Monday, September 24, 2018

Oppose New Four Story Building in Oakwood; It's a Dangerous Precedent

Please send the following message to city planner Oliver Netburn ( opposing Venice Community Housing Corporation's proposal to build the first four story building in the Oakwood neighborhood.

Dear Mr. Netburn, the VCHC's proposal is too tall, too dense, has too little parking, and is way out of character with Venice.  It is extremely out of step with both the Venice Specific (land-use) Plan and the desires of residents for Venice to remain a low-rise community.  Approving its 45-foot height and almost no parking will set a dangerous precedent. Send it back to the drawing board!

The hearing is Wednesday at 9:30 AM, so please email your message by the end of business Tuesday.

More details are provided below.

Thanks for helping stop this classic example of over-development.

Dear Mr. Netburn,

I am writing on behalf of the Venice Stakeholders Association to oppose the Rose Apartments project proposed for the former site of the offices of Venice Community Housing Corporation (VCHC) unless the project’s height, setbacks, fa├žade, landscaping and parking are modified.

As is readily evident from elevations of the project presented on VCHC’s website, the project will tower over all nearby structures.  Further, the massing, height and lack of required parking stand in extreme violation of the Venice Local Coastal Specific Plan.

To start with, the project description, as declared on the CPC’s hearing notice and elsewhere, is incorrect:

Demolition of commercial office uses and the construction, use maintenance of a four-story, 35 unit permanent supportive housing complex with ancillary administrative office.  

This is a mixed-use project with ground floor commercial offices to be occupied by Venice Community Housing Corp., a private corporation, with a 35% plus 20% density bonus project totaling 35 residential units.  The commercial component is not ancillary to the residential housing because VCH intends on conducting their own separate corporate business - which is now conducted in a structure on the same site – within the new structure - unrelated to the housing component. Outlined below are several facts which call for the modification of the project to conform with the VLCSP, city ordinances, Coastal Commission precedents, environmental best practices, and a variety of community concerns.

1.   Number of stories and height of the building: The applicant has not designed the project within the California state standard density bonus guidelines but has requested “off menu incentives.” Off menu incentives are requests that exceed the “by right” incentives permitted under the density bonus laws.  As an example, the SB 1818 state density law permits an applicant to exceed the height limit by one story and not more than 11 feet. This applicant is requesting two additional stories and 20 additional feet of height.  As proposed this building would be the only four-story building in the entire Oakwood subarea of the Venice Land Use Plan. The permitted height in the coastal zone for this project is 25-feet for a flat roof and the proposed project is 45 feet high. Thus, this project represents a dangerous precedent both for future developments under the existing Specific Plan and for the message its approval would send to city planners now engaged in drafting the Venice Local Coastal Plan and revising the Specific Plan.  Venetians support the low-rise nature of our community and want it maintained.

2.   Parking The required parking for this project under the VLCSP is 89 spaces. In the past the Coastal Commission has determined that state density bonus laws DO NOT override the California Coastal Act.  Numerous affordable housing projects within the Coastal Zone have been required to provide one parking space per unit. The proposed project as designed and presented to the Venice Neighborhood Council provides only 12 parking spaces for the 35 residential units of which seven parking spaces are proposed off-site. Based on the Los Angeles Municipal Code section 12.26E5 and documentation from the property owner who owns the offsite parking lot located at 225 Lincoln Boulevard, these seven off-site parking spaces will not be available for the new project, as explained below.

3.   Off-Site Parking Affidavit Parking affidavit 4123, which was recorded on October 11, 1973, was an agreement signed between a building tenant, Safeway No. 45, located at 225 Lincoln Boulevard, and The Children’s Center for Educational Therapy, located at 718-720-722 Rose Avenue. Parking affidavits are required to be signed by the legal owners of the real property of both properties and not tenants. Safeway No. 45 was not the legal property owner and had neither the authority, permission nor right to sign said agreement. Parking affidavit 4123 should be deemed null and void. Furthermore, per city policy, parking affidavit 4123 will no longer continue in effect once the existing structures on 718-720-722 Rose are demolished.  The seven offsite parking spaces which VCHC has publicly claimed will be satisfied by the affidavit are non-existent.

