Los
Angeles Department of City Planning
LAX/Playa Vista Section
Attn: Sue Chang, City
Planner
200 N. Spring St., Floor 720
Los Angeles, CA 90012
Re: Response/Statement to Playa Vista’s Phase II
(The Village) EIR No. ENV-2002-6129 EIR from the Mar Vista Community Council Transportation Committee
OPENING STATEMENT:
After a careful review, the
Mar Vista Community Council Transportation Committee finds that the Playa Vista
Phase II Draft EIR is seriously incomplete in its analysis of the project’s
traffic impacts on the Mar Vista Community. Specifically, the DEIR is void of an analysis of the cut
through traffic, which would seek out the residential local and collector
streets within our community, especially in the area north of Washington Blvd. This deficiency also appears to
deliberately leave out the traffic impacts on Inglewood Blvd. - one of three north/south arteries that leads
directly from the project site and through our community.
This omission greatly
understates the overall traffic burden and the resulting air quality impacts
placed on our community. Although
Centinela Ave. was well studied, its current and worsening condition places
increasing pressure on the residential Local/Collector sections of Inglewood
Boulevard, Grand View Boulevard, Beethoven Avenue, Walgrove Avenue, Palms
Boulevard and Veteran Avenue as convenient cut-through routes.
The other concerns
discovered during this review, was the apparent disregard for the Goals,
Objectives and Policies contained in the Los Angeles General Plan, specifically
the Palms–Mar Vista–Del Rey Community Plan and neglecting to address that allowable Phase 2
traffic maximums are tied to a yet-to-be-achieved cap on Phase 1 traffic.
The MVCC Transportation Committee will seek to explain
our fundamental concerns with the DEIR in the following manner:
1.
PROJECT’S
TRAFFIC IMPACTS AND RELEVANT FACTS
2.
VIOLATIONS
OF THE LOS ANGELES GENERAL PLAN POLICIES
a)
VEHICLE TRIPS (taken from Section
I.G. Summary of Project Impacts)
The proposed project will generate 24,220 vehicle trips per day. Of
these, 1,626 trips would occur in
the AM peak hour and 2,302 trips
would occur during the PM peak hour.
b)
EXISTING TRAFFIC CONDITIONS (At
Busiest Mar Vista Intersections)
PEAK AM, PEAK
PM
Centinela/Venice – V/C*:
1.128 LOS “F” V/C*:
1.167 LOS “FF”
Lincoln/Venice – V/C*:
1.08 LOS “F” [Not a MVCC intersection but affect
us.]
Lincoln/Venice – V/C*:
1.016 LOS “F”
[Not a MVCC intersection but affect us.]
Centinela/National – V/C*:
1.128 LOS “F” V/C*:
1.167 LOS “FF”
Centinela/Ocean Park – V/C*:
0.919 LOS “E” V/C*:
1.308 LOS “FFFF”
Centinela/Washington Place – V/C*:
0.894 LOS “D” V/C*:
0.936 LOS “E”
Centinela/Washington Boulevard - V/C*:
0.757 LOS “C” V/C*:
0.887 LOS “D”
Walgrove/Venice Boulevard – V/C*:
0.711 LOS “C” V/C*:
0.859 LOS “D”
Walgrove/Palms – Not
addressed
Beethoven/Washington Boulevard - Not addressed
Inglewood/Venice - Not rated nor mentioned anywhere in the analysis.
*V/C – Volume/Capacity Ratio: The volume/capacity ratio compares the capacity of a roadway with the number of vehicles actually using the roadway. For example, a V/C ratio of 1 means that the roadway is at capacity. Intersections with V/C ratios of 1 or more are subject to grid-lock and are appropriated rated “F” for “Failure”..
Page
863, Section IVK(1) Traffic & Circulation, states that trip generation will
increase by 16% along the north/south Centinela corridor and the
increase will be 18% along Lincoln Blvd.
c) MITIGATION CLAIMS
Section
V.I. (1) page 887 contains the proposed project mitigation measures, referred
to as the “Village at Playa Vista Transportation Improvement
Measures”. It was stated
that if any of the proposed mitigation measures are ”determined not to be
feasible or if it is not possible to obtain the necessary permits, then a
significant impact(s) will remain”.
