fact, as demonstrated in the attached CBRE Report, the land use patterns, both in the immediate neighborhood of the Project Site and in the larger Arts District, has evolved from its historic industrial and manufacturing uses to light industrial and manufacturing uses and new technologies alongside compatible and complementary non-industrial uses including residential, creative office, and related retail/cultural/entertainment uses. This evolution reflects larger employment and economic trends. The Project is merely a continuation of this evolution. Additionally, the Project would increase pedestrian connectivity at the street level. The surrounding uses (office, commercial, proposed private club hotel) are compatible with the Project’s proposed land uses (live/work, commercial, office).

In addition, as demonstrated in the attached CLC Memo, utilizing Los Angeles Department of Building and Safety (“LADBS”) building records, CLC obtained as many non-manufacturing

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building permits and Certificates of Occupancy available within an area surrounding the site bounded by Palmetto Street to the north, the Los Angeles River to the east, Interstate 10 Freeway to the south and Alameda Street to the west (“Study Area”). According to the information CLC obtained and reviewed, the Study Area contains 1,107 parcels of land. The permits were categorized into the following use groups: office, commercial (including stores and mercantile), hotel, restaurant (including catering), residential, joint live work quarters (“JLWQ”), mixed-use (including JLWQ), mixed-use nonresidential, gas station, medical office, institutional and parking. Using these categories, along with a corresponding color, the various uses were plotted on the attached Radius Map (See CLC Memo Exhibit A – Land Use Map Based on Building Permit Records). Parcels with no color are assumed to be industrial/manufacturing uses.

As indicated by the large diversity of colors found on the Land Use Map, a significant percentage of the Study Area’s uses are compatible and complementary non-industrial/non- manufacturing uses which are spread throughout the Study Area. According to CLC’s verified research, approximately 30% (314 of 1,107 parcels) of the parcels reviewed have building permits issued by the Department of Building and Safety for non-manufacturing uses. Approximately 10% of the total parcels contain a mix of uses, such as office, retail and restaurant, but not including JLWQ units. Restaurants are located on approximately 9% of the Study Area’s parcels as standalone uses or as part of a mixed-use project. Office (6.6%) and retail (7.6%) uses combined cover up over 14%6 of the parcels. Close to 7% of the parcels are developed with either JLWQ units that are part of mixed-use project (5%) or only contain JLWQ units (1.7%). These uses which are permitted in Commercial zoning districts demonstrates the evolution in the Study Area of land use patterns.

CLC made the following observations after reviewing the detailed LADBS building permit information:

• Joint Live/Work Uses: A substantial number of properties around 7th Street between Alameda Street and the LA River are JLWQ projects (purple) or mixed-use complexes that include JLWQ (yellow) uses including:

o Example of large mixed-use developments include a seven-story building with ground floor retail and 119 JLWQ units at 1855 Industrial Street (permitted issued in 2005), and an eight-story building with ground floor retail and 104 JLWQ units at 1850 Industrial Street (permitted issued in 2009).

o Many of the JLWQ projects are small to medium in scale and are characterized by 2- to 4-story buildings that have been adaptively reused. Examples include a property at 2101 7th Street (permitted issued in 1955) with 39 JLWQ units, a property at 712 Santa Fe Avenue (permitted issued in 2012) with 9 JLWQ units and ground floor restaurant, a property at 720 Santa Fe Avenue (permitted issued in 2004) with 22 JLWQ units, and a property at 2038 Bay Street (permitted issued in 2011) with 4 JLWQ units.

6 Includes mixed use projects and standalone uses.

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• Commercial Uses: A variety of single use commercial (red), mixed use without JLWQ (green) and restaurant (burnt orange) are scattered throughout the vicinity including:

o Many well know restaurants including Bestia at 2121 East 7th Place (permitted issued in 2013), Brera Ristorante located at 1331 E 6th Street (permitted issued in 2011) and the Church & State located at 1850 Industrial Street (permitted issued in 2009).

o The property at 634 Mateo Street (permit issued in 2018) is occupied by a video game arcade and the property at 1005 Mateo Street (permit issued in 2018) is occupied by a large plant nursery.

o The property located at 584 Mateo Street (permit issued in 1995) is developed with a retail establishment.

o 661 Imperial Street (permitted issued in 2009) contains a grocery store, and there is a fish market at 584 Mateo (permits issued in 2009).

o The @Mateo project, located at 555 Mateo Street (permit issued in 2016) contains approximately 132,000 square feet of office, retail and restaurant space.

o A private club, known as the Soho House, offering hotel, restaurant and bar amenities, located a 1000 Santa Fe Avenue (permitted issued in 2017).

• Office use: A variety of office uses (pink) scattered throughout the study area with a high concentration located near the Project site south of 7th Street on. Notable properties with office space include:

o 2159 Bay Street, abutting the site, (permit issued in 2016) is developed with a high tech office use (Hyperloop).

o The Ford Factory renovation, located at 777 Santa Fe Avenue (permit issued in 2017), is an example of a successful conversion of an existing underutilized manufacturing building and converting it to a create office structure.

o 2222 Damon Street (permitted issued in 1980), 1407 6th Street (permitted issued in 1957) and 1220 6th Street (permitted issued in 1951) are examples of office uses that have been part of this community for decades.

• Institutional uses: The following Institutional uses (turquoise blue) can be found in the Study area:

o A charter elementary school at 1617 7th Street (permitted issued 2006) and Metropolitan High School is located at 727 Willow Street7.

o An art gallery at 1018 Santa Fe Avenue (permit issued in 2005). In summary, the land use patterns, both in the immediate neighborhood of the Project Site and in the larger Arts District, has evolved from its historic industrial and manufacturing uses to light industrial and manufacturing uses and new technologies alongside compatible and complementary non-industrial uses including residential, creative office, and related

7 This is an LAUSD school and is not required to obtain a City of LA permit.

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retail/cultural/entertainment uses. This evolution reflects larger employment and economic trends. 3.4 Proposed and Approved Developments Prior to the NOP

The following developments included zone changes and further demonstrate the ongoing evolution of the Arts District with light industrial and manufacturing uses and new technologies alongside compatible and complementary non-industrial uses including residential, creative office, and related retail/cultural/entertainment uses. It should be noted that each development was filed and issued a certificate of occupancy well before the Project’s Notice of Preparation was released in March 2017. The City has approved the following projects, which shows a demand to provide compatible and complementary non-industrial uses in former industrial- zoned lots.8

• One Santa Fe at 300 S. Santa Fe Avenue, a 6-story mixed-use project with 439 apartment units, 17 live/work units, and approximately 27,520 square feet of ground floor commercial space. The application was submitted on February 15, 2007 and a certificate of occupancy was issued on March 12, 2015.

• 905 E. 2nd Street, a 5-story mixed-use project with 320 apartment units and 15,576 square feet of commercial space. The application was submitted on October 2, 2006 and a temporary certificate of occupancy was issued on July 8, 2016.

• 1855 Industrial, is an adaptive reuse project for a change of use to 119 Live/Work units and 5,203 square feet of retail space. The application was submitted on July 29, 2002 and a certificate of occupancy was issued on May 17, 2005.

• The Savoy project, located along the eastside of Alameda Street, between 1st and 2nd Streets within the Arts District, was approved for a zone change from CM and M3 to C2 in order permit a development that consists of 500 multi-family residential units.

• The Mega Toys project, located at 2nd Street and Garey Street within the Arts District, was approved for a zone change from CM to C2 in order to permit a mixed-use development for 320 dwelling units and 15,576 square feet of commercial space.

• The SoHo House DTLA, located at 1000 S. Santa Fe (adjacent to the Project Site), was approved on February 9, 2016 for a Conditional Use Permit to allow the sales of alcoholic beverages and live entertainment in conjunction with a private club to include rooftop dining and pool for an existing 5-story industrial building adjacent to the east of the Project Site. The SoHo House is expected to open in August 2019.9

8 Consulting Report, CBRE, September 30, 2019, Addendum A. 9 http://www.ladowntownnews.com/development/soho-warehouse-to-open-next-month/article_1b3de2ee-a1da-11e9-9778- 93ef9b7be0ac.html and http://sohowarehouse.com/

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In addition, the following developments are recent new construction and/or requesting a change of use:

• 1800 7th Street, a 7-story mixed use project with 122 live/work units, 9,500 square feet of commercial space, and 5,885 square feet of arts production space, with a total floor area of 129,440 square feet. The application was submitted on July 27, 2016, and an effective date of zone change ordinance was issued on October 24, 2018.

• 710 Santa Fe, a conversion of a vacant historic fire house into a 10-room boutique hotel and restaurant and bar. The application was submitted on February 9, 2017, and an effective date of zone change ordinance was issued on March 25, 2018.

• 668 S. Alameda, a mixed-use development consisting of 475 live/work units and 61,200 square feet of ground floor commercial space. The application was submitted on September 20, 2016, and an effective date of zone change ordinance was issued on November 24, 2018.

• 408 Alameda, a change of use from manufacturing warehouse to 66-guest room boutique hotel, and 3,800 square foot restaurant, 840 square feet of retail, and 890 square-foot screening room. The application was submitted on September 26, 2016, and an effective date of zone change ordinance was issued on March 28, 2018.

• 100 N. Santa Fe, a change of use from vacant industrial building to eight condominium joint living and work Artist-In-Residence units. The application was submitted on January 7, 2005, and an approval date of April 14, 2005.

The City approvals show an ongoing trend through use of standard City zoning tools to compatible and complementary non-industrial uses in former industrial-zoned lots that pre-dates the Project by more than 10 years in keeping with various City policy documents including the 2007 Industrial Land Use Policy (ILUP) and updates to the Community Plan. The ongoing development of mixed-use projects and JLWQ projects in the general vicinity is beneficial for the City’s long-term fiscal and economic viability. The mixed-use Project will contribute to the City’s fiscal and economic viability, while revitalizing an area with compatible and complementary non- industrial uses that will be beneficial to local residents and light industrial and manufacturing uses. The new developments and conversions of aging industrial buildings to mixed-use projects that contain Live/Work units contribute to the revitalization of the economically depressed areas of the surrounding neighborhoods. Occupants of JLWQ projects in the industrial area contribute to the reduction of traffic congestion because they either establish home-based occupations or primarily commute by public transit to the numerous job opportunities in the downtown area. The development of the Artist-In-Residence District into more JLWQ units, creative office space and neighborhood serving commercial uses helps to achieve the City’s vision of a more livable city.

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A list of proposed development projects in the area of the Project Site was prepared based on information obtained from the City of Los Angeles Department of Transportation, City of Los Angeles Department of City Planning, City of Vernon Planning Department, recent traffic studies prepared in the area, and other third party research. A total of 60 potential related projects have been identified within the vicinity (approximately 1.5 mile radius) of the Project Site. These related projects are in varying stages of the approval/entitlement/development process and consist of a variety of land uses reflecting the diverse range of land uses in the vicinity of the Project Site. The list was obtained at the time of the Notice of Preparation (NOP) in March 2017 and includes proposed developments within the Arts District subarea.

Table 1 provides the related projects estimated total in land uses that were considered and Table 2 provides detailed land use programs and addresses on each of the 60 related projects. As shown, the only proposed industrial or manufacturing uses are two related projects in the neighboring City of Vernon to the south of the I-10 Freeway (Related Projects Nos. 59 and 60). The area around the Project Site has proposed developments that include residential, commercial restaurant, and hotel uses. Thus 58 of the 60 related projects are uses that are compatible and complementary non-industrial. Since the related projects list was drawn from applications provided to the City and LADOT prior to the Project, it demonstrates the evolution of the local land use patterns with light industrial and manufacturing uses and new technologies alongside compatible and complementary non-industrial uses including residential, creative office, and related retail/cultural/entertainment uses was occurring well before the Project was filed.

Table 1 Related Projects Land Uses Use Size City of Los Angeles Residential 15,870 units Retail, commercial, shopping uses, community, and similar style uses 854,936 square feet Office and similar style uses 2,779,623 square feet Market uses 242,098 square feet Restaurant, eating, drinking uses 336,558 square feet Hotel 1,300 rooms Theater uses 793 seats School uses 832 students City of Vernon Retail, commercial uses 13,835 square feet Industrial, manufacturing uses 66,000 square feet Source: Crain and Associates.

Table 2 Related Projects Locations and Descriptions No. Address/Location Size Unit Project Description 1 2901 E Olympic Boulevard Boyle Heights Mixed-Use Project (Wyvernwood)1 4,400 du Apartment

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Table 2 Related Projects Locations and Descriptions No. Address/Location Size Unit Project Description 185,000 sf Shopping Center 125,000 sf Office 25,000 sf Medical-Dental Office 15,000 sf Day Care Center 15,000 sf Library 10,000 sf Community Room 10 ac Park (1,187) du Apartment 2 905 E 2nd Street Garey Building Project2 320 du Condominium 18,716 sf Retail 3 810 E Pico Boulevard Stanford Regency Plaza2 181,620 sf Wholesale Market 4 610 S Louis Street Hollenbeck Terrace Apartments2 100 du Senior Adult Housing-Attached 33,000 sf Medical Office 5 1057 S San Pedro Street The City Market Mixed-Use Project3 945 du Multi-Family Residential 210 rm Hotel 294,641 sf Office 224,862 sf Retail 744 st Cinema 6 540 S Santa Fe Avenue4 98,825 sf Office 7 1525 E Industrial Street Camden Arts Mixed-Use Project2 344 du Live/Work 24,044 sf Creative Office 5,500 sf Restaurant 8 950 E 3rd Street Santa Fe Freight Yard Redevelopment2 532 stu Sci Arc School 30,062 sf Retail 635 du Apartment 9 695 S Santa Fe Avenue AMP Lofts Mixed-Use Project5 320 du Apartment 20,000 sf Retail 10 1147 E Palmetto Street Palmetto Colyton Mixed-Use Community6 310 du Live/Work 11,500 sf Retail/Restaurant 12,000 sf Art Production Space 11 963 E 4th Street Fourth & Traction Project2 78,600 sf Office

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Table 2 Related Projects Locations and Descriptions No. Address/Location Size Unit Project Description 25,000 sf Retail 20,000 sf Restaurant 12 2030 E 7th Street2 243,000 sf Office 40,000 sf Retail 13 2650 E Olympic Blvd Sears Adaptive Reuse Project7 1,030 du Apartment 219,258 sf Office 31,285 sf Supermarket 15,642 sf Apparel Store 2,607 sf Walk-In Bank 15,642 sf Drinking Place 26,070 sf High-Turnover Restaurant 2,607 sf Coffee Shop without Drive-Through Window 246,626 sf Department Store (246,626) sf Department Store 14 410 N Center Street Metro Emergency Security Operations Center2 110,000 sf Office 15 2407 E 1st Street2 50 du Apartment 8,500 sf Office 3,400 sf Retail 16 826 S Mateo Street2 90 du Live/Work 11,000 sf Retail 5,600 sf Restaurant 17 555 S Mateo Street At Mateo Project8 122,624 sf Retail 48,040 sf Office 18 1800 E 7th Street9 122 du Apartment 2,700 sf Office 4,605 sf High-Turnover Restaurant 3,245 sf Specialty Retail 19 520 S Mateo Street2 600 du Condominium 30,000 sf Office 15,000 sf Retail 15,000 sf Restaurant 20 360 S Alameda Street10 55 du Apartment 2,500 sf Restaurant 6,300 sf Creative Office 21 500 S Mateo Street2 12,682 sf High-Turnover Restaurant 22 649 S Wall Street Clinic at 7th & Wall Project2 55 bed Assisted Living 55 emp Medical Office