4.   Building Setback Requirements from Rose Avenue The Specific Plan, in the Oakwood subarea, requires “any portion of the roof that exceeds 25 feet be set back from the required front yard at least one foot in depth for every foot in height above 25 feet.” The proposed project does not comply with this step back requirement and proposes a 45-foot high wall with no windows facing Rose Ave at the 2nd, 3rd and 4th floors. The proposed design does not provide a varied and articulated facade with visual interest to pedestrians. The primary ground floor entrance to the residential entrance does not face the street and is accessed from a narrow side yard and a 14-foot passageway and is located more than 75 feet from the sidewalk.

All of these design elements violate the Specific Plan, thus precluding the CPC’s granting of a Project Permit under the plan.  Further, the ground floor office space, which is not a visitor serving use, is set two feet below the grade of the sidewalk, which is inconsistent with the Los Angeles Citywide Design Guidelines.

5.   Environmental Categorical Exemption The applicant is unacceptably proposing no environmental review for the proposed project despite requesting a project with density almost double that permitted in the zone, the tallest building in Oakwood by an entire floor, inadequate parking, no loading zone, blank walls facing Rose Avenue, no required step backs from the street, all of the mass of the building facing the adjacent neighbors’ properties, and has not provided a detailed explanation of what services will be provided on-site to residents and in the ground-floor corporate office for nonresidents, which may generate vehicular traffic. Your department should call for a full environmental review.

6.   The City of Los Angeles and California Coastal Commission have already set a precedent for mixed-use projects with a residential density bonus on Rose Avenue and this project is inconsistent with that precedent.

On August 9, 2005 The California Coastal Commission approved a precedent-setting mixed-use project which included a density bonus project with 70 residential units located at 512 Rose Avenue after an appeal was filed and a substantial issue was found. The De Novo Permit Special Conditions relating to the project set various building design conditions; these same conditions should apply to the 720 Rose Project and the design should be modified as follows: 

Building Design: The 720 Rose project should be designed with a varied and articulated facade that provides visual interest to pedestrians. Frequent windows and the primary ground floor entrances for the residential units shall face the streets. Porches, bays and balconies are encouraged, consistent with the City's setback requirements

    • Building HeightThe 720 Rose project should be limited to three stories with a 33-foot high flat roof.  Placing the residential portion of the project on top of the commercial portion does not give the applicant a right under the density bonus to a 40 foot height, just a 30 foot height.  The applicant should be told to remove the corporate office space or remove one floor of residences.

    • Landscaping: The 720 Rose project should be designed with landscaping in order to enhance visual quality.  To preserve water, the side of the project facing the public street, Rose Avenue, should be landscaped with large canopy street trees and low water use plants, consistent with City requirements. 

    • Parking: With a reduction to 33 feet in height as recommended above, the number of units would be reduced to 22, so project parking requirement should be:

a.    VCHC corporate ground floor offices - 10 spaces
b.    one space for each resulting affordable unit or 22 spaces
c.    two (2) spaces for the manager’s unit, and
d.    ¼ guest parking space per unit - equaling 6 parking spaces - for a total of 40 spaces. 

The additional required parking should be provided below grade.

Having managed 160 units of affordable housing in the San Fernando Valley for five years I know from experience that while homeless individuals usually move in without a vehicle, this does not remain the case in many instances.  As they stabilize their situation, receive benefits and job training, and eventually obtain employment, one of their first purchases is a vehicle.  There also is the likelihood that some of the eventual residents of the Rose Apartments will be former “car campers;” by definition they will arrive with a vehicle.  We have seen this here in Venice before.  During Councilman Bill Rosendahl’s tenure, one of the first vehicle dwellers that PATH moved into an apartment in a Breezes del Mar building on California Avenue at Electric Avenue parked his empty camper across the street from the building for months, taking two parking spaces away from residents. 

Thank you for your consideration of our views on this project.


Mark Ryavec

Mark Ryavec, President