One
of the mitigation measures at Centinela/Venice proposes to re-stripe a separate
southbound right turn lane so that there would be two through lanes, a single
left hand turn lane and a separate right turn lane.
On
page 910, Playa Vista claims that it will mitigate the effects of traffic
generated by its proposed project at every intersection, using the three
main mitigation tools cited in Section V.I. (1): Transit mitigations,
Roadway improvements and Signalizations improvements.
Furthermore, Playa Vista claims that its mitigation efforts will result
in no significant impact to the Centinela/Venice intersection and at every
intersection surrounding the
project site.
The Los Angeles General
Plan, specifically the sub-section called the Palms-Mar Vista-Del Rey
Community Plan, contains several very
important Goals in the Transportation Section. These Goals, which are shared by every Community Plan, are
intended to maintain an adequate transportation infrastructure for existing
residents and to place constraints on traffic growth to ensure it does not
exceed infrastructure capacity. It
should be noted that the General Plan and the individual Community Plans, are required
by State Code 65300 to be “the fundamental policy document of the City of
Los Angeles.” Two relevant
Goals are as follows:
·
Goal 14 – Discourage non-residential traffic flow on
residential streets and encourage community involvement in determining
neighborhood traffic controls.
·
Goal 16 – Provide a circulation system which supports
existing and planned land uses, while maintaining a desired level of service at
all intersections on our highways, freeways and streets.
Below, we have included
statements contained in the DEIR, which appear to violate our Community
Plan. Included with each statement
is the relevant Policy contained in our Community Plan:
Analysis of Attachment C of LADOT’s “Initial Traffic Impact Assessment for the Proposed Village at Playa Vista Project”, EIR Volume XX, indicates that 31 Intersection-Peak Hours periods currently operating at LOS “D” or better will not be maintained at LOS “D” after the proposed project. We view these as violations to our Community Plan, Policy 16-1.1 [a], which states that the City is to “Maintain a satisfactory LOS [Level of Service] for streets and highways that should not exceed LOS “D” for Major Highways, Secondary Highways and Collector Streets”. Does the City agree that a violation exists? If not, please explain why.
Analysis of Attachment C of
LADOT’s “Initial Traffic Impact Assessment for the Proposed Village
at Playa Vista Project”, EIR Volume XX, indicates there are 15 Intersection-Peak Hours periods currently operating
at LOS “E” or worse that will not be maintained at LOS
“E” after the proposed project. We view these as violations to our Community Plan, Policy 16-1.1 [b], which states that, “If existing levels of service are LOS
“E” or LOS “F” on a portion of a highway or collector
street, then the level of service for future growth should be maintained a LOS
“E” if possible”. Does the City agree? If not, please
explain why.
If the City believes that it
is impossible to improve these intersections to LOS “E”, please
explain why. How does the City
justify approving developments, which generate significant volumes of traffic,
further degrading intersections that are already at unacceptable Levels of
Service?
Analysis of Attachment C of
LADOT’s “Initial Traffic Impact Assessment for the Proposed Village
at Playa Vista Project”, EIR Volume XX, indicates that 10
Intersections-Peak Hour periods to be used by the proposed project are already
at LOS “F” while 31 will be at LOS “F” after the
proposed project and mitigation.
Therefore, the infrastructure “cannot accommodate the traffic generated”. We view these as violations to our Community Plan, Policy 16-2.1, which states that, “No increase in density
shall be effected by zone change or subdivision unless it is determined that
the transportation infrastructure serving the property can accommodate the
traffic generated”. Does the City agree? If not, please explain why.
Because of the limited
number of north/southbound roads (3) leading north from the project site, it
should be noted that when one or more of these roadways is highly congested as
they are today during AM/PM peak traffic times, commuters will quickly seek out
alternatives. Since Centinela
Blvd. is currently rated at LOS “F” during peak AM/PM traffic
times, commuters already divert to the residential Collector streets such as Inglewood
Blvd. as a convenient
alternative.