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Table 2 Related Projects Locations and Descriptions No. Address/Location Size Unit Project Description 23 2130 E Violet Street2 84,200 sf Office 7,500 sf Retail 24 719 E 5th Street2 160 du Apartment 10,057 sf Retail 25 929 E 2nd Street 2nd and Vignes Project11 36,955 sf Shopping Center (Public) 1,024 sf Specialty Retail (Private) 8,157 sf Event Space (Private 10,784 sf Lounge/Bar (Private) 42,716 sf General Office (Private) 3,043 sf Photo Studios (Private) 6,378 sf Health/Fitness Club (Private) 49 seat Screening Room (Private) (17) du Artist Live/Work 26 1722 E 16th Street2 8,515 sf Restaurant 27 647 S Mateo Street12 45,000 sf Office 4,000 sf Restaurant 28 1129 E 5th Street 1129 E 5th Street Mixed-Use Project13 228 du Apartment 149 rm Hotel 23,000 sf Retail 28,400 sf Restaurant/Bar 31,215 sf Office 29 401 E 7th Street FLOR 401 Lofts Project 99 du Apartment 30 400 S Alameda Street 400 S Alameda Hotel Project2 66 rm Hotel 2,130 sf Restaurant 840 sf Retail 31 940 E 4th Street Hewitt & 4th Mixed-Use15 93 du Apartment 6,000 sf Office 14,248 sf Retail (17,005) sf Warehouse 32 640 Alameda Street 6AM Project16 1,736 du Residential 253,514 sf Office 22,639 sf Quality Restaurant 22,639 sf High-Turnover Restaurant 82,332 sf Retail 22,429 sf Art Museum 514 rm Hotel 300 stu School

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Table 2 Related Projects Locations and Descriptions No. Address/Location Size Unit Project Description (316,632) sf Warehouse 33 676 Mateo St17 167 du Apartments 11,963 sf Commercial 11,962 sf Arts & Production (26,740) sf Light Industrial 34 67930 E 6th Street18 236 du Apartments 12,000 sf Shopping Center (23,732) sf Shopping Center 35 1000 S. Santa Fe Avenue SoHo House Project19 14,193 sf Market 6,793 sf Health Club (Spa) 10,065 sf Restaurant (71,737) sf Studio/Office 36 1024 Mateo Avenue20 104 du Live/Work 121,557 sf Commercial (16,960) sf Dash Bus Depot 37 2143 Violet Street 2143 Violet Project - Option B21 290 du Residential 46,670 sf Shopping Center 224,292 sf Office 38 670 Mesquit Street 670 Mesquit Mixed-Use Project22 308 du Apartment 236 rm Hotel 136,000 sf Commercial 39 668 S. Alameda Street23 475 du Live/Work Apartment 34,000 sf Live/Work Office 9,000 sf Specialty Retail 9,000 sf Office 17,000 sf Restaurant 15,000 sf Super Market (131,350) Sf Warehouse 40 554 S San Pedro Street Weingart Towers Project24 6 du Apartments 401 du Affordable Housing 12,300 sf Retail (7,040) sf High-Turnover Restaurant 41 600 S San Pedro Street 6th & San Pedro Affordable Housing Project25 5 du Apartments 298 du Affordable Housing 19,909 sf Retail 42 401 S Hewitt Street 4th & Hewitt Project26 7,800 sf Museum 255,514 sf Office

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Table 2 Related Projects Locations and Descriptions No. Address/Location Size Unit Project Description 4,970 sf Retail 9,940 sf Restaurant (3,515) sf Office (7,800) sf Museum 43 330 S Alameda Street Mixed-Use Project27 186 du Live/Work Apartments 10,415 sf Creative Office 11,925 sf Commercial 44 777 S Alameda Street ROW DTLA28 117,400 sf Restaurant 66,200 sf Retail 850,400 sf General Office 125 rm Hotel (3,000) emp Manufacturing (15) veh Manufacturing – Service Vehicles (12,600) sf Restaurant (65,800) sf Retail (513,300) sf Office (29,800) sf Assembly Space 45 2159 E Bay Street4 222,000 sf Office 46 640 S Santa Fe Avenue4 107,000 sf Office 47 641 S. Imperial Street 641 Mixed-Use Development29 140 du Live/Work 7,000 sf Retail 7,000 sf Creative Office 48 1745 E 7th Street The Walnut Mixed-Use Development30 57 du Live/Work 6,000 sf Commercial Space 49 1100 E 5th Street30 218 du Live/Work 18,400 sf Retail 50 755 S. Wall Street The Southern California Flower Market31 53,200 sf Office 323 du High-Rise Residential 4,400 sf Retail 4,420 sf High-Turnover Restaurant 125 per Event Space 66,200 sf Flower Market (2,000) sf High-Turnover Restaurant (196,800) sf Flower Market 51 212 E 7th Street30 452 du Apartment 13,655 sf Commercial

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Table 2 Related Projects Locations and Descriptions No. Address/Location Size Unit Project Description 52 730 S Los Angeles St30 72 du Live/Work 13,500 sf Commercial 53 752 S. Los Angeles St14 54 du Live/Work 54 333 S Alameda Street Little Tokyo Galleria Development32 834 du Apartment 160 du Affordable Housing 100,000 sf Commercial 55 443 S. San Pedro Street30 78 du Live/Work 7,000 sf Commercial 56 331 E. 1st Street30 41 du Apartment 4,000 sf Commercial 57 234 N. Center Street32 430 du Apartment 47 du Affordable Housing 33 58 1810 25th Street 13,835 sf Retail/Commercial Center 34 59 2626 26th Street 35,000 sf Concrete Batch Plant 34 60 1890 25th Street 31,000 sf Industrial Building Notes: du = Dwelling Units; sf= Square Feet; ac = Acres; rm = Rooms; st = Seats; stu = Students; bed = Beds; emp = Employees; veh = Vehicles; per = Persons. 1 Traffic Impact Study for the Boyle Heights Mixed-Use Project (Fehr & Peers, July 2011). Phase 1 assumed to be constructed by the buildout year (2022) of the Project. 2 Net trip generation and peak-hour directional distribution provided by the LADOT database. 3 Traffic Study for The City Market of Los Angeles (The Mobility Group, October 7, 2013). Phase 1 assumed to be constructed by the buildout year (2022) of the Project. 4 Trip generation and peak-hour directional distribution of trips based on ITE Land Use Code 710 (General Office Building). 5 Trip generation and peak-hour directional distribution of trips based on ITE Land Use Codes 220 (Apartment) and 820 (Shopping Center), with conservative internal capture, transit, and pass-by adjustments. 6 Trip generation and peak-hour directional distribution of trips based on ITE Land Use Code 110 (General Light Industrial), 220 (Apartment), and 820 (Shopping Center), with conservative internal capture, transit, and pass-by adjustments. 7 Traffic Impact Study for the Proposed Sears Adaptive Reuse Project (Crain & Associates, October 13, 2014). 8 At Mateo Development Updated Traffic Assessment for Revised Project (R.A. Smith National, June 8, 2015). 9 Supplemental Traffic Impact Analysis for the 1800 East 7th Street Project (Kunzman Associates, July 6, 2016). 10 Traffic Impact Study for the Proposed Mixed-Use Project at 360 S Alameda Street (The Mobility Group, August 2014). 11 Traffic Impact Study for the Proposed 2nd and Vignes Project (Crain & Associates, May 26, 2016). 12 Trip generation and peak-hour directional distribution of trips based on ITE Land Use Codes 710 (General Office Building) and 932 (High-Turnover Restaurant), with conservative internal capture, transit, and pass-by adjustments. 13 Trip generation and peak-hour directional distribution of trips based on ITE Land Use Codes 220 (Apartment), 310 (Hotel), 710 (General Office Building), 820 (Shopping Center), and 931 (Quality

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Table 2 Related Projects Locations and Descriptions No. Address/Location Size Unit Project Description Restaurant), with conservative internal capture, transit, and pass-by adjustments. 14 Trip generation and peak-hour directional distribution of trip based on ITE Land Use Code 220 (Apartment). 15 Transportation Impact Study Memorandum of Understanding with LADOT for the Proposed Hewitt & 4th Mixed-Use Project (February 23, 2017). 16 Transportation Impact Study Memorandum of Understanding with LADOT for the Proposed 6th & Alameda Project (April 19, 2017). With a buildout year of 2035, the 6AM Project is expected to contribute nominal traffic volumes to the local roadway system during the buildout year (2022) of the Project. 17 Traffic Study Memorandum of Understanding with LADOT for the Proposed 676 Mateo Street Project (September 16, 2016). 18 Traffic Impact Report for Proposed 930 E. 6th Street Mixed-Use Project (Crain & Associates, May 2017). 19 LADOT Referral Form for Proposed SoHo House Project (October 8, 2015). Peak-hour directional distributions based on ITE Land Use Code 931 (Quality Restaurant). 20 LADOT Referral Form for Proposed 1024 Mateo Avenue Project (December 1, 2016). Peak-hour directional distributions based on ITE Land Use Code 820 (Shopping Center). 21 LADOT Referral Form for Proposed 2143 Violet Street Project (January 31, 2017). 22 Trip generation and peak-hour trip directional distribution of trips based on ITE Land Use Code 220 (Apartment), 310 (Hotel), and 820 (Shopping Center), with conservative internal capture, transit, and pass- by adjustments. 23 Traffic Study Memorandum of Understanding with LADOT for the Proposed 668 S. Alameda Street Project (September 22, 2016). 24 LADOT Referral Form for Proposed 554-556 S. San Pedro Street Project (March 24, 2017). 25 LADOT Referral Form for Proposed 600-628 S. San Pedro Street Project (March 24, 2017). 26 Draft Transportation Impact Study Memorandum of Understanding with LADOT for the Proposed 4th & Hewitt Project. 27 Traffic Study Memorandum of Understanding with LADOT for the Proposed 330 S. Alameda Street Mixed-Use Project (September 7, 2016). 28 Trip Generation Analysis for Change of Land Use at ROW DTLA (Gibson Transportation Consulting, March 6, 2017). 29 Trip generation and peak-hour trip directional distribution of trips based on ITE Land Use Code 220 (Apartment), 710 (General Office Building), and 820 (Shopping Center), with conservative internal capture, transit, and pass-by adjustments. 30 Trip generation and peak-hour trip directional distribution of trips based on ITE Land Use Code 220 (Apartment) and 820 (Shopping Center), with conservative internal capture, transit, and pass-by adjustments. 31 Traffic Study Memorandum of Understanding with LADOT for The Southern California Flower Market (October 27, 2016). 32 Trip generation and peak-hour trip directional distribution of trips based on ITE Land Use Codes 220 (Apartment) and 820 (Shopping Center) and Affordable Housing trip rates provided by LADOT, based on empirical surveys of 35+ sites performed throughout the City in early 2016. 33 Trip generation and peak-hour directional distribution of trips based on ITE Land Use Code 820 (Shopping Center). 34 Trip generation and peak-hour trip directional distribution of trips based on ITE Land Use Code 130 (Industrial Park).

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Given the geographic range (1.5 miles from the Project Site) of the related projects and the proposed uses, it is likely that some related projects would request zone changes and/or General Plan Amendments to facilitate their proposed program. As with all discretionary requests, each related project would undergo its own environmental review under CEQA. As noted in this Errata, the areas zoned for industrial uses have been and are continuing to transition to residential and other-related uses in an economic trend in which manufacturing demand for land and manufacturing-related jobs has been substantially diminished.10 However, which projects would seek a zone change versus a different type of approval to allow for a non- industrial use is not known and as such CEQA does not require the analysis of speculation. (See Citizens for a Sustainable Treasure Island v. City and County of San Francisco (2014) 227 Cal.App.4th 1036, 1068 [CEQA does not require lead agencies to engage in speculation in order to analyze a worst case scenario], citing Napa Citizens for Honest Government v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 373; Sierra Club v. West Side Irrigation Dist. (2005) 128 Cal.App.4th 690, 704 [“For us to require more analysis than what was done would be to require the City to engage in sheer speculation, an act CEQA does not require.”)

3.5 Land Use Cumulative Impact Analysis

As stated in Section IV.G, Land Use and Planning, on page IV.G-9 and IV.G-28 of the Draft EIR, the surrounding area has undergone an evolution of land use patterns over the last several years resulting in a significant amount of compatible and complementary non-industrial development including residential, creative office, and related retail/cultural/entertainment uses. This was further confirmed in the CBRE Report, both in the immediate neighborhood of the Project Site and in the larger Arts District.11 These compatible and complementary non- industrial uses include several examples of sites that were previously industrial/manufacturing and now support residential, live/work, and mixed-use developments, such as the Soho Warehouse (1000 Santa Fe Avenue), AMP Lofts (695 Santa Fe Avenue), 1147 Palmetto Street, Ford Factory (777 Santa Fe Ave), Firehouse Hotel (710 Santa Fe Avenue), and proposed developments at 688 Alameda Street, 330 Alameda Street, 2166 Sacramento Street and 2036 Sacramento Street.

The proposed related projects developments are comprised of a variety of uses, including apartments, condominiums, restaurants, retail uses, office, hotel, restaurant, as well as mixed- use developments incorporating some or all of these elements as shown in Table 2, above. The Project and other related projects would be compatible with the uses in the surrounding vicinity, including the nearest related projects to the Project Site:

Related Project No. 23 – 2130 Violet Street is an office and retail use

Related Project No. 35 – 1000 Santa Fe is a hotel, night club, and restaurant use.

10 Consulting Report, CBRE, September 30, 2019. 11 Consulting Report, CBRE, September 30, 2019, Cover Letter page 1.

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Related Project No. 45 – 2159 Bay Street is an office use.

Based on the mix of uses and buildings that currently comprise the community as well as the related projects that are proposed, approved, or are under construction, the Project would be compatible with the various existing developments and related projects in the immediate vicinity of the Project Site and surrounding area. The Project complements and continues the recent development of the immediate neighborhood and the vicinity of the Artist-In-Residence District with mixed-use buildings and Live/Work and commercial uses.

According to a neighborhood amenities map for the Fourth & Traction project at 963 E. 4th Street (former Coca Cola warehouse converted to creative office), there were at least eight restaurants, cafes, and bars within walking distance (less than 10 minute walk according to Google Maps) of the Project Site.12 Together with the redevelopment of the former Ford Motor Company building at 777 S. Santa Fe Avenue, these examples show the trend of creative office, residential-amenities, and mixed land use development extending southerly in the Community Plan area.

In addition, while the Project in combination with the related projects represents a continuing trend of infill development at increased densities, future development inclusive of the Project would also serve to activate the Project vicinity and provide sufficient housing and amenities to serve the needs of the growing population. As the decade plus existing trend commensurate with City policies and City zoning tools, the related projects are not expected to fundamentally alter the current land use relationships in the community, and as with the Project, the related projects would be required to comply with relevant land use policies and regulations. In addition, as noted in the CBRE Report, the surrounding area has undergone an evolution of land use patterns over the last several years resulting in a significant amount of compatible and complementary non-industrial development including residential, creative office, and related retail/cultural/entertainment uses under allowable City zoning tools. This evolution of land use patterns reflects larger City employment and economic trends, as evidenced by the Project and related projects.13

As with the Project, the related projects would be required to comply with relevant land use policies and regulations. Therefore, as with the Project, the related projects would not conflict with applicable land use plans. Specifically, as with the Project, the related projects would be required to comply with certain regulations and City goals, objectives, and policies to reduce emissions during construction as well as using clean materials and energy efficient appliances, consistent with the City’s Green Building Code. In support of the City’s goal to reduce vehicle miles, it is anticipated that related projects would also implement various methods to promote alternative modes of transportation, including providing bicycle parking spaces, which is a City

12 http://fourthandtraction.com/#neighborhood. Viewing the ‘south’ area shows: American Tea Room, Stumptown Roasters, Bestia, Petty Cash Taqueria, Bread Lounge, Pizzanista, Everson Royce Bar. Church and State. 13 Consulting Report, CBRE, September 30, 2019, page 9.

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requirement. Overall, cumulative impacts related to conflict with land use plans would be less than significant.

As noted above, whether a project results in a spot zone is merely a screening criteria under the L.A. CEQA Thresholds Guide; a spot zone does not in and of itself constitute a significant impact. If a related project would result in the creation of a spot zone, it would be subject to further CEQA analysis to determine whether there would be a significant land use impact under the Appendix G thresholds of significance. If necessary, the City would require mitigation measures. Moreover, as noted above, the Project would not result in a significant land use impact as a result of a spot zone. Therefore, cumulative impacts with respect to spot zoning would be less than significant.

