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 unless the project’s height, setbacks, façade, landscaping and parking are modified.
As is readily evident from elevations of the project presented on VCHC’s website, the project will tower over all nearby structures. Further, the massing, height and lack of required parking stand in extreme violation of the Venice Local Coastal Specific Plan.
- 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.
- Parking The required parking for this project under the Venice Local Coastal Specific Plan would require 89 parking spaces. In the past the Coastal Commission has determined that state density bonus laws DO NOT trump 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 provides 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 Blvd., these seven off-site parking spaces will not be available for the new project.
- 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, 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 supposedly satisfy part of the parking requirement for the project are non-existent.
- Building Setback Requirements from Rose Avenue The Venice Local Coastal 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. 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.
- 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 at the ground-floor corporate office for nonresidents, which may generate vehicular traffic. Your Board should call for a full environmental review.
- 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.