The City’s traffic
modeling tools and methods do not address the Cut-through traffic issue. As a
result the City is continually surprised that traffic predicted by prior
approved projects has not appear on the modeled arterial streets when the next
developer comes seeking approval for a new project. This is because much of the prior predicted traffic is now
cutting-through our residential neighborhoods. This is an unacceptable omission
by the model. This omission
provides an incomplete analysis and makes it impossible for the members of the
Mar Vista community to accurately assess Playa Vista’s Phase II traffic
impacts.
Section V.I. (1), page 887,
contains the proposed project mitigation measures, referred to as the
“Village at Playa Vista Transportation Improvement Measures”. It was stated that if any of the
proposed mitigation measures are ”determined not to be feasible or if it
is not possible to obtain the necessary permits, then a significant impact(s)
will remain”. Our
community, should not be placed in a position to absorb a “new
development’s traffic burden on our streets until it can be clearly
demonstrated that the transportation infrastructure is able to handle the
additional traffic volume.
On page 910, Playa Vista
claims that the results of its mitigation measures, using the three main
mitigation tools cited in Section V.I. (1): Transit mitigations, Roadway improvements and Signalizations improvements will result in no significant impact to the
Centinela/Venice intersection. In
fact, Playa Vista claims that it will mitigate the effects of traffic generated
by the proposed project at every intersection surrounding the development
site.
These assumptions appear to
be overly optimistic when you
considering that 39% (12 of 31) of the required mitigation measures in the City
of Los Angeles are to be fulfilled by requiring the developer only to “contribute
to the design and implementation of …(some signal or transit
improvement).” Simply
“Contributing to” a traffic mitigation measure provides not
guarantee that the measure will be implemented nor when it will be
implemented. Therefore our
transportation infrastructure could be left incapable of accommodating the
proposed project’s traffic, which would be a violation of City Policy
16-2.1 as mentioned above.
We also question the
effectiveness of the proposed Transit improvements to realize the mitigations
necessary considering the socio-economic level of the people capable of buying
Playa Vista homes. Therefore we
must ask:
Where
in the city have Transit improvements achieved the level of trip mitigation by
people of similar socio-economic level as is being used for the Playa Vista
project?
One of the mitigation
measures at Centinela/Venice proposes
to re-stripe a separate southbound right turn lane so that there would be two
through lanes, a single left hand turn lane and a separate right turn lane. Since the main problem affecting this
intersections peak southbound traffic is the long wait time for left turns, the
re-striping of lanes may do little to increase the intersection’s vehicle
capacity until a left turn lane arrow is added to the southbound side. Why is a new left-turn arrow not yet
under consideration by the LADOT as an effective mitigation measure for this
intersection? If a left-turn arrow
is under consideration by the LADOT, when will it be installed?
It is not in the best
interests of the surrounding communities to allow itself to be burdened with
the failed efforts to mitigate the traffic intrusion resulting from Playa
Vista’s proposed Phase II project.
The burden should remain with the developer. The developer ought to be required to convince community
leaders how they will minimize or eliminate the potential for traffic intrusion
and be made financially responsible and accountable for their
implementation’s success or failure before they are granted any type of
conditional approval for the proposed project.
5.
RECOMMENDATIONS
a)
We recommend that
Playa Vista Phase II not be approved if it alone or in combination with other
related projects violates Policies 16-1.1[a], 16-1.1[b] or 16-2.1 contained in
the Los Angeles General Plan and Community Plans affected by said development
project(s).
b) Playa Vista Phase 2 can not be
approved without revoking Phase 1 Office Space vesting.
A condition was place on Playa Vista Phase 1 approval that ties the maximum traffic allowed for Phase 1 to the maximum to be allowed by the remainder of Playa Vista’s Master Plan. Phase 2 now constitutes the remainder of that Master Plan. The condition in questions is Condition 116 of Vesting Tentative Tract No. 49104 for Phase 1.