Moreover, the conversion of industrial land is an economic issue that is not within the scope of CEQA review unless it results in adverse impacts on the physical environment. The Project Site is vacant and would not displace existing industrial uses. While the related projects may displace the existing warehouse or industrial uses (unless at those sites, similar to the Project Site, the uses are vacant), it is unclear whether these uses will go out of business or relocate. It would be speculative to assume that they will relocate to other sites in the area. If they were to relocate, it is unclear whether these businesses would move into existing buildings or seek to develop new facilities. The latter would likely require discretionary approval and CEQA review. Appellant presented no evidence of potential displacement or, most significantly, evidence of direct or indirect physical impacts of such potential speculative impacts, which is Appellant’s burden. If industrial uses were displaced they would only be able to locate to lots that are industrially zoned or would have to seek a zone change to industrial use. The Appellant has presented no evidence of any such zone changes and in any event such zone changes would be subject to CEQA review. As such, based on the lack of substantial evidence, the City concludes that the cumulative impacts related to displacement of industrial uses would be less than significant.

Further, the evolution of land use patterns is evidenced by the City’s draft DTLA 2040 plan updates. The City notes that by 2040, the Downtown area will add approximately 125,000 residents, 70,000 housing units, and 55,000 jobs. Currently, housing is allowed in 33% of the Plan area. DTLA 2040 proposal allows housing in 60% of the Plan area.14 Notably, the proposed area of expanded housing includes the Project Site. In addition, the Project supports the General Plan by contributing to the available housing stock within the City and towards the housing crisis in the City, as well as the Mayor’s initiative to build 100,000 new housing units by 2020. Also, in support of Framework Element Policy 3.3 (promote equitable land use decisions that result in fewer vehicle trips by providing greater proximity and access to jobs…), the proposed General Plan Amendment would locate housing near jobs-rich Downtown while also allowing for jobs-producing uses.

14 https://www.dtla2040.org/draft-plan.html

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3.6 Proposed Changes in the Project Area

The proposed General Plan Amendment would be consistent and compatible with the existing pattern of development including complementary and compatible non-industrial uses and expansion of commercial and live/work uses in the area, as noted in Section 3.1.5 above. Specific live/work uses in the area include:

• 1855 Industrial Street, 6-story Toy Factory Lofts which contain 119 units and ground floor retail space;

• 1850 Industrial Street, 7-story Biscuit Company Lofts which contains 104 units and Church & State restaurant at the ground floor;

• 510 Hewitt Street, Barker Block Lofts with 300 units;

• 2135 7th Street, 2121 Lofts which contain 78 residential units and Bestia restaurant; and

• 2057 7th Street (695 Santa Fe), AMP Lofts which is entitled for 320 residential units and 20,000 square feet of ground floor commercial space.

Additional creative office conversion development from former industrial uses has also occurred nearby, including:15

• 777 Santa Fe, former auto (Ford Factory) and later toy manufacturing to creative office

• 963 E. 4th Street, former Coca Cola production building to creative office

• 405 Mateo, former Maxwell House Coffee building to creative office

• 1330 Santa Fe, former industrial building to creative office

• 777 S. Alameda Street, former garment and food manufacturing to creative office, retail, and restaurants.

As demonstrated in Section 3.3 and Section 3.4 above, in addition to the evolution of light industrial and manufacturing uses along with the development of compatible and complementary non-industrial uses in 10 years plus, recently approved projects and proposed changes establish that this Project would not be spot zoning but rather would be compatible with its surrounding uses.

15 Consulting Report, CBRE, September 30, 2019, Addendum A.

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4 Supplemental Land Use Consistency Analysis

Section IV.G, Land Use and Planning, of the Draft EIR, evaluates the Project’s potential land use impacts based upon the physical compatibility of the Project with its surrounding area and vicinity, and the Project’s consistency with applicable local and regional plans, regulations and policies adopted for the purpose of avoiding or mitigating an environmental effect. The following discussion expands on the land use consistency discussion from the Draft EIR and provides additional clarification to the text of the Draft EIR (additions are noted with underline and deletions are noted with strikethrough).

The information contained in this section clarifies, amplifies, or refines information in the Draft EIR but does not make any changes that would meet the definition of “significant new information” as defined above. The information added to the Draft EIR does not change the Draft EIR in a way that deprives the public of a meaningful opportunity to comment upon a new or substantially increased significant environmental effect of the Project.

4.1 Expanded Discussion of Economic Development Chapter

Page IV.G-5 references the Economic Development Chapter of the Framework Element:

The Economic Development Chapter of the Framework Element seeks to identify physical locations necessary to attract continued economic development and investment to targeted districts and centers. Goals, objectives, and policies focus on retaining commercial uses, particularly within walking distance of residential areas, and promoting business opportunities in areas where growth can be accommodated without encroaching on residential neighborhoods.

As noted on page IV.G-6:

The Project’s consistency with applicable goals, objectives, and policies in the Framework Element is analyzed in Table IV.G-3 of the Draft EIR. In addition, the Project’s consistency with certain economic development goals, objectives, and policies is discussed below for informational purposes. As these economic development goals, objectives, and policies were not adopted for the purpose of avoiding or mitigating an environmental effect, any potential inconsistency therewith would not be considered to be a significant environmental impact. (CEQA Guidelines Section 15064(e).)

Table IV.G-3 provides a Project consistency discussion for the Economic Development Chapter’s Objective 7.2 and Policy 7.2.2. The discussion has been updated to include Goal 7B, Policy 7.2.8 through Policy 7.2.14 and the inapplicability of Policy 7.3.4 through Policy 7.3.8.

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Goal 7B: A City with land appropriately and No Conflict. This is an economic development goal that sufficiently designated to sustain a robust was not specifically adopted for the purpose of avoiding or commercial and industrial base. mitigating an environmental effect. Therefore, the following is for informational purposes only. The Project would include 110 live/work apartment units, 113,350 square feet of creative office space, and 50,848 square feet of commercial space. The Project’s creative office space would be designed to accommodate and would support the media and entertainment industry. The Project would result in an increase of 662 jobs onsite and would generate substantial ongoing revenues to the City in the form of sales and property taxes. In addition, the Project Site represents only approximately 0.15 percent of the industrially-zoned land in the Central City North Community Plan area. Therefore, adequate land would remain for a robust industrial base and the Project contributes to a robust commercial base. Policy 7.2.8. Retain the current No Conflict. This is an economic development policy that manufacturing and industrial land use was not specifically adopted for the purpose of avoiding or designations, consistent with other mitigating an environmental effect. Therefore, the following Framework Element policies, to provide is for informational purposes only. The Project Site adequate quantities of land for emerging represents only approximately 0.15 percent of the industrial sectors. industrially-zoned land in the Central City North Community Plan area. Therefore, adequate land would remain for emerging industrial sector. In addition, the Project’s creative office space could be designed to accommodate the emerging media and entertainment industry in the area, as evidence by Warner Music’s recent relocation to 7th Street and Santa Fe.

Further, the Site is currently underutilized as demonstrated by the vacant uses and 0.05:1 FAR, and the Project would result in an increase of 662 jobs onsite and would generate substantial ongoing revenues to the City in the form of sales and property taxes. Manufacturing employment has declined dramatically on a regional basis, being replaced by service and creative jobs.16 The Project would serve this type of jobs demand. This meets the intent of this policy.

Moreover, this policy must be considered in light of Policy 3.14.6. As discussed therein, the Project would meet the criteria for changing the current industrial land use designation.

16 Consulting Report, CBRE, September 30, 2019, page 9.

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Policy 7.2.9. Limit the redesignation of No Conflict. This is an economic development policy that existing industrial land to other land uses was not specifically adopted for the purpose of avoiding or except in cases where such redesignation mitigating an environmental effect. Therefore, the following serves to mitigate existing land use conflicts, is for informational purposes only. As discussed above, the and where it meets the criteria spelled out in Project would meet the criteria spelled out in Policy 3.14.6 Policy 3.14.6 of Chapter 3: Land Use. for changing the Project Site’s current industrial land use designation. Policy 7.2.10. Ensure that the City's industrial No Conflict. This is an economic development policy that sites are regionally competitive to maintain was not specifically adopted for the purpose of avoiding or and enhance a core manufacturing base. mitigating an environmental effect. Therefore, the following is for informational purposes only. The Project Site is not appropriate for manufacturing due to the small size and configuration and the Project would not impede the City’s ability to meet this policy. It is clear that the land use patterns, both in the immediate neighborhood of the Project Site and in the larger Arts District, has evolved from its historic heavy industrial and manufacturing uses to light industrial and manufacturing along side compatabile and complimentary residential, creative office, and related retail/cultural/entertainment uses.17 Policy 7.2.11. Ensure that the City has No Conflict. This is an economic development policy that sufficient quantities of land suitable to was not specifically adopted for the purpose of avoiding or accommodate existing, new and relocating mitigating an environmental effect. Therefore, the following industrial firms, whose operations are is for informational purposes only. The Project would not appropriate to a specific location in Los impede the City’s ability to accommodate existing, new Angeles. and relocating industrial firms to a more appropriate location. The Project Site represents only approximately 0.15 percent of the industrially-zoned land in the Central City North Community Plan area. Therefore, adequate land would remain for emerging industrial sector. Policy 7.2.12. Establish, as shown in Figure No Conflict. This is an economic development policy that 7-1, the area adjacent to the Port of Los was not specifically adopted for the purpose of avoiding or Angeles, the rail corridor bisecting the San mitigating an environmental effect. Therefore, the following Fernando Valley, and the South is for informational purposes only. The Project would not Central/Southeast industrial area as market- impede the City’s ability to establish the various market- linked targeted industrial areas (market-linked linked targeted industrial areas as the Arts District is not areas are described on page 7-4). identified as a market-linked targeted industrial area. In any event, it should be noted that most remaining industrial uses in the area, and in the larger region, are actually warehouse/distribution uses (light industrial and manufacturing), not traditional heavy manufacturing and industrial uses. Heavy industrial/manufacturing employment has been declining due to the evolution of land uses to light industrial and manufacturing as well as

17 Consulting Report, CBRE, September 30, 2019, page 9.

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complimentary and compatibly land uses, regardless of specific zoning ordinances or land use planning.18 Policy 7.2.13. Facilitate environmentally No Conflict. This is an economic development policy that sound operations and expansion of the Port was not specifically adopted for the purpose of avoiding or of Los Angeles and the Los Angeles mitigating an environmental effect. Therefore, the following International Airport as major drivers of the is for informational purposes only. The Project Site is not local and regional economy. located at the Port of Los Angeles or Los Angeles International Airport. Policy 7.2.14. Take steps to assure that new No Conflict. This is an economic development policy that industries developed are sensitive to was not specifically adopted for the purpose of avoiding or environmental and conservation issues, and mitigating an environmental effect. Therefore, the following that cumulative environmental impacts are is for informational purposes only. The Project is not addressed. proposing new industries but rather live/work, commercial, and creative office uses that would be compatible with surrounding uses. Policy 7.3.4. Recognize the crucial role that Not Applicable. This is an economic development policy the Port of Los Angeles and the Los Angeles that was not specifically adopted for the purpose of International Airport play in future avoiding or mitigating an environmental effect. Therefore, employment growth by supporting planned the following is for informational purposes only. The Project Port and Airport expansion and modernization Site is not located at the Port of Los Angeles or Los that mitigates its negative impacts. Angeles International Airport.

Policy 7.3.5. Improve the movement of goods No Conflict. This is an economic development policy that and workers to industrial areas. was not specifically adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, the following is for informational purposes only. The Project Site existing uses are vacant and do not involve the movement of goods and workers. However, the proposed compatible mixed uses will reduce traffic as it is providing live/work housing close to the existing industrial uses. Policy 7.3.6. Retain the City's existing Not Applicable. This is an economic development policy manufacturing base through an outreach that was not specifically adopted for the purpose of program to existing businesses and an avoiding or mitigating an environmental effect. Therefore, ongoing assessment of their specific land use the following is for informational purposes only. The Project requirements. Site existing uses are vacant and do not support existing industrial businesses. Policy 7.3.7. Prioritize the retention and Not Applicable. This is an economic development policy renewal of existing industrial businesses. that was not specifically adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, the following is for informational purposes only. The Project Site existing uses are vacant and do not support existing industrial businesses. The Project Site will not have any material effect on future conversions of industrial land to office, residential, or commercial uses in the Arts District as it is not eliminating an ongoing industrial use, but rather providing compatible and complementary non-

18 Consulting Report, CBRE, September 30, 2019, page 5.

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industrial mixed uses. Moreover it is unlikely that the Project Site could in fact attract any viable industrial use.19 Policy 7.3.8. Assist existing industries Not Applicable. This is an economic development policy located in Los Angeles with their expansion that was not specifically adopted for the purpose of plans and/or relocation efforts to find suitable avoiding or mitigating an environmental effect. Therefore, industrial sites in the City. the following is for informational purposes only. The Project would not impede the City’s ability to assist existing industries with expansion plans and/or relocation efforts to a more appropriate location. The Project Site represents only approximately 0.15 percent of the industrially-zoned land in the Central City North Community Plan area. Therefore, adequate land would remain for emerging industrial sector.

4.2 Expanded Discussion of City’s Industrial Land Use Policy

Page IV.G-52 through IV.G-56 discusses the City’s Industrial Land Use Policy. In summary,

In or about 2007, the City Planning Department and Community Redevelopment Agency formulated an Industrial Land Use Policy (ILUP) that was intended to preserve certain industrially-zoned land in the City for industrial use. The City Planning Commission approved the ILUP, but it was never formally presented to the City Council for consideration or adoption. Since the ILUP was not adopted, the City is considering zone changes and General Plan Amendments from industrial designations on a case-by-case basis, as it has historically done.

However, specific to the Project site, the ILUP identified the Project Site as an “Employment Protection Districts” - areas where industrial zoning should be maintained, and where adopted General Plan, Community Plan and Redevelopment Plan industrial land use designations should continue to be implemented. However, Policy Guidance from the 2007 ILUP – Industrial Mixed-Use District Areas provides “Areas that should remain predominantly industrial/employment districts, but which may support a limited amount of residential use” and lists the Arts District, portions of Fashion District, West Los Angeles industrial areas: North of Expo/Sepulveda, Northwest of Expo/Bundy and the Hollywood Community Plan: Northeast of Santa Monica/Highland, Southwest of La Brea/Santa Monica. Moreover, as indicated in the Economic Development Chapter of the Framework Element, some existing industrially zoned lands may be inappropriate for new industries and should be converted for other land uses. Where such lands are to be converted, their appropriate use shall be the subject of future planning studies. This is satisfied in several ways. First, the entire project approval process, including the CEQA process, the entitlement process, and the various points therein for public comment form a planning study themselves which informs the City decisionmakers in

19 Consulting Report, CBRE, September 30, 2019, page 9.

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determining the appropriate use for this Site. Furthermore, a supplementary planning study has been provided demonstrating that the land use pattern, both in the immediate neighborhood of the subject property and in the larger Arts District, has undergone an evolution of land use patterns over the last several years resulting in a significant amount of compatible and complementary non-industrial development including residential, creative office, and related retail/cultural/entertainment uses, reflecting larger employment and economic trends. Finally, the ILUP stated that if unique circumstances existed to approve a change of use or zone in an ‘Employment Protection District’ the findings for such determination must be clearly articulated and the project should be required to incorporate community benefits.

The ILUP Map for Analysis Area 5 shows that the Project Site survey of land use is “Commercial / Service / Office”. Thus, the Site is not industrial use. Utilizing Los Angeles Department of Building and Safety (“LADBS”) building records, approximately 30% (314 of 1,107 parcels) of the parcels have building permits issued by the LADBS for non-manufacturing uses. Thus, the surrounding area, and the ILUP map reflected a Project Site that had already converted from industrial uses. This supports the requested GPA and does not hinder the preservation of industrial land, which occurs elsewhere. The ILUP is an additional study that meets the Framework Element Chapter 3 definition of an industrial conversion study.

4.3 Expanded Discussion of General Plan

Table IV.G-3 provides a Project consistency discussion in response to the General Plan Framework Element’s Policy 3.14.1, Policy 3.14.6, and Policy 3.14.9 9. The discussion has been updated to include Policy 3.14.2 through 3.14.5, 3.14.7, 3.14.8, and revised discussion for 3.14.6:

Policy 3.14.2: Provide flexible zoning to No Conflict. This is an economic development policy that facilitate the clustering of industries and was not specifically adopted for the purpose of avoiding or supporting uses, thereby establishing viable mitigating an environmental effect. Therefore, the "themed" sectors (e.g., following is for informational purposes only. The Project movie/television/media production, set would not impede the City’s efforts to rezone or reclassify design, reproductions, etc.). land to create clusters of industries.

Policy 3.14.3: Promote the re-use of No Conflict. This is an economic development policy that industrial corridors for small scale incubator was not specifically adopted for the purpose of avoiding or industries. mitigating an environmental effect. Therefore, the following is for informational purposes only. The Project would not impede the City’s efforts to re-use industrial corridors for small-scale incubator industries. However, the area does not support heavy manufacturing uses. The transition away from historic industrial/manufacturing uses, both in the immediate neighborhood and in the larger region, has already happened. Most remaining industrial uses in the area, and in the larger region, are actually light industrial and manufacturing uses (warehouse/distribution uses served primarily by diesel

2110 Bay Street Mixed-Use Project City of Los Angeles Errata to the EIR October 2019 Page 28

trucks, with resulting traffic and air pollution issues). Heavy manufacturing employment has been declining for decades, regardless of specific zoning ordinances or land use planning.20

Policy 3.14.4: Limit the introduction of new No Conflict. This is an economic development policy that commercial and other non-industrial uses in was not specifically adopted for the purpose of avoiding or existing commercial manufacturing zones to mitigating an environmental effect. Therefore, the uses which support the primary industrial following is for informational purposes only. function of the location in which they are located. The surrounding urban environment is comprised of a mix of industrial buildings, warehouses, residential lofts, commercial/retail, office, restaurant, parking, and neighborhood amenities. As shown in Section 3.3 above, the Project Site is located adjacent to a recently renovated building that includes restaurant and bar, event space, hotel rooms (Soho House), and a creative office building (Hyperloop One). Nearby are commercial and restaurant uses. Development of the Project would reinforce the evolution of land use patterns over the last several years through the use of various City zoning tools (discretionary and non-discretionary approvals as per the LAMC) resulting in a significant amount of compatible and complementary non-industrial development including residential, creative office, and related retail/cultural/entertainment uses as evidenced by the CBRE report and would not result in a fragmented pattern of development. Most remaining industrial uses in the area, and in the larger region, are actually warehouse/distribution uses (served primarily by diesel trucks, with resulting traffic and air pollution issues). Specific warehouse/distribution uses include 2124 Sacramento, south of the Site; 1100 Santa Fe southwest of the Site; 2433-2465 8th Street, 250 feet south of the Site. Heavy manufacturing employment has been declining for decades, regardless of specific zoning ordinances or land use planning.21 Policy 3.14.5: Promote the development of a No Conflict. This is an economic development policy that mix of commercial and light industrial uses in was not specifically adopted for the purpose of avoiding or areas designated as Industrial-Transit. mitigating an environmental effect. Therefore, the following is for informational purposes only. The area is not designated as Industrial-Transit.

20 Consulting Report, CBRE, September 30, 2019, page 5. 21 Consulting Report, CBRE, September 30, 2019, page 5.

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Policy 3.14.6: Consider the potential re- No Conflict. This is an economic development policy that designation of marginal industrial lands for was not specifically adopted for the purpose of avoiding or alternative uses by amending the community mitigating an environmental effect. Therefore, the plans based on the following criteria: following is for informational purposes only. a. Where it can be demonstrated that the existing parcelization precludes effective The Applicant retained CBRE to address the issues use for industrial or supporting functions raised in the Appeal relative to the Project’s requested and where there is no available method land use changes and the potential effects of that to assemble parcels into a unified site change on neighboring and regional land uses, and on that will support viable industrial the opportunities for manufacturing employment. The development; resulting study is provided as “Consulting Report, b. Where the size and/or the configuration of CBRE, September 30, 2019”, and included as an assembled parcels are insufficient to attachment to this Errata. In summary, there has been accommodate viable industrial an evolution of land use patterns over the last several development; years resulting in a significant amount of compatible and c. Where the size, use, and/or configuration complementary non-industrial development including of the industrial parcels adversely impact residential, creative office, and related adjacent residential neighborhoods; retail/cultural/entertainment uses. This evolution reflects d. Where available infrastructure is larger employment and economic trends. Therefore, the inadequate and improvements are Project will not have any material effect on future economically infeasible to support the needs of industrial uses; conversions of industrial land to office, residential, or e. Where the conversion of industrial lands commercial uses in the Arts District. Moreover, it is to an alternative use will not create a unlikely that the Project Site could in fact attract any fragmented pattern of development and viable industrial use.22 The Project is merely a reduce the integrity and viability of continuation and recognition of this now firmly existing industrial areas; established pattern. f. Where the conversion of industrial lands to an alternative use will not result in an The Project is proposing re-designation of industrial lands. adverse impact on adjacent residential However, development of the Project would not result in a neighborhoods, commercial districts, or fragmented pattern of development because it would not other land uses; physically divide an established community. Specifically, g. Where it can be demonstrated that the the surrounding urban environment is comprised of a mix reduction of industrial lands will not of industrial buildings, cold storage warehouses, adversely impact the City's ability to residential lofts, commercial/retail, office, restaurant, accommodate sufficient industrial uses to parking, and neighborhood amenities. The Project Site is provide jobs for the City's residents or located adjacent to a recently renovated building that incur adverse fiscal impacts; and/or includes restaurant and bar, event space, hotel rooms h. Where existing industrial uses constitute (Soho House), and a creative office building (Hyperloop a hazard to adjacent residential or One). Nearby are commercial and restaurant uses. natural areas. Development of the Project would reinforce current mixed- use development trends and would not result in a fragmented pattern of development.

According to the Central City North Community Plan, there are 1,180 acres (approximately 60 percent of the

22 Consulting Report, CBRE, September 30, 2019, page 9.

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2,005-acre total) of industrially zoned property in the Community Plan area. The Project Site comprises 1.78, or only approximately 0.15 percent of the industrially- zoned land and approximately 0.09 percent of the total land in the Community Plan area.

The Project Site is currently developed with an existing surface parking lot, an open-air industrial shed to be incorporated into the new development (Shed Building), and an approximately 4,000 square feet manufacturing building to be demolished. The existing buildings are vacant. Thus, the Site is currently underutilized as evidence by the underutilization of existing FAR (0.05:1) compared to the Project’s proposed FAR of 3.9:1 (287,137 square feet) and the Project Site’s many months of vacancy. Through a requested General Plan Amendment, the total FAR permitted by the proposed change to HD 2 is 6.0:1 (444,138 square feet). The Project is proposing less FAR than allowed to be entitled.

The Project would result in an increase of 662 jobs onsite and would generate substantial ongoing revenue to the City in the form of sales and property taxes. Therefore, the Project would not adversely impact the City's ability to accommodate sufficient industrial uses to provide jobs for the City's residents or cause the City to incur adverse fiscal impacts. Therefore, the Project would not conflict with this policy. Policy 3.14.7: Consider the potential No Conflict. This is an economic development policy that redesignation of non-industrial properties was not specifically adopted for the purpose of avoiding or located adjacent to lands designated and mitigating an environmental effect. Therefore, the developed with industrial uses for industrial following is for informational purposes only. The Project purposes by amending the community plans or by conditional use permits based on the would not impede the City’s efforts to amend the following criteria: community plan or by conditional use permits to re- designate non-industrial properties adjacent to lands a. The redesignation is required to designated and developed with industrial uses. accommodate the expansion of existing industrial uses to facilitate their retention in The Project is proposing re-designation of industrial lands. areas in which they are located; However, development of the Project would not result in a fragmented pattern of development because it would not b. There is substantial support of the property physically divide an established community. Specifically, owners of the parcels to be redesignated; the surrounding urban environment is comprised of a mix of industrial buildings, warehouses, residential lofts, c. There is no significant disruption or intrusion into existing residential commercial/retail, office, restaurant, parking, and neighborhoods, commercial districts, or other neighborhood amenities. The Project Site is located land uses; adjacent to a recently renovated building that includes restaurant and bar, event space, hotel rooms (Soho d. There are no adverse environmental House), and a creative office building (Hyperloop One).

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impacts (traffic, noise, lighting, air pollution, Nearby are commercial and restaurant uses. other) on adjacent land uses due to the Development of the Project would reinforce current mixed- industrial uses; and use development trends and would not result in a fragmented pattern of development. e. There is adequate infrastructure to support the expanded industrial use(s). Policy 3.14.8: Encourage the development in No Conflict. This is an economic development policy that areas designated as "Industrial-Heavy" of was not specifically adopted for the purpose of avoiding or critical public facilities that are necessary to mitigating an environmental effect. Therefore, the support the needs of residents and following is for informational purposes only. The Project businesses but normally are incompatible would not impede the City’s efforts to provide critical with residential neighborhoods and public facilities to support the needs of residents and commercial districts, such as corporate yards. businesses. As noted, the area is transitioning from predominantly industrial to commercial and live/work uses. New residential services and amenities such as restaurants and neighborhood-serving retail have been added to the Arts District area to the north.

4.4 Expanded Discussion of Community Plan

Table IV.G-6 provides a Project consistency discussion for the Community Plan’s Industrial Objective 3-2 and Policy 3-2.1. The discussion has been updated to include Goal 3, Objective 3- 1, Policy 3-1.1 through Policy 3-1.3, Objective 3-3, and Policy 3.3.1 and revised discussion for Policy 3-2.1:

Goal 3: Sufficient land for a variety of industrial No Conflict. Each of these relates to economic uses with maximum employment opportunities development, and none were specifically adopted for the which are safe for the environment and the purpose of avoiding or mitigating an environmental effect. work force and which have minimal adverse Therefore, the following is for informational purposes only. impact on adjacent uses. The Project Site represents only approximately 0.15 percent of the industrially-zoned land in the Central City Objective 3-1: To provide for existing and North Community Plan area. Therefore, adequate land future industrial uses which contribute job would remain for emerging industrial sectors. opportunities for residents and which minimize environmental and visual impacts to the The Project is proposing re-designation of industrial lands. community. However, development of the Project would not result in a fragmented pattern of development because it would not Policy 3-1.1: Designate lands for the physically divide an established community. Many of the continuation of existing industry and uses that are locating and expanding in the Arts District development of new industrial parks, research are consistent with the uses specified in this policy. and development uses, light manufacturing, Specifically, the surrounding urban environment is and similar uses which provide employment comprised of a mix of industrial buildings, warehouses, opportunities. residential lofts, commercial/retail, office, restaurant, parking, and neighborhood amenities. The Project Site is Policy 3-1.2: Adequate compatibility should be located adjacent to a recently renovated building that achieved through design treatments, includes restaurant and bar, event space, hotel rooms

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compliance with environmental protection (Soho House), and a creative office building (Hyperloop standards and health and safety requirements One). Nearby are commercial and restaurant uses. for industrial uses where they adjoin residential Development of the Project would reinforce current mixed- neighborhoods and commercial uses. use development trends and would not result in a fragmented pattern of development. Policy 3-1.3: Require that any proposed development be designed to enhance and be The Project Site is currently developed with an existing compatible with adjacent development. surface parking lot, an open-air industrial shed to be incorporated into the new development (Shed Building), and an approximately 4,000 square feet manufacturing building to be demolished. The existing buildings are vacant. Thus, the Site is currently underutilized as evidence by the underutilization of existing FAR (0.05:1) compared to the Project’s proposed FAR of 3.9:1 (287,137 square feet). Through a requested General Plan Amendment, the total FAR permitted by the proposed change to HD 2 is 6.0:1 (444,138 square feet). The Project is proposing less FAR than allowed to be entitled.

The Project is not an industrial use adjacent to residential and commercial uses. Rather, the Project is a residential, creative office, and restaurant use. In addition, the Project would be in compliant with the required health and safety requirements applicable to residential, office, and restaurant uses.

In addition, the Site is currently underutilized, and the Project would result in an increase of 662 jobs onsite and would generate substantial ongoing revenues to the City in the form of sales and property taxes. This meets the intent of each of the goal, objective, and policy. Policy 3-2.1: Support the existing artists-in- No Conflict. This is an economic development policy that residence in Central City North as a cultural was not specifically adopted for the purpose of avoiding or resource for the community. mitigating an environmental effect. Therefore, the following is for informational purposes only. The Project would support the existing artist-in-residence community by providing opportunities for artists to live in close proximity to work and potentially within the same space. A live/work unit allows the artist to live and work in the same unit. Inclusion of the artists-in-residence community in the industrial section of the Plan, rather than the residential section, demonstrates that JLWQ and live/work uses are not traditional residential uses but are rather supportive and complimentary of the kind of evolving light industrial uses supported by the City’s land use policies.

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Consistent: The Project includes development of live- work units, office, and commercial uses. Objective 3-3 To retain industrial plan No Conflict. This is an economic development policy that designations to maintain the industrial was not specifically adopted for the purpose of avoiding or employment base for community residents and mitigating an environmental effect. Therefore, the to increase it whenever possible. following is for informational purposes only. The Project Site represents only approximately 0.15 percent of the industrially-zoned land in the Central City North Community Plan area. Therefore, adequate land would remain for maintain the industrial employment base. In addition, the Site is currently underutilized and does not support any jobs. Moreover, it is unlikely that the Project Site could in fact attract any viable industrial use.23 Policy 3-3.1 The numerous large rail yards No Conflict. This is an economic development policy that and other industrially planned parcels located was not specifically adopted for the purpose of avoiding or in predominantly industrial areas should be mitigating an environmental effect. Therefore, the protected from development by other uses following is for informational purposes only. The Project which do not support the industrial base of the Site represents only approximately 0.15 percent of the City and the community. industrially-zoned land in the Central City North Community Plan area. Therefore, adequate land would remain for emerging industrial sectors.

The two nearest rail yards are approximately 3,400 feet south of the Site near Washington Boulevard, and 4,500 feet north of the Site near 4th Street. Neither is nearby the Project Site.

In addition, the Site is currently underutilized, and the Project would result in an increase of 662 jobs onsite and would generate substantial ongoing revenues to the City in the form of sales and property taxes. Moreover, the creative office space could be designed to accommodate the media and entertainment industries. This meets the intent of this policy.

5 Industrial Conversion Study

Framework Element, Chapter 3 – Industrial includes as part of the definitional section of Chapter 3: “Where such lands are to be converted, their appropriate use shall be the subject of future planning studies.” The City has determined that the CBRE Report meets the definition of an Industrial Conversion Study pursuant to Chapter 3 of the Framework Element.

Per the CBRE Report, there has been an evolution of land use patterns over the last several years resulting in a significant amount of compatible and complementary non-industrial

23 Consulting Report, CBRE, September 30, 2019, page 9.

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development including residential, creative office, and related retail/cultural/entertainment uses in the surrounding area. This evolution of land use patterns reflects larger employment and economic trends. Therefore, the Project will not have any material effect on future conversions of industrial land to office, residential, or commercial uses in the Arts District. Moreover, it is unlikely that the Project Site could in fact attract any viable industrial use, as set forth more fully below. The Project is merely a continuation of this evolution of land use patterns.

Per the CBRE Report, active real estate brokers in the area unanimously report that there is no current interest from manufacturing users. Thus, it can be reasonably concluded that given the many months of vacancy at the Project Site coupled with the lack of broker interest, the Project Site will not support any viable industrial use. In addition, over the past 28 years (since 1990 and last reported in 2018), manufacturing employment in Los Angeles County declined by 474,800 jobs (58%) over the same time period that overall employment increased by 663,400 jobs (or 16%) adding further support for the significant declining heavy manufacturing/industrial trend.

Therefore, per Framework Element’s Policy 3.14.6 (g), the CBRE Report demonstrates that the very minor reduction of industrial lands presented by this Project will not adversely impact the City's ability to accommodate sufficient industrial uses to provide jobs for the City's residents or incur adverse fiscal impacts should such demand present itself.