Condition
116 states that the maximum traffic to be generated by all Phase 1 Office Space
is limited to 1493 vehicle trips in the PM Peak Hour and states that, “failure to achieve the trip
reduction goal will result in a corresponding decrease in total office
entitlement of the Playa Vista Master Plan Project as a whole.” Playa Vista Phase 2 – The Village
now constitutes the remainder of that Master Plan.
However,
Phase 1 (in the eastern commercial portion near
Inglewood Blvd.) is not yet completed or even started at this time. If the City approves Phase 2 before
Phase 1 is completed, the City will lose its method of enforcing its cap on
Phase 1 traffic generation.
Therefore
we recommend either that Phase 2 not be approved until Phase 1 is completed, or
that the vesting of the Office and Retail commercial section at the east third
of Area D be revoked to allow Phase 2 to proceed in the approval process.
c)
Curtail Cut-through Traffic and Re-measure True Remaining
Excess Capacity
Much
commuter traffic is already using residential Collector streets due to LA and
neighboring cities approving more traffic-generating development that our
existing transportation infrastructure can accommodate at acceptable Levels of
Service (“D”). This is already in violation of City Transportation
Goals 14 and 16 and their related Policies. If the City actually operated in accordance with their
stated Goals and Policies commuter traffic now adversely impacting the quality
of live in our residential neighborhoods would be redirected to back to our
arterial streets. This would of
course leave less excess capacity on our arterial streets for new development
which will then limit the amount of new growth possible.
While
the City may not like this coming reality, our perspective as a community based
arm of the City tells us that existing residents are not longer willing to give
developer’s traffic a free-ride on their residential streets. The City may soon have to choose
between either voluntarily implementing cut-through traffic prevention measures
or be forced to do so by court action.
Therefore
we recommend that the City
1.
initiate cut-through commuter traffic prevention measures (deterrents are no
longer enough) on the streets listed below,
2.
re-measure the excess capacity remaining after cut-through traffic has been
directed back to its intended arterial streets, and then
3.
re-evaluate all proposed development projects based on actual remaining excess
capacity,
4.
require developers to implement any infrastructure expansion measure determined
via modeling to accommodate they desired proposed traffic,
5.
measure the resulting new expanded excess capacity. and then
6.
given the developer permission to generate new traffic to that expanded
capacity limit.
To
continue allowing traffic-generating development based on modeling that does
not address the cut-through traffic problem and the existing lack of
infrastructure capacity is courting disaster.
Cut-through
commuter traffic should be eliminated from at least the following residential
Local/Collector streets in the Mar Vista Community Council area:
· Veteran Avenue between Venice Boulevard and National
Boulevard.
· McLaughlin Avenue between Washington Boulevard and
Barrington Avenue.
· Inglewood Boulevard between Washington Boulevard and
National Boulevard.
· Grandview Boulevard between Venice Boulevard and
National Boulevard.
· Beethoven Street between Washington Boulevard and
Walgrove Avenue.
· Walgrove Avenue between Washington Boulevard and the
Los Angeles/Santa Monica border.
· Palms Boulevard between McLaughlin Avenue and
Walgrove Avenue.
.
d)
Implement traffic mitigation and capacity expansion measures now before
approving any new development.
Until it can be clearly demonstrated how those
intersections in the Mar Vista area, which are now rated at LOS “E
“or “F”, can adequately carry the additional traffic proposed
by the developer, the Playa Vista Phase II should not be approved. The affected intersections should have
their capacity increased to accommodate additional traffic and actual excess capacity
measured (as stated in the recommendation above) before new development is approved. If it is not feasible to
increase the capacity of certain intersections, then the development should be
scaled back or prohibited until the proposed traffic impacts fall within the
capacity of the transportation infrastructure.
If
the City does not concur with any of our recommendations, please explain why.
Respectfully,
The Mar Vista Transportation Committee
© 2003 Mar Vista Community Council/Transportation Committee. All Rights Reserved.