As discussed in the Draft EIR and this Errata, the Project Site as currently zoned is an under- utilized site and in order to appropriately utilize the Project Site, it must be constructed into a mixed-use development. 6 Conclusion

The City has prepared the Errata and has determined that it does not change any of the findings or conclusions of the EIR and does not constitute significant new information requiring recirculation pursuant to CEQA Guidelines Section 15088.5. The clarification of land use discussion does not constitute a substantial revision such that a Supplemental/Subsequent EIR need be prepared, as set forth in CEQA Guidelines 15163. The change constitutes updated information which makes insignificant corrections and clarifications to the Final EIR and does not introduce new information that was not known previously, and recirculation is not required.24 There would be no new significant impacts or new mitigation measures required as a result of the Project.

24 State CEQA Guidelines 15163

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Attachment A

2110 Bay Street Mixed-Use Project City of Los Angeles Errata to the EIR October 2019 Page 36 CONSULTING REPORT

2110 BAY STREET MIXED-USE PROJECT Draft Environmental Impact Report (ENV-2016-3480-EIR) Supplementary Study – Art District & Regional Land Use & Employment Trends Los Angeles, CA 90021 CBRE, Inc. File No. 19-251LA-1869

Mr. Daniel Taban

BAY CAPITAL FUND, LLC

888 South Figueroa, Suite 1900

Los Angeles, CA 90015

www.cbre.com/valuation

© 2019 CBRE, Inc.

VALUATION & ADVISORY SERVICES

Valuation & Advisory Services Los Angeles, CA 90071-1549

T 213-613-3176 F 213-613-3131

www.cbre.com September 30, 2019

Mr. Daniel Taban BAY CAPITAL FUND, LLC 888 South Figueroa, Suite 1900 Los Angeles, CA 90015 Phone: 213-745-5191 Email: [email protected]

RE: 2110 Bay Street Mixed-Use Project Draft Environmental Impact Report (ENV-2016-3480-EIR) Supplementary Study – Art District & Regional Land Use & Employment Trends Los Angeles, CA 90021 CBRE, Inc. File No. 19-251LA-1869

Dear Mr. Taban: At your request, CBRE Valuation and Advisory Services has prepared the following report in connection with the Environmental Impact Report (EIR) report referenced above. The purpose is to address issues raised in an appeal of that EIR, relative to its requested land use changes and the potential effects of that change on neighboring and regional land uses, and on the opportunities for manufacturing employment. Summarized below are brief descriptions of: 1) the subject Arts District submarket; 2) the subject property and its proposed redevelopment; and 3) CBRE Valuation and Advisory Service’s experience in the area. This is followed by our understanding and analysis of the primary issues raised in the appeal. Since these issues focus on land use changes, our analysis includes charts documenting (on a building or site specific basis) the transition of both the immediate neighborhood and the surrounding area away from its historic manufacturing uses, and other data relevant to these issues. In summary, it is our conclusion that the land use patterns, both in the immediate neighborhood of the Project Site and in the larger Arts District, has evolved from its historic industrial and manufacturing uses to modern, technology oriented light industrial and manufacturing compatible and complementary with residential, creative office, and related retail/cultural/entertainment uses. This evolution reflects larger employment and economic trends.

© 2019 CBRE, Inc. Mr. Daniel Taban September 30, 2019 Page 2

Therefore the subject project will not have any material effect on future conversions of industrial land to office, residential, or commercial uses in the Arts District. Moreover it is unlikely that the subject could in fact attract any viable industrial use. The proposed subject development is merely a continuation and recognition of this now firmly established pattern. Sincerely,

CBRE - VALUATION & ADVISORY SERVICES

David A. Zoraster, MAI Director CA State Certification No. AG001785

Phone: (213) 613-3658 Fax: (213) 613-3131 Email: [email protected]

© 2019 CBRE, Inc. Certification

Certification

We certify to the best of our knowledge and belief: 1. The statements of fact contained in this report are true and correct. 2. The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions and are our personal, impartial and unbiased professional analyses, opinions, and conclusions. 3. I have no present or prospective interest in or bias with respect to the property that is the subject of this report and have no personal interest in or bias with respect to the parties involved with this assignment. 4. My engagement in this assignment was not contingent upon developing or reporting predetermined results. 5. My compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal. 6. This assignment was not based upon a requested minimum valuation, a specific valuation, or the approval of a loan. 7. My analyses, opinions, and conclusions were developed, and this report has been prepared, in conformity with the Uniform Standards of Professional Appraisal Practice, as well as the requirements of the State of California. 8. The reported analyses, opinions, and conclusions were developed, and this report has been prepared, in conformity with the requirements of the Code of Professional Ethics and Standards of Professional Appraisal Practice of the Appraisal Institute. 9. The use of this report is subject to the requirements of the Appraisal Institute relating to review by its duly authorized representatives. 10. As of the date of this report, David A. Zoraster, MAI has completed the continuing education program for Designated Members of the Appraisal Institute. 11. David A. Zoraster, MAI has made a personal inspection of the property that is the subject of this report. 12. Valuation & Advisory Services operates as an independent economic entity within CBRE, Inc. Although employees of other CBRE, Inc. divisions may be contacted as a part of our routine market research investigations, absolute client confidentiality and privacy were maintained at all times with regard to this assignment without conflict of interest. 13. David A. Zoraster, MAI has provided appraisal services regarding the property that is the subject of this report within the three-year period immediately preceding acceptance of this assignment.

David A. Zoraster, MAI Director CA State Certification No. AG001785

i

© 2019 CBRE, Inc. Table of Contents

Table of Contents

Certification ...... i Table of Contents ...... ii The Arts District ...... 1 Assumptions and Limiting Conditions ...... 10

ADDENDA A Arts District – Conversions and New Development B Qualifications

ii

© 2019 CBRE, Inc. The Arts District

The Arts District

Boundaries and Access

The Arts District is located on the east side of Downtown Los Angeles, roughly bounded by Alameda Street on the west, rail lines and the Los Angeles River on the east, and 1st Street on the north. The south boundary – historically 7th Street (with a jog down to Violet Street) – has clearly moved south (encompassing the subject site), at least to the Santa Monica (I10) Freeway. Some abutting areas, particularly just to the west of Alameda, are also now part of the district.

First, 4th, 6th and 7th streets are all viaducts (6th Street is being rebuilt) crossing the Los Angeles River and rail lines just to the east. They are essentially the only east-west streets crossing the district. The main north-south streets are Santa Fe Avenue along the eastern edge of the district, parallel to the Los Angeles River, passing under these viaducts, and Alameda Street, forming the west boundary.

The street pattern is erratic. Cul-de-sacs, T-intersections, and diagonal merging are common. Only Alameda Street, 1st Street, 4th Street, 6th Street, 7th Street and (to a lesser extent) Santa Fe Avenue/Center Street and Mateo Street carry significant through traffic. The result is a relatively isolated district, adjoining but only partially integrated into Downtown Los Angeles.

Access in the northern part of the district benefits from a light rail passenger line, connecting Downtown and East Los Angeles, with a station at 1st and Alameda streets. The under-construction Regional Connector will provide direct access from First and Alameda to the Civic Center, Historic Core and Financial District.

History and Background Land uses are or were mostly older industrial and distribution facilities, a pattern that evolved starting in the late 1800s. Multi-story industrial loft buildings and railroad oriented warehouses dominated. Parking, truck access and loading at these buildings was poor. Railroad spur lines, now rarely used (often now vacated), are scattered throughout the area.

Since World War II, competition from modern or relatively modern industrial districts (the San Fernando Valley, the City of Commerce, Industry, the Inland Empire) resulted in the decline of the district for industrial and distribution uses. The multistory design, emphasis on rail (rather than truck) service, and lack of adequate seismic reinforcing, typical of these older industrial buildings, all contributed to the decline. New industrial buildings emphasize single story design, high clear heights, truck transportation and abundant truck loading doors and parking.

Transition – Artists and Creative Uses In the late 1970s artists began occupying abandoned upper floor industrial space in the area. Although described as artist use, it was more of a residential use. Use of vacant industrial buildings was a logical solution to higher priced housing alternatives, and is also appropriate to artistic

1

© 2019 CBRE, Inc. The Arts District

sensibilities for space and atmosphere. Such use originally violated city zoning and building codes (particularly in the predominant M3 industrial zone). For years, landlords rented these spaces as "studios" and ignored the obvious residential use. Passage in 1981 of the Joint Living and Work Quarters for Artists Ordinance provided a pathway for legalizing these uses. The area between 1st and 4th streets, just east of Little Tokyo, including Traction, 2nd, 3rd and Vignes streets, was historically the most active area, but was only a portion of the overall activity. A number of larger conversions, including the 2121, Toy, and Biscuit Lofts (in 2005 and 2006), expanded this use to the south.

Due to the Arts District’s industrial zoning, ground-up residential development requires a general plan amendment and zone change, a discretionary action that can trigger very specific design guidelines and potentially affordable housing requirements.

Related to artist loft use was the growth of design offices in the area. Architects, interior decorators, and commercial photographers in particular find the older industrial buildings attractive as office space. The ground floors of many of these buildings have been remodeled into high-quality design offices, typically in combination with upper floor artist lofts. The relocation of the SCI-Arc architectural college to this neighborhood in 2000-2001 complimented and encouraged this trend.

A number of buildings in the area have also been converted to recording or film studios, reflecting their large interior spaces, relatively cheap rents, and the strength of the regional entertainment industry. Art galleries also find such space attractive. Location filming is a significant activity.

Current Activity Reflecting the demand across many industries for more “creative space”, numerous large industrial buildings in the area have been converted to creative office; others are planned. Including projects like Ford Factory Building, Coca Cola Building, Row DTLA and Maxwell, well over two million square feet of creative office space conversions have now occurred. Major developers active in the area include Hudson Pacific, Shorenstein Group, Tishman Speyer, Lowe Enterprises, Omni Group, and Atlas. Major office users attracted to the area now include Warner Music, WeWorks, Spotify, Soylent, USC, and Honey Science.

Restaurants and retail uses serving the growing residential population have also expanded. This area has attracted numerous popular restaurants, attracting diners (“Foodies”) from out of the area. Examples include Bestia, Church and State, Factory Kitchen, Zinc Café, Officine Brera, Urth Café (reportedly the chain’s highest grossing location), and Salt Bae.

Breweries and distilleries, a hybrid manufacturing but primarily retail/restaurant use, have also located in the Arts District, including Iron Triangle, Angel City Brewery, Arts District Brewery, Boomtown Brewery, Dry River Brewing, Greenbar Distillery, Spirit Guild and Indie Brewery.

Ground-up residential construction, typically requiring a zone change and general plan amendment, has become more common. Examples built or under construction include One Santa Fe (438 units), Aliso Apartments (472 units), and AMP Lofts (180 units).

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© 2019 CBRE, Inc. The Arts District

Major Planned New Arts District Developments Included in the Addenda is a chart headed “Completed Major New Arts District Construction”, listing major new ground up residential or mixed-use projects already completed in the Arts District. Shown below is a sampling of major projects in planning in the area, all with significant architectural, legal, and entitlement work (and costs) already expended. The planned uses (and the scale of the projects) is indicative of the future of the Arts District.

SoHo House is redeveloping (not new construction but adjacent to the subject) a 100- year old warehouse at the southeast corner of Santa Fe Avenue and Bay Street (abutting the subject). Killefer Flammang Architects are converting this six-story building into a mix of performance rooms, a spa, a gym, 48 hotel rooms, a film screening room, a restaurant, a club and a pool terrace. (Construction started in 2017.)

SunCal, owner of a 14.5-acre site at the corner of 6th and Alameda streets March 2015, has submitted an entitlement application with preliminary conceptual plans for the site, now called 6AM. They include two 58-story towers, 1,736 residential units, two hotels, retail shops, creative offices and a school, and 23,000 square feet for art and two parks. The developer is reportedly partnering with a fund affiliated with Dell computers founder Michael Dell. (Filed 9/26/16.)

Rancho Cold Storage, owner (the Gallo family) and New York developer V.E. Equities have announced a joint venture to redevelop the Rancho Cold Storage property, at 670 Mesquit, along the west side of the Los Angeles River, between the 6th Street and 7th Street bridges. The project consists of 308 residential units, 236 hotel rooms, and a reported 800,000 square feet of creative office space and open space in two 30-story buildings. The design also calls for a small museum or public sculpture park with a large deck extending over the rail line between the site and the Los Angeles River. (Filed 1/23/17; VTT-74765.)

520 Mateo is a proposed 35-story, 475-unit live-work, plus 125,000 SF of commercial space proposed for 520 Mateo by Camden Development. It has received L.A. Planning Commission approval (but is subject to an appeal).

527 Colyton is a proposed 12-story, 310 residential unit complex with 11,375 SF of retail and 11,736 SF of production space, now in the entitlement process. (Filed 9/30/16; VTT-74541.)

330 Alameda is a proposed 7-story, 186-live work unit over retail complex, also in the entitlement process. (Filed 9/2/16; VTT-74472.)

668 Alameda (prior use – industrial cold storage), is a proposed 475 live-work units over 61,200 sq. ft. commercial complex, the developer is Avalon Bay. (Submitted 9/20/16; approved 10/3/18.)

641 Imperial, a planned 7-story, 344 live-work units over 29,544 sq. ft. of commercial. (Filed 9/7/17; VTT-74112-2A.)

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The completed and the planned developments are all residential and/or mixed-use. None include any significant manufacturing or industrial component. They predate or are concurrent with the subject application.

The Subject Property and Its Proposed Development The subject property is a near rectangular 77,457-square-foot site, located at 2110 Bay Street, extending through (south) to Sacramento Street. It is on the southeast side of the Arts District, located just east of Santa Fe Street. Both Bay and Sacramento Street dead-end just east of the subject site, at the rail lines and the L.A. River channel that forms the east boundary of the Arts District.

The site was occupied historically as a vehicle storage and impound yard, it has been vacant other than some parking and storage use for several years.

Existing Zoning The site is currently zoned City of Los Angeles M3-1-RIO, a heavy industrial zone, also allowing office and retail uses (residential uses are allowed under the artist in residency ordinance in converted industrial buildings, but not as new construction). It is the predominant zone in the Arts District.

The “1” is a height district limiting development to a floor to land area ratio (FAR) of 1.5 to one. The “RIO” designation is a River Improvement Overlay, which includes design guidelines for properties near the Los Angeles River but has little or no impact on allowable uses or densities.

The general plan designation (Heavy Manufacturing) is in conformity with the zoning.

Proposed Subject Development In 2016, the owners applied (ENV-2016-3480-EIR) to redevelop the site as a mixed-use project, with the following components:

Building 1: Retail New Construction, Under Existing Metal Shed to Retail.

Building 2: Creative Office New, 7-story, 113,350 SF

Building 3: Live Work New, 11-story, 110 units, 114,825 SF

Parking: Below Grade 479 spaces (plus bicycle)

The total floor area will be 287,137 square feet. Eleven of the live-work units (11%) will be affordable/very low income.

This application requires a zone change from the present M3-1-RIO to CM-2-RIO, a general plan amendment, and a density bonus from the present 1.5 floor area ratio to a 3.9 to one floor area ratio (FAR).

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CBRE Valuation and Advisory Services – Relevant Experience Over the past 40 years CBRE Valuation and Advisory Services has completed several hundred appraisal assignments in and around the area now known as the Arts District. More specifically, over the past five years, we have completed over 90 appraisal assignments in the subject 90021 zip code (including two appraisals of the subject property, both for federally regulated lenders).

Other CBRE divisions – specifically brokerage and research – also have extensive experience in the area. We have incorporated their data in this report.

APPEAL SPECIFICS – SUMMARY FINDINGS The appeal of the subject EIR covers a number of interrelated land use issues. The primary ones deal with the potential effects of the requested zone change and general plan amendment:

1) On the immediate subject neighborhood, specifically the potential negative effect of this “spot zoning” on surrounding industrial uses; and

2) On the larger Arts District and adjoining area, due to the potential negative effect on industrial uses (and industrial employment) from the loss of manufacturing land.

These issues are addressed below. In summary, land uses in both the immediate neighborhood and in the larger region have evolved from their historic industrial and manufacturing uses to modern, technology oriented light industrial and manufacturing uses compatible with residential, creative office, and related retail/cultural/entertainment uses.

The appeal conflates industrial with manufacturing. Most remaining industrial uses in the area, and in the larger region, are actually warehouse/distribution uses (served primarily by diesel trucks, with resulting traffic and air pollution issues). Actual manufacturing employment has been declining for decades, regardless of specific zoning ordinances or land use planning.

Employment in the creative office fields – a major proposed use for the subject site – is growing, while manufacturing employment has declined dramatically, a decline that continues.

IMMEDIATE NEIGHBORHOOD – LAND USE CHANGES As described previously, the subject property is located on the southside of Bay Street, extending south to Sacramento Street, east of Santa Fe Avenue. Both Bay and Sacramento Streets dead-end just east of the subject. The immediate neighborhood of the subject site – properties potentially directly affected by the proposed development of the subject – are therefore limited to properties on the subject block itself, or directly across from it, on either the southside of Bay or the northside of Sacramento, from Santa Fe Avenue east to the rail lines and L.A. River.

The land use pattern in the immediate neighborhood of the Project Site has evolved from its historic industrial and manufacturing uses to industrial and manufacturing uses with new technologies,

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compatible and complementary to residential, creative office, and related retail/cultural/entertainment uses. This evolution reflects larger employment and economic trends.

Those immediately neighboring properties, as shown on the chart below, have already substantially converted to non-industrial uses. Those that have not are primarily the smaller properties.

IMMEDIATE NEIGHBORHOOD LAND USES Address Original Use/ Current Use/ Location Relative to Subject Description Description Same Block 1) 1000 Santa Fe @ Bay, 62,000 SF Industrial Being converted to SoHo House, a club, west across alley Loft (David Harvey building) hotel, and performance venue.

2) 1018 Santa Fe, 4,960 SF Factory Now music studio/art gallery. west across alley

3) 1022-1024 Santa Fe @ Sacramento, 26,937 SF Industrial Appears vacant. west across alley (two buildings)

4) 2136 Bay, through to 2145 Sacramento, 32,232 SF Industrial Now hyperloop, creative offices. adjacent east

Northside of Bay Street 5) 930 Santa Fe @ Bay, Service Station, Service Station, Car Wash. diagonally across Bay Cash Wash

6) 2121-2125 Bay, 16,559 SF Industrial Part photo studio/office; part garment. directly across Bay (two buildings)

7) 2133-2135-2143 Bay, 12,698 SF Industrial Now creative offices (Nasty Girl). directly across Bay (two buildings) & 10,400 SF Office

8) 2149 Bay, 9,848 SF Industrial Now Artist in Resident – Home Owner. diagonally across Bay

Southside of Sacramento 9) 1100 Santa Fe @ Sacramento, 12,226 SF Food Processing Ocean Sea Food, still sea food. diagonally across Sacramento

10) 2116-2120 Sacramento, 11,210 SF Warehouse Now art gallery. directly across Sacramento

11) 2124 Sacramento, 11,210 SF Industrial Distribution use. directly across Sacramento

12) 2132-2146-2150 Sacramento, 33,621 SF Industrial Half long vacant; half garment diagonally across Sacramento (three buildings) industry use.

13) 2152 Sacramento, 17,705 SF Industrial Garment industry. diagonally across Sacramento

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IMMEDIATE NEIGHBORHOOD

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ARTS DISTRICT AREA – LAND USE CHANGES As previously described, the larger subject area (generally now known as the Arts District) began its evolution from industrial/manufacturing to live-work, creative office, and retail/cultural/entertainment in the 1970s, with the earliest artist in residency conversions. These conversions have continued, evolving from artist to work-live and general residency, and – more recently – new residential construction. Also significant has been a flood of creative office conversions, with strong leasing and resulting employment. Reflecting and supporting both the residential and creative office growth has been a strong influx of retail, cultural, dining, and entertainment uses.

Specific Examples In the Addenda are a series of charts showing conversions and new construction from industrial/manufacturing uses to artist residential, creative office, and other non-industrial uses.

In summary, in the Addenda charts show approximately 18 generally large conversions from industrial to residential, five large conversions to creative office, and six major new projects. Creative office conversions and new construction total well over 2,000,000 square feet, with strong leasing.

These are additional to those shown in the immediate neighborhood, and comprise only a partial listing. The (generally smaller) conversions to retail/cultural/entertainment uses have been excluded.

The great majority of these conversions have occurred on properties with the same M3-1-RIO Zone as the subject. They are scattered throughout the area.

Broker Interviews We have interviewed a number of real estate brokers active in the area, asking each the question do you have any current interest from manufacturing users. The unanimous answer is no. Many have in fact moved traditional industrial users out of the area.

Those brokers interviewed are listed below.

Robert Harris, Sterling Realty David Freitag, Daum John Hillman, CBRE Jeff Stevens, CBRE Brandon Gill, Cushman & Wakefield Jae Yoo, Cushman & Wakefield

MANUFACTURING EMPLOYMENT – LONG TERM REGIONAL DECLINE Reflecting – and causing – the decline of traditional manufacturing uses in the subject neighborhood is the long term decline in manufacturing employment in the larger region. Like in

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the Arts District, manufacturing employment has declined dramatically on a regional basis, replaced by service and creative jobs.

Manufacturing employment, compared to total employment, for Los Angeles County over the past three decades, is shown below. (Data from the State of California Employment Development Department, Labor Market Information Division.)

Year Total Employment Manufacturing Employment 1990 4,233,100 818,500 2000 4,425,600 618,400 2010 4,302,300 379,700 2018 4,896,500 343,700

Over the past 28 years, manufacturing employment in Los Angeles County declined by 474,800 jobs, or 58%; over the same time period overall employment increased by 663,400, or 16%. Put another way, manufacturing was 19% of total employment countywide, it is now only 7%.

CONCLUSION For both the immediate neighborhood and for the larger Arts District, the transition from historic industrial/manufacturing uses more modern, technological oriented industrial uses compatible with residential/artist, creative office, and related retail/cultural/restaurant/entertainment uses, is far along. This reflects large economic and social patterns.

The proposed subject development reflects these trends, and the economic realities of the area and the region. It will have no negative effect on the remaining industrial or manufacturing uses in the area.

It is clear that the land use pattern, both in the immediate neighborhood of the subject property and in the larger Arts District, has already strongly transitioned away from its historic industrial and manufacturing uses to residential, creative office, and related retail/cultural/entertainment uses. This pattern, now clearly established, reflects larger employment and economic trends, which are also discussed.

Therefore the subject project will not have any material effect on future conversions of industrial land to office, residential, or commercial uses in the Arts District. Moreover it is unlikely that the subject could in fact attract any viable industrial use.

The proposed subject development is merely a continuation and recognition of this now firmly established pattern.

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© 2019 CBRE, Inc. Assumptions and Limiting Conditions

Assumptions and Limiting Conditions

1. CBRE, Inc. through its appraiser (collectively, “CBRE”) has inspected through reasonable observation the subject property. However, it is not possible or reasonably practicable to personally inspect conditions beneath the soil and the entire interior and exterior of the improvements on the subject property. Therefore, no representation is made as to such matters. 2. The report, including its conclusions and any portion of such report (the “Report”), is as of the date set forth in the letter of transmittal and based upon the information, market, economic, and property conditions and projected levels of operation existing as of such date. The dollar amount of any conclusion as to value in the Report is based upon the purchasing power of the U.S. Dollar on such date. The Report is subject to change as a result of fluctuations in any of the foregoing. CBRE has no obligation to revise the Report to reflect any such fluctuations or other events or conditions which occur subsequent to such date. 3. Unless otherwise expressly noted in the Report, CBRE has assumed that: (i) Title to the subject property is clear and marketable and that there are no recorded or unrecorded matters or exceptions to title that would adversely affect marketability or value. CBRE has not examined title records (including without limitation liens, encumbrances, easements, deed restrictions, and other conditions that may affect the title or use of the subject property) and makes no representations regarding title or its limitations on the use of the subject property. Insurance against financial loss that may arise out of defects in title should be sought from a qualified title insurance company. (ii) Existing improvements on the subject property conform to applicable local, state, and federal building codes and ordinances, are structurally sound and seismically safe, and have been built and repaired in a workmanlike manner according to standard practices; all building systems (mechanical/electrical, HVAC, elevator, plumbing, etc.) are in good working order with no major deferred maintenance or repair required; and the roof and exterior are in good condition and free from intrusion by the elements. CBRE has not retained independent structural, mechanical, electrical, or civil engineers in connection with this appraisal and, therefore, makes no representations relative to the condition of improvements. CBRE appraisers are not engineers and are not qualified to judge matters of an engineering nature, and furthermore structural problems or building system problems may not be visible. It is expressly assumed that any purchaser would, as a precondition to closing a sale, obtain a satisfactory engineering report relative to the structural integrity of the property and the integrity of building systems. (iii) Any proposed improvements, on or off-site, as well as any alterations or repairs considered will be completed in a workmanlike manner according to standard practices. (iv) Hazardous materials are not present on the subject property. CBRE is not qualified to detect such substances. The presence of substances such as asbestos, urea formaldehyde foam insulation, contaminated groundwater, mold, or other potentially hazardous materials may affect the value of the property. (v) No mineral deposit or subsurface rights of value exist with respect to the subject property, whether gas, liquid, or solid, and no air or development rights of value may be transferred. CBRE has not considered any rights associated with extraction or exploration of any resources, unless otherwise expressly noted in the Report. (vi) There are no contemplated public initiatives, governmental development controls, rent controls, or changes in the present zoning ordinances or regulations governing use, density, or shape that would significantly affect the value of the subject property. (vii) All required licenses, certificates of occupancy, consents, or other legislative or administrative authority from any local, state, nor national government or private entity or organization have been or can be readily obtained or renewed for any use on which the Report is based. (viii) The subject property is managed and operated in a prudent and competent manner, neither inefficiently or super- efficiently. (ix) The subject property and its use, management, and operation are in full compliance with all applicable federal, state, and local regulations, laws, and restrictions, including without limitation environmental laws, seismic hazards, flight patterns, decibel levels/noise envelopes, fire hazards, hillside ordinances, density, allowable uses, building codes, permits, and licenses. (x) The subject property is in full compliance with the Americans with Disabilities Act (ADA). CBRE is not qualified to assess the subject property’s compliance with the ADA, notwithstanding any discussion of possible readily achievable barrier removal construction items in the Report.

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(xi) All information regarding the areas and dimensions of the subject property furnished to CBRE are correct, and no encroachments exist. CBRE has neither undertaken any survey of the boundaries of the subject property nor reviewed or confirmed the accuracy of any legal description of the subject property. Unless otherwise expressly noted in the Report, no issues regarding the foregoing were brought to CBRE’s attention, and CBRE has no knowledge of any such facts affecting the subject property. If any information inconsistent with any of the foregoing assumptions is discovered, such information could have a substantial negative impact on the Report. Accordingly, if any such information is subsequently made known to CBRE, CBRE reserves the right to amend the Report, which may include the conclusions of the Report. CBRE assumes no responsibility for any conditions regarding the foregoing, or for any expertise or knowledge required to discover them. Any user of the Report is urged to retain an expert in the applicable field(s) for information regarding such conditions. 4. CBRE has assumed that all documents, data and information furnished by or behalf of the client, property owner, or owner’s representative are accurate and correct, unless otherwise expressly noted in the Report. Such data and information include, without limitation, numerical street addresses, lot and block numbers, Assessor’s Parcel Numbers, land dimensions, square footage area of the land, dimensions of the improvements, gross building areas, net rentable areas, usable areas, unit count, room count, rent schedules, income data, historical operating expenses, budgets, and related data. Any error in any of the above could have a substantial impact on the Report. Accordingly, if any such errors are subsequently made known to CBRE, CBRE reserves the right to amend the Report, which may include the conclusions of the Report. The client and intended user should carefully review all assumptions, data, relevant calculations, and conclusions of the Report and should immediately notify CBRE of any questions or errors within 30 days after the date of delivery of the Report. 5. CBRE assumes no responsibility (including any obligation to procure the same) for any documents, data or information not provided to CBRE, including without limitation any termite inspection, survey or occupancy permit. 6. All furnishings, equipment and business operations have been disregarded with only real property being considered in the Report, except as otherwise expressly stated and typically considered part of real property. 7. Any cash flows included in the analysis are forecasts of estimated future operating characteristics based upon the information and assumptions contained within the Report. Any projections of income, expenses and economic conditions utilized in the Report, including such cash flows, should be considered as only estimates of the expectations of future income and expenses as of the date of the Report and not predictions of the future. Actual results are affected by a number of factors outside the control of CBRE, including without limitation fluctuating economic, market, and property conditions. Actual results may ultimately differ from these projections, and CBRE does not warrant any such projections. 8. The Report contains professional opinions and is expressly not intended to serve as any warranty, assurance or guarantee of any particular value of the subject property. Other appraisers may reach different conclusions as to the value of the subject property. Furthermore, market value is highly related to exposure time, promotion effort, terms, motivation, and conclusions surrounding the offering of the subject property. The Report is for the sole purpose of providing the intended user with CBRE’s independent professional opinion of the value of the subject property as of the date of the Report. Accordingly, CBRE shall not be liable for any losses that arise from any investment or lending decisions based upon the Report that the client, intended user, or any buyer, seller, investor, or lending institution may undertake related to the subject property, and CBRE has not been compensated to assume any of these risks. Nothing contained in the Report shall be construed as any direct or indirect recommendation of CBRE to buy, sell, hold, or finance the subject property. 9. No opinion is expressed on matters which may require legal expertise or specialized investigation or knowledge beyond that customarily employed by real estate appraisers. Any user of the Report is advised to retain experts in areas that fall outside the scope of the real estate appraisal profession for such matters. 10. CBRE assumes no responsibility for any costs or consequences arising due to the need, or the lack of need, for flood hazard insurance. An agent for the Federal Flood Insurance Program should be contacted to determine the actual need for Flood Hazard Insurance. 11. Acceptance or use of the Report constitutes full acceptance of these Assumptions and Limiting Conditions and any special assumptions set forth in the Report. It is the responsibility of the user of the Report to read in full, comprehend and thus become aware of all such assumptions and limiting conditions. CBRE assumes no responsibility for any situation arising out of the user’s failure to become familiar with and understand the same. 12. The Report applies to the property as a whole only, and any pro ration or division of the title into fractional interests will invalidate such conclusions, unless the Report expressly assumes such pro ration or division of interests. 13. The allocations of the total value estimate in the Report between land and improvements apply only to the existing use of the subject property. The allocations of values for each of the land and improvements are not intended to be used with any other property or appraisal and are not valid for any such use.

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14. The maps, plats, sketches, graphs, photographs, and exhibits included in this Report are for illustration purposes only and shall be utilized only to assist in visualizing matters discussed in the Report. No such items shall be removed, reproduced, or used apart from the Report. 15. The Report shall not be duplicated or provided to any unintended users in whole or in part without the written consent of CBRE, which consent CBRE may withhold in its sole discretion. Exempt from this restriction is duplication for the internal use of the intended user and its attorneys, accountants, or advisors for the sole benefit of the intended user. Also exempt from this restriction is transmission of the Report pursuant to any requirement of any court, governmental authority, or regulatory agency having jurisdiction over the intended user, provided that the Report and its contents shall not be published, in whole or in part, in any public document without the written consent of CBRE, which consent CBRE may withhold in its sole discretion. Finally, the Report shall not be made available to the public or otherwise used in any offering of the property or any security, as defined by applicable law. Any unintended user who may possess the Report is advised that it shall not rely upon the Report or its conclusions and that it should rely on its own appraisers, advisors and other consultants for any decision in connection with the subject property. CBRE shall have no liability or responsibility to any such unintended user.

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© 2019 CBRE, Inc. Addenda

ADDENDA

© 2019 CBRE, Inc. Addenda

Addendum A

ARTS DISTRICT – CONVERSIONS AND NEW DEVELOPMENT

© 2019 CBRE, Inc. Addenda

ARTIST – RESIDENTIAL CONVERSIONS

Location Original Use Current 2101 E. 7th @ Santa Fe 3-story, 63,786 SF Early artist in residency conversion. (688 Santa Fe) industrial

2135 E. 7th Place, e/o 2-story, 1922-built 2006-conversion, residential condominiums. 2121 Lofts industrial building Santa Fe

940 E. 2nd, through to 2-story; 1906-built 38 residential condominium units; 2011-conversion. 947 E. 3rd industrial building

1745 E. 7th @ Mill 6-story; 100,286 SF 57 work-live units. (Walnut Growers Ass.) walnut processing building

801 E. 4th @ Hewitt 2-story; 28,000 SF Gallery and 75-seat theater, classrooms. (Art Share) industrial building

510-530 Hewitt, Furniture warehouse 297 condominium units, 2007-conversion. 527 Molino and repair buildings (Barker Block Lofts)

825 E. 4th @ Alameda 5-story, 67,000 SF 2012 conversion; 53 condominium units. (Beacon Lofts) industrial building

837 Traction @ Avery 4-story; 27,792 SF Early conversion, 16-artiist in residence units. (Binford Lofts) industrial building

1850 Industrial @ Mateo 6-story; 1925-built 104 residential condominiums; 2005-conversion. (Biscuit Co. Lofts) bakery and garment mfg. building

500-530 Molino Street @ 2 & 3-story; 91 residential condominiums; 2006-conversion. Palmetto industrial building (Molino Street Lofts)

1855 Industrial @ Mateo 6-story; 1923-built 119 residential condominiums, 2006-conversion. (Toy Factory Lofts) warehouse and mfg. building

215 S. Santa Fe @ 3rd 3-story; 20 residential units; 2001-conversion. (Toy Warehouse Lofts) industrial building

1308 Factory Place 5-story; 100,500 SF Early work-live conversion. (part of Factory Place) warehouse/fish processing

900 E. 1st @ Vignes 3-story; 65,952 SF 45 artist in residence units, 1985-conversion. (Newberry) industrial building

652 Mateo @ Jesse 3-story; 33,566 SF 21 residential units. (Brick Lofts) wood working building

929 E. 2nd @ Vignes 2-story; 44,547 SF Artist-in-residency; converted in 1983. (Challenge Dairy Building) dairy products manufacturing

810-812 E. 3rd 4-story; 22,320 SF Artist lofts. baking supply distribution

1200 Santa Fe @ 8th 3 and 4 stories, 82,149 SF 53 residential loft units. (Art House) 2 industrial buildings

© 2019 CBRE, Inc. Addenda

COMPLETED MAJOR NEW ARTS DISTRICT CONSTRUCTION

Location Prior Land Use New Construction 100-300 S. Santa Fe Rail Yards 6-story; 438-unit apartment over retail; (One Santa Fe) 2014-2015 built.

695 S. Santa Fe Medium-sized industrial buildings 7-story, 180-unit live-work units over retail (AMP Lofts) (under construction).

930-950 E. 3rd @ Traction Industrial storage yard, parking 8-building; 472 live-work residential units (Aliso Apartments) over retail; in initial lease-up.

905 E. 2nd N/A 5-story, 2015-built, 320-unit apartment. (The Garey)

SWC Mateo & Palmetto Five warehouses 2016-2017 built, 262,628 SF retail and creative office (At Mateo) complex; substantial leased as office (Spotify, USC, Soylent).

© 2019 CBRE, Inc. Addenda

CREATIVE OFFICE CONVERSIONS

Location Original Use Current 2060 E. 7th @ Santa Fe 5-story; 444,139 SF Converted to creative office, (Ford Factory) auto and later toy manufacturing fully leased by Warner Music (Shornstein).

963 E. 4th @ Traction 4-story; 130,397 SF Converted to creative office, (Coca Cola) Coca Cola production building fully leased (Hudson Pacific).

405 Mateo, 1019 E. 4th Pl. 1- & 5-story; 100, 219 SF Converted to creative office, (The Maxwell) Maxwell House Coffee major lease to WeWorks (Hudson Pacific).

1330 Santa Fe @ Hunter 3-story; 19,000 SF industrial Converted to creative office. (The Huntsman)

777 Alameda @ 7th 4- & 6-story; 1,325,000 SF Converted to creative office and retail, major leases. (ROW DTLA) in 4 buildings; distribution and manufacturing (garment and food)

© 2019 CBRE, Inc. Addenda

Addendum B QUALIFICATIONS

© 2019 CBRE, Inc. Addenda

QUALIFICATIONS OF DAVID A. ZORASTER, MAI Director CBRE Valuation & Advisory Services 400 South Street, 25th Floor Los Angeles, California 90071 Phone: (213) 613-3658 FAX: (213) 613-3131

EDUCATION University of California at Santa Barbara, Bachelor of Arts Society of Governmental Appraisers, Seminars American Society of Appraisers, Seminars International Association of Assessment Officers, Seminars Appraisal Institute, Seminars and Courses American Society of Farm Managers and Rural Appraisers, Seminars University of California at Los Angeles, Extension Courses

LICENSES/CERTIFICATIONS • Member, Appraisal Institute (MAI) • Member, Royal Institute of Chartered Surveyors (MRICS) • California Certified General Real Estate Appraiser, No. AG001735 • Advanced Appraiser for Property Tax Purposes, State Board of Equalization • California Community College Instructor's Credential in Real Estate • UCLA Extension Certificate in Real Estate

GUEST LECTURER AND AUTHOR

• Society of Governmental Appraisers • International Assoc. of Assessment Officers • The American Society of Appraisers • So. Calif. Chapter of the Appraisal Institute • The Trust Real Estate Bankers Group • International Right of Way Association • The Appraisal Journal, Appraisal Institute • UCLA Extension • Society of Real Estate Appraisers • ULI (Urban Land Institute) • CLE (Continuing Legal Education)

EXPERT WITNESS

Los Angeles County Superior Court; Los Angeles County Assessment Appeals Board; San Francisco Assessment Appeals Board; United States Bankruptcy Court; United States Federal District Court; American Arbitration Association; Kern County Superior Court

EMPLOYMENT

CBRE Valuation and Advisory Services 2012 – Los Angeles County Assessor’s Office – Chief Deputy, Commercial & Investment Properties 2011 CB Richard Ellis, Inc. (Coldwell Banker) Valuation & Advisory Services 1978 – 2011 Los Angeles County Assessor's Office 1970 – 1978 Evening Instructor, Real Estate Appraisal – West Los Angeles Community College 1976 – 1978 Evening Instructor, Real Estate Economics – Glendale Community College 2009 – 2013

© 2019 CBRE, Inc. Addenda

SIGNIFICANT ASSIGNMENTS

Pacific Design Center, West Hollywood Hollywood Park/Santa Anita/Golden Gate Racetracks California Mart, Downtown Los Angeles Marriott/Intercontinental Hotel and Marina, San Diego Broadway (MCI) Plaza, Arco Towers, Union Bank Plaza Downtown Los Angeles Financial District Sony Pictures Plaza Lease Arbitration 2003 & 2008, Culver City Seventh Street Produce Market, Downtown Los Capitol Records, Hollywood, 2016 Lease Arbitration Angeles New Chinatown, Los Angeles Santa Monica Business Park Ground Rent Arbitration 2008 Los Angeles Center Studios, Los Angeles Hollywood Palladium, Hollywood East Fifth Street Skid Row, Los Angeles Egyptian Theater, Hollywood Million Dollar Theatre Building/Grand Central The Shrine Auditorium, Los Angeles Market, Los Angeles Times Mirror Square, Downtown Los Angeles Downtown Los Angeles Redondo Beach/King Harbor Rent Arbitration Chevron Corporate Headquarters, San Francisco Broad Museum, Museum of Contemporary Art Los Angeles Flower Mart, Downtown Los Angeles (MOCA), Colburn School, (ground leases) Bunker Hill Los Angeles Union Station, Downtown Los Angeles Patina Restaurant Group leaseholds, Federal Reserve Bank of San Francisco Headquarters, San Francisco Hollywood Bowl, Disney Concert Hall, The Cornfield State Park Site, Los Angeles LACMA, Norton Simon

© 2019 CBRE, Inc.

Attachment B

2110 Bay Street Mixed-Use Project City of Los Angeles Errata to the EIR October 2019 Page 37 Craig Lawson & Co., LLC Land Use Consultants

Memo To: Mr. Daniel Taban BAY CAPITAL FUND, LLC From: Jim Ries, Senior Vice President Craig Lawson & Co. LLC. Date: October 7, 2019 Re: 2110 Bay Street Mixed-Use Project

Bay Capital Fund, LLC. (“Client”), retained Craig Lawson & Co., LLC (“CLC”) to analyze the existing land uses in proximity of their development site located at 2110 East Bay Street1 (the “Project Site”) in the Central City North Community Plan area of the City of Los Angeles. The focus of the research is to understand the extent to which compatible and complementary non-industrial/non-manufacturing uses have replaced traditional industrial and manufacturing uses, while maintaining the area’s economic vitality. Compatible and complementary non-industrial/non-manufacturing uses are uses also permitted in the City of Los Angeles Commercial or Residential zoning districts, as opposed to traditional manufacturing uses which are only permitted in Industrial or Manufacturing zoning districts.

Utilizing Los Angeles Department of Building and Safety (“LADBS”) building records, CLC obtained as many non-manufacturing building permits and Certificates of Occupancy available within an area surrounding the site bounded by Palmetto Street to the north, the Los Angeles River to the east, Interstate 10 Freeway to the south and Alameda Street to the west (“Study Area”). According to our information, this Study Area contains 1,107 parcels of land. The permits were categorized into the following use groups: office, commercial (including stores and mercantile), hotel, restaurant (including catering), residential (including joint live work quarters (“JLWQ”)2, mixed-use3 (including JLWQ), mixed-use nonresidential, gas station, medical office, institutional and parking. Using these categories, along with a corresponding color, the various uses were plotted on the attached Radius Map (Exhibit A – Land Use Map Based on Building Permit Records). Parcels with no color are assumed to be traditional industrial/manufacturing uses.

1 Also includes 2130 East Bay Street and 2141 East Sacramento Street. 2 As designed, JLWQ units contain residential floor area as well as commercial floor area commonly utilized in small business incubation efforts. 3 Mixed-use could include commercial and/or a small portion of manufacturing uses. ______3221 Hutchison Avenue, Suite D Los Angeles, California 90034 (310) 838-2400 Phone (310) 838-2424 Fax

As indicated by the large diversity of colors found on the Land Use Map, it is clear that compatible and complementary non-industrial/non-manufacturing uses are spread throughout the Study Area. According to our research, approximately 30% (314 of 1,107 parcels) of the parcels reviewed have building permits issued by the Department of Building and Safety for non-manufacturing uses that are compatible and complementary to the Study Area’s traditional industrial and manufacturing uses. Approximately 10% of the total parcels contain a mix of uses, such as office, retail and restaurant, but not including JLWQ units. Restaurants are located on approximately 9% of the Study Area’s parcels as standalone uses or as part of a mixed-use project. Office (6.6%) and retail (7.6%) uses combined cover up over 14%4 of the parcels. Close to 7% of the parcels are developed with either JLWQ units that are part of mixed-use project (5%) or only contain JLWQ units (1.7%). These uses which are permitted in Commercial zoning districts demonstrates an evolution in the Study Area away from its traditional manufacturing uses to job-creating uses that further the City’s desire to protect its economic vitality.

The following observations are made after reviewing the LADBS building permit information:

 JLWQ Uses: A substantial number of properties around 7th Street between Alameda Street and the LA River are JLWQ projects (purple) or mixed-use complexes that include JLWQ (yellow) uses consisting of: o Large mixed-use developments including a seven-story building with ground floor retail and 119 JLWQ units at 1855 Industrial Street (permit issued in 2005), and an eight-story building with ground floor retail and 104 JLWQ units at 1850 Industrial Street (permit issued in 2009). o Many of the JLWQ projects are small to medium in scale and are characterized by 2- to 4-story buildings that have been adaptively reused. Examples include a property at 2101 7th Street (permit issued in 1955) with 39 JLWQ units, a property at 712 Santa Fe Avenue (permit issued in 2012) with 9 JLWQ units and ground floor restaurant, a property at 720 Santa Fe Avenue (permit issued in 2004) with 22 JLWQ units, and a property at 2038 Bay Street (permit issued in 2011) with 4 JLWQ units.

 Commercial Uses: A variety of single use commercial (red), mixed use without JLWQ (green) and restaurant (burnt orange) are scattered throughout the vicinity including: o Many well know restaurants including Bestia at 2121 East 7th Place (permit issued in 2013), Brera Ristorante located at 1331 E 6th Street

4 Includes mixed use projects and standalone uses.

Page 2 of 4 (permit issued in 2011) and the Church & State located at 1850 Industrial Street (permit issued in 2009). o The property at 634 Mateo Street (permit issued in 2018) is occupied by a video game arcade and the property at 1005 Mateo Street (permit issued in 2018) is occupied by a large plant nursery. o The property located at 584 Mateo Street (permit issued in 1995) is developed with a retail establishment. o 661 Imperial Street (permit issued in 2009) contains a grocery store, and there is a fish market at 584 Mateo (permit issued in 2009). o The @Mateo project, located at 555 Mateo Street (permit issued in 2016) contains approximately 132,000 square feet of office, retail and restaurant space. o A private club, known as the Soho House, offering hotel, restaurant and bar amenities, located a 1000 Santa Fe Avenue (permit issued in 2017).

 Office use: A variety of office uses (pink) scattered throughout the Study Area with a high concentration located near the Project site south of 7th Street on. Notable properties with office space include: o 2159 Bay Street, abutting the site, (permit issued in 2016) is developed with a high-tech office use (Hyperloop). o The Ford Factory renovation, located at 777 Santa Fe Avenue (permit issued in 2017), is an example of a successful conversion of an existing underutilized manufacturing building and converting it to a create office structure. o 2222 Damon Street (permitted issued in 1980), 1407 6th Street (permitted issued in 1957) and 1220 6th Street (permitted issued in 1951) are examples of office uses that have been part of this community for decades.

 Institutional uses: The following Institutional uses (turquoise blue) can be found in the Study Area: o A charter elementary school at 1617 7th Street (permitted issued 2006) and Metropolitan High School is located at 727 Willow Street5. o An art gallery at 1018 Santa Fe Avenue (permit issued in 2005).

5 This is an LAUSD school and is not required to obtain a City of LA permit.

Page 3 of 4 In conclusion, the Radius Map’s land use pattern illustrates an evolution from traditional industrial and manufacturing job-creating uses to light industrial/manufacturing uses as well as complementary non-industrial uses including JLWQ, creative office, and related retail/cultural/entertainment uses which maintain the Study Area’s focus on job creation and the City’s economic vitality.

Page 4 of 4 26 5 TH 2 25 4 36 35 1 194 24 37 34 3 23

38 2 ST PL 4 6 ST

33 1 ST ST

39 5 ST 3 40 32 4 TH SANTA FE ST 4 6 8 41 31 3 42 5 7

30 RIVER 43 6 8 10

29 1 LT 44 5 AVE 23 7 9 45 28 LT A 8 AVE 10 12

46 27 7 2 22 3 47 9 11 26 21 10 12 14 25 9 ATCHISON TOPEKA & SANTA FE 20 11 13 RAILROAD COMPANY'S R/W 24 19 12 14 16 "UNNUMBERED LT" 24 23 11 LT B CERES 18 13 15 AVE 22

MOLINO 47 25 17 14 45 46 16 18 1 43 44 21 41 42 48

13 17 HEWITT 39 40 26 16 15 LT A 20 27 15 16 18 ST 19 20

COLYTON PALMETTO 15 17 19 28 14 18 ST ST "UNNUMBERED LT"

29 13 18 SEATON 20 17 17 30 12 19 PALMETTO 16 31 11 20 15 10 19 3 27 32 29 28 "UNNUMBERED LT" 30 14 32 31 34 33 1 9 36 35 13 4 37 8 PALMETTO AVE 38 12 11 12 13 14 2 37 5 6 9 10 7 2 3 4 8 5 1 7 36 11 "UNNUMBERED LT" 35 34 6 10 6 33 5 9 "UNNUMBERED LT" 20 4 18 19 16 17 8 7 14 15 3 12 13 10 11 7

26 27 28 "UNNUMBERED LT" 2 25 D C F C A L 21 22 23 24 8 20 6 TH 6 15 16 17 18 19 1 4 5 9

4 ST 23 3 33 24 PL WILLOW 27 2 LT A 3 25 26 FACTORY 1 15 13 14 11 12 9 10 7 8 5 6 3 4 52 53 2 47 48 49 50 51 1 A 42 43 44 45 46 37 38 39 40 41 32 29 30 31 29 28 LT 1 30

40 WILDE 42 41 44 43 33 34 35 36 46 45 48 47 50 49 52 51 54 53 ST WHITTIER WILDE 74 75 76 77 78 79 69 70 71 72 73 64 65 66 67 68 59 60 61 62 63 54 55 56 57 58 BLVD LT 1 ST ST 76

77 25 6 TH

26 ST ST 27 74 75 78 6 TH 72 73 28 70 71 69 1 68 66 67 28 1/2 LT 5 65 79 ST 63 64 2 62 61 59 60 57 58 3 LT 2 55 56 105 80 106

9 "UNNUMBERED LT" 4 ST 8 1/2 128 5 129 104 81 3 107 6 147 "UNNUMBERED LT" 148 127 103 7 130 82 108

8 146 ANGELES LOS LT 1 LT C LT 7 LT D LT 8 LT E LT 11 149 126 131 102 83

SANTA FE SANTA 109

CENTRAL 145

MATEO 150 125 IMPERIAL 132 LT 3 101 84 ALAMEDA 110

MILL 144 LT 4 151 124 133 100 MESQUIT 85 111 143 123 152 99 134 86 112 142

INDUSTRIAL LT 3

ST 153 122 ST

ST LT E 135 98 87 LT 8 ST 13 LT C LT 7 LT D 113

141 154 121 RIVER

12 97 136 AVE 88 ST LT 2 114 11 140 LT A 10 155 120 14 137 89 LT 4 LT B LT 12 I 139 15 156 1 16 119 LT 3 138 90 2 17 95 LT 2 3 18 LT 1 118 LT A 19 94 91 4 194 5 192 228 93 LT F 158 92 6 195 7 191 8 159 227 LT 4 261 262 9 "UNNUMBERED LT" LT 6 196 230 LT 10 190 226 7 TH 160 263 197 ST 189 161 264 LT A G 260 231 ST 265 "UNNUMBERED LT" JESSE

259 225 D C F C A L LT 5 198 232 188 266 INDUSTRIAL 162 224 258 199 233 187 LT 1 267 163 223 257 A 200 234 186 268 ST 164 222 201 256 235 INDUSTRIAL 185 269 165 221

255

L A C F C D C F C A L 202 LT" "UNNUMBERED ST 236 F 184 270 166 220 E 203 254 237 183 271 167 219 204 253

182 238 ANGELES LOS LT 1 272 168 218 LT 2 205 252 239 181 273 "UNNUMBERED LT" 169 206 217 251 ST 240 180 274 216 170 207 250 241 A 179 275 171 215 249

B

7 TH MILL 208 210 245 209 242 243 244 B 178 247 248 174 175 176 177 211 246

172 173 212 213 214 276 277 278 279

IMPERIAL SANTA FE SANTA ST MESQUIT

ST 7 TH

ST ST 7 TH 6 ST 5 4 3 2 1 ST 1 2 A 22 21 20 "UNNUMBERED LT" 19 18 17 16

"UNNUMBERED LT" 15 14 13 12 11 10 9 8 7 6 B 5 4 3 2 1 13 12 11 C 7 10 9 8 7 AVE 6 5 16 4 3 2 1 3

8 MATEO 15 "UNNUMBERED LT" 14 30 35 9 LT A 11 44 14 15

CHANNING 23 24 25 26 27 28 29 31 10 34 36 37 38 39 40 41 42 47 48 10 45 49 LT 1 13 16 LAWRENCE 6

9 32 33 LT" "UNNUMBERED 11 WILSON 46

7 TH DECATUR 17

12 LT" "UNNUMBERED SANTA FE SANTA PL 7 8 7 TH 18 PL 7 TH 3 LT "A" PL 19 2 70 12 63 11 62

ALAMEDA 10 20 9 LT "A" 8

7 78 ANGELES LOS 77 76 75 74 73 72 71 69 62 49 48 47 46 45 44 43 63 21 8 7 6 5 4 3 2 1 68 61 64 22

1 67 60 ST 3 23 65

ST 4 66 59 66 5 24 ST 2

79

81 80 82 83 84 85 6 86 65 58 9 10 11 12 13 14 56 55 54 53 52 51 50 AVE 67 15 16 1 25

7 RIVER B 8 64 57 68 9 26

1 VIOLET VIOLET ST 2

28

95 99 4 86 29

87

88

89 90 91 92 93

94 96

100 104 103 105 106 107 108 109

5 87 85 84 83 82 81

80

79 78 77 30 97 101 88

31 "UNNUMBERED LT" "UNNUMBERED 98 102

1 2 89 32

3 130 6

121 117 4 90 33 LT "A"

7 131

5 122 91

93 118 94 95 96 97

98 SANTA FE SANTA 99 34 100 101 102 127

128 126

129 125

112 115 111 113

BAY 116 114 110 123 119

92

35 132 120 124 36 PCL 1 BAY ST 15 14 13 37 12 ST 11 10 BAY 9 8 7 114 6 38 5 4 3 1 7 2 ST 1 ST 115

18 39 17 16 SUBJECT SITE 15 74 72 70 68 66 64 14 84 82 80 78 76

C 13 116

12 40 11 10 9 2 8 7 3 6

6 117 41

5 4 D C F C A L 3 LT A LT B 2 1

B LT B

118 42

19 WILSON 4 20 65 5 LT" "UNNUMBERED 21 83 81 79 77 75 73 71 69 67 63 119 22 43 23 A 24 25 26 27 28 120 29 62 30 31 36 32 33 35 SACRAMENTO 34 SACRAMENTO SACRAMENTO ST

1

61 144 8 TH ST ST 19 PCL 2 18 2

17 145 143

60 142 51 53 55 141

45 47 49 140 137 41 43 139 37 39 138 136 134 16 135 133 D 15 132 14 13 3 12

ST 11 59 146 10 4 9 8 7

1 147 25 1 6 8 TH 58 24

LAWRENCE 20 21 4 148 22 5 23

23 24 48 50 52 54 32 34 36 38 40 42 44 46 57 ANGELES LOS

25 149 MATEO

153 151 152 154 155

157 156

26 161

160 159 158 27 162 163 28 22 15 29 14 30 31 56 13 32 150 11 33 21 34 12 10 35 9 8 36 7 20 6 5 8 TH 4 ST 3 1 19 2 1 3 2

18 3 178 18 17 164 16 ST 2 165

15 166

14 167 168

13 3 169 17 179 170

177

176

175 174

12 173 171 2 172 LT 1 11 12 9 8 7 6 5 4 MC GARRY 21 20 19 18 17 16 15 14 13 "UNNUMBERED LT" 10 9 DAMON 16 8 ALAMEDA

7 4 8 180 SANTA FE SANTA 6 ALLEY 5 MATEO 1 SANTA MONICAMONICA ST RTE 10 15 4 ST 1 LEMON 9 181 FWY SANTA MONICAMONICA 2 3 7 182 8 10 200

ST 9 25 RTE 10 4 12 13 14 15 16 17 18 19 20 21 ST 22 23 24 28 30 31 32 183 29 201

10 AVE 25 "UNNUMBERED LT" 11 LT 1 26 11 202 DAMON FWY SANTA MONICA 27 12 ST ST DAMON 203

13 24 ENTERPRISE

204 ST RIVER 14 47 28 R/W ST

23 33 34 35 36 37 38 39 40 41 42 43 44 45 46 ST

29 205 R/W LT 2 22 COS. 30 HUNTER 206

66 14 15 21 31 12 13 16 65 207 10 11 8 9 57 58 59 60 61 62 63 64 7 54 55 56 2 5 6 20 4 32 LT 2 3

RAILROAD RTE 10

19 ST ST 33 243 ENTERPRISE ST

18 19 LT 1 23 34 31 30 29 28 27 26 25 24 22 21 20 COMPANY'S 244 19 18 20 17 17 81 35 82 21 80 245 ENTERPRISE 74 75 76 77 78 79 211

16 PACIFIC 36 18 ST LT 3 212 LT 2 HUNTER LEGEND: 15 ST HUNTER 37 22 ST 17 OLYMPIC 213 23 97 14 96 38 279

16 95 98 214 -OFFICE SOUTHERN 13 39 280 15 215 278 277 276 275 274 273 272 271 270 269 268 267 266 265 264 263 262

25 RAILWAY LT 4 12 40 14 1 216 281 -COMMERCIAL (INCLUDING STORES AND MERCANTILE) 2 HUNTER ST 26 3 LT 5 11 41 13 34 217 282 27 35 -HOTEL 10 36 42 130 131 132 133 12 125 126 127 128 129 218 283

4 ST 134 28 1 123 9 2 122 124 43 286 287 288 289 290 291 -RESTAURANT (INCLUDING CATERING) 11 219 284 292 293 294 295 296 297 298 299 300 301 302

5 33 3 303 29 D C F C A L 34 8 44 35 10 220 285 6 32 36 139 144 145 146 147 148 149 150 30 SANTA MONICA 142 143 -MIXED USE-RESIDENTIAL 137 151 7 4 137 221

45 FE SANTA 1 140 9 7 31 FWY 31 2 138 6 5 3 PORTER PORTER -MIXED USE NON-RESIDENTIAL 46 33 ST ST 141 8 8 30 34 32 ST 35 PORTER 222 47 6 32 36 243

ST 20 -SERVICE STATION 7 9 29 33 4 R/W "UNNUMBERED LT" BLVD 241 246 246 48 7 31 239 245 201 244 237 6 235 1 2 3 21 19 18 17 16 15 14 13 10 28 OLYMPIC 4 5 12 11 10 2 1 34 5 33 6 7 MATEO 8 7 6

-MEDICAL OFFICE 8 30 247 5 4 3 2 1 49 & 32 227 22 5 11 27 U01324 225 35 6 202 9 50 29 31 16 ST 15 4 7 14 211 -PARKING - AUTOS 12 26 13 209 23 36 12 11 203 10 8 10 28 9 51 MC GARRY 3 24 13 25 R/W 37 27 245 4 204 3 -INSTITUTIONAL 11 26 27 25 27 28 29 30 31 32 33 2 14 24 5 34 35 36

38 ST 246 TOPEKA CHANNING 12 6 205 1 26 -RESIDENTIAL 15 23 7 6 39 13

14 CO.'S RTE 10 28 8 LT 3 16 22 7 26 10 TH CO'S. 36 LT 1 -SUBJECT SITE - 2110 BAY ST. 25 17 27 24 9 20 21 8 BLVD OLYMPIC 23 10 TH 22 26 LT 2 12

21 10 ST TRANS. LT 2 RAILROAD 20 18 9 10 TH 45 19 25 14TH 13 11 ST 46 4 17 10 "UNNUMBERED LT" 5 14 24 PACIFIC LT 1 6 1 37 12 7 38 47 16 11 39

40 SANTA FE 8 15 23 41 9 2 42 ALAMEDA MONICA 43 10 13 44 48 15 12 45 11 3 LAWRENCE 16 LT F

22 LEMON 7 12 ST 46 PACIFIC ST

WILSON LT C ELWOOD 14 LT E

SANTA CHANNING 13 49 ANGELES LOS 14 ST LT 3

17 21 ATCHISON MATEO UNION LT D 47 48 SOUTHERN 0

CASE NO. GC MAPPING SERVICE, INC. DATE: 08-20-2019 3055 WEST VALLEY BOULEVARD LAND USE MAP BASED ON BUILDING PERMIT RECORDS SCALE: 1" = 200' ALHAMBRA CA 91803 (626) 441-1080 FAX (626) 441-8850

JAMES D. RIES 3221 Hutchison Avenue, Suite D Los Angeles, Ca 90034 (310) 838-2400 EXPERIENCE: Craig Lawson & Co., LLC – Land Use Consultants, Los Angeles California Senior Vice President June 1999 to present

Managed land use planning, entitlement approvals and multi-disciplinary team efforts to facilitate in-fill development projects covering a wide spectrum of types and sizes, including commercial, institutional, residential and mixed-use projects, which require close coordination with City of Los Angeles public agencies, including Planning, Building & Safety, Transportation and Public Works to streamline the approval process.

Initiated strategy for property owners and developers to acquire entitlements and satisfy due diligence issues that affect development decisions. Established and maintained extensive professional knowledge of relevant planning policies and regulations including the Zoning Code, the General Plan, Specific Plans, the Subdivision Map Act and CEQA.

Achieved the entitlement approvals for major multi-family residential projects that locate housing proximate to jobs and transit. Since 2002, these accomplishments in the Central City area of downtown th include the approvals for the Concerto/Apex, 8 & Grand, Atelier, 3 residential towers for Onni Development, and Amacon developments, resulting in entitlements for approximately 3,0000 residential units over ground floor commercial space within walking distance of the region’s largest employment and transit hub.

Activated the successful Arts Districts residential renaissance by securing entitlements for numerous adaptive-reuse projects in that area. These accomplishments include bringing vitality to abandoned and underutilized commercial and industrial areas, including the Toy Factory Lofts, Biscuit Lofts, Barker Block, Eastern Columbia, Federal Industrial Lofts, and the Molino Lofts buildings, most of which are acknowledged as landmark projects for redeveloping and reusing properties in the urban core.

Launched a variety of affordable housing projects citywide to create new and innovative housing opportunities, while satisfying City’s objectives for low income housing opportunities. The 100% affordable developments initiated include the Roland Curtis, SP7, Ivy Terrace, San Lucas, Hart Village and Morgan Place projects, in addition to mixed income projects such as the Abbot Kinney and Pioneer Bakery Lofts. Selma Community Housing, New Dana Strand, Rio Vista and Pico Robertson Senior Community projects are examples of Public Private partnerships.

Promoted the expansion of necessary educational uses, including TurningPoint School, The Help Group, Yeshiva University of Los Angeles and the Maimonides Academy.

Coordinated and supervised, in the capacity as Vice President, the firm’s staff efforts to process a wide range of development projects. . C.W. Cook Co., Inc., Culver City, California Associate Planner July 1998 – May 1999

Initiated and managed the redevelopment of the northwest corner of Sunset and Vine in the Hollywood area of the City of Los Angeles. The original concept sought to create an urban entertainment center containing movie theaters, and neighborhood serving retail uses and restaurants.

Malibu Bay Company, Malibu, California Planner July 1996 – May 1998

Directed a wide range of responsibilities including permit expediting, future development planning, construction management and property management. Due to the large amount of developed and undeveloped property owned by the Malibu Bay Company, interacted constantly with the City of Malibu’s Planning and Building & Safety staff regarding various types of permits. Achieved professional knowledge by hands-on experience with the City’s General, Specific and Local Coastal Plans. Performed property management duties for an 115,000 SF retail center, in addition to being the on-site owner’s representative for a 10,000 SF remodel project.

Bobrow/Thomas & Associates, Los Angeles, California Planner January 1993 – June 1996

Involved with the firm’s planning department that offered many different services including Master, Medical, Site and Campus Planning. Managed the research of pertinent issues, report writing, maintenance of planning database and site design. Achieved proficiency in several computer software programs including Auto Cad, Excel, Quattro-pro, Microsoft Word and other industry specific data base systems. Stanley Hoffman & Associates, Los Angeles, California Planning Intern June 1992 – September 1992

Assisted in the response to the Clean Air Act and Air Quality Management District regulations imposed on a consortium of 17 Southeast Los Angeles cities for a company that focused on Urban Public Finance.

Bobrow/Thomas & Associates, Los Angeles, California Accounting Clerk June 1985 – December 1992

Created and maintained the financial spreadsheets used to assist the company’s managers in their financial planning, including profit/loss reports, staffing projections and earnings reports.

EDUCATION: University of California, Los Angeles: Los Angeles California Masters of Arts in Urban Planning June 1993 Social Policy and Analysis concentration combined with Environmental Issues Bachelor of Arts in Political Science March 1991 PROFESSIONAL AFFILIATIONS • Former member and Chair of the City of Santa Monica Planning Commission • Former member and Chair of City of Los Angeles Commercial Reuse Task Force, Appointed member of the Santa Monica’s Sustainable City Task Force (former chair) • Participant, Westside Urban Forum

COMMUNITY INVOLVMENT • Past board member of the Pico Neighborhood Association • Member of the Community Corporation of Santa Monica sponsored Home Ownership Study Group