November 24, 2004
Eastwood Coalition
1740 North Gramercy Place #108
Los Angeles, California 90028
Nicholas Hendricks
Environmental Review Coordinator
Department of City Planning
Environmental Review Section
200 North Spring Street, Room 750
Los Angeles, California 90012
Re: Scoping comments in response to Notice of Preparation for Environmental Impact Report for the Hollywood Whole Foods Market Project (EAF No. ENV-2004-3814-EIR)
Dear Mr. Hendricks:
The Eastwood Coalition appreciates the opportunity to provide scoping comments in response to the Notice of Preparation (NOP) for the above-referenced EIR. The Eastwood coalition is a neighborhood association representing the various people who live or work within the area generally bounded by Hollywood Boulevard on the south, Western Avenue on the east, Franklin Avenue on the north, and the 101 freeway on the west. The Hollywood Whole Foods Market is proposed for development within the area we represent. Eastwood Coalition’s purpose is to act as a uniform voice regarding the best interests of our neighborhood. In this regard, we have extensively engaged our neighborhood for input on the proposed project and held numerous community meetings on the subject, including many with Whole Foods, Bond Development, and City staff. The comments presented here represent the majority views of the community members as they have voiced their concerns to us.
As an initial matter, it should be noted that English is not the first language for many of our neighbors. To ensure that the entirety of our community is engaged in the EIR process as it moves forward, we request that all future notices for the project and community meetings be written in Spanish, Armenian, and Thai. Also, while we recognize that translating the entire EIR into multiple languages may be too much to ask, we request that at least a summary of the EIR be available in the several languages spoken in our community. Failure to overcome the language barrier inherent in our community would mean that the EIR conforms only to statutorily required process and would do nothing to accomplish what should be the real objective of adequately informing and soliciting input from the affected public.
The following presents our comments on the project objectives, analysis of impacts and mitigation, and alternatives to be studied in the EIR.
PROJECT OBJECTIVES
Every EIR must articulate clear project objectives as a benchmark to compare the effects of the project against reasonable alternatives and mitigation measures. (“A clearly written statement of objectives will help the lead agency develop a reasonable range of alternatives to evaluate in the EIR… [14 Cal. Code Regs. § 15124 (b)].) After reviewing the NOP for the EIR, we feel the NOP is silent as to what is or are the objective/s for this project. Other than the project description to build a “52,000 sqaure foot Whole Foods Market,” we found no guidelines or suggestions regarding the objectives that this project should be studied against.
Therefore, we suggest the following objectives are appropriate for this project, along with guidelines explaining our rationale.
1. Be consistent with the neighborhood, be
compatible with the existing sizes and types of buildings, and further the
objectives of “SNAP”.
This neighborhood is one of Hollywood’s oldest; home to some prime examples of the Arts and Crafts as well as Art Deco styles of architecture in the city. This site also lies within a Station Neighborhood Area Plan (SNAP) district. The proposed Whole Foods market with 52,000 square feet and two levels of parking above (totaling 210 parking spaces) doesn’t appear to fit in with our existing historic buildings and small “Mom and Pop” businesses or with the SNAP objectives, which strive to encourage an urban pedestrian village-like development.
2. Address needs of the immediate community.
Our neighborhood needs community gathering spots, park areas, housing, and most importantly, parking. Currently, there are approximately one hundred fifty rental units on Garfield Place with no off-street parking available. Unfortunately, there are only approximately one hundred parking spaces available on the street. These numbers are similar for the next two residential streets as well, Gramercy Place and Wilton Place.
3. Place no new demand on on-street parking.
Because our neighborhood is so dearth for parking, any acceptable development proposal must provide sufficient off-street parking for its customers and employees so as not to place any new demand on the limited parking on our community’s streets.
4. Have no lasting unmitigated significant
impacts.
Any acceptable development should not have any lasting unmitigated significant negative impacts on the community. That is, the development cannot result in an unacceptable increase in traffic on neighborhood streets or increase demand for parking, pedestrian needs, or housing needs in the neighborhood.
IMPACTS ASSESSMENT AND MITIGATION
Traffic and Parking
The increased traffic, along with the increased need for parking that the proposed project will bring into our community is of immense concern. Following are some detailed matters the EIR should consider in assessing the project’s impacts on traffic and parking.
· Assure an accurate traffic count. No matter how the traffic test is administered, we’re concerned that the results won’t be accurate, for currently, residents of Garfield must drive up and down looking for a parking space. Therefore, the traffic counts need to consider the additional volume of traffic generated by residents circling the blocks in search of parking.
· Recognize that much of the traffic volume consists of large buses. Currently, MTA bus routes 207 and 357 use this block of Garfield Place as a turn-around. All totaled, there are 532 buses that make a trip of Garfield Place, everyday. That averages out to one every three minutes. These large buses place a huge demand on Garfield Place, far greater than would a similar number of passenger cars. The traffic study must recognize this existing condition and the difference between buses and cars.
· Recognize that traffic is already at gridlock. This block of Garfield Place is only two lanes wide with parallel parking on both sides, and only .2 miles long. Often people double park, further restricting traffic flow. And everyday, traffic is already at gridlock at the Hollywood intersection.
· Use an accurate, reasonable worst-case estimate of project-generated traffic. We have previously been told the project will generate 150 car trips/hour during peak business hours. But we have also been informed that Whole Foods’ store design criteria calls for four customer parking spots for every 1,000 square feet of store. For the proposed 52,000 square-foot store, that’s 208 parking spots. Assuming a customer’s store visit is about 30 minutes long, that’s 416 customers per peak hour or 832 car trips/hour during peak periods. In order to fully assess traffic impacts, we recommend the EIR use the highest, reasonable estimate of impacts, and if necessary, measure actual traffic volumes at similarly sized Whole Foods stores.
· Fully consider the project’s traffic impacts on Garfield Place. As noted above, the Whole Foods Market will generate a huge volume of additional traffic. While the store will be located on Hollywood Boulevard, only one block west of Western Avenue, it is naïve to assume all project-generated traffic will enter and exit via Hollywood Boulevard. We fear many shoppers will travel down Garfield Place to avoid the Western/Hollywood intersection. Further, since the store caters to an up-scale clientele, we suspect most traffic will be coming from residents in the Hollywood Hills to the north of us, and thus use Garfield Place exclusively.
· Fully account for new truck traffic, including waiting time. Bond Development and Whole Foods have already acknowledged that there will be at least five semis delivering produce and goods to the market, everyday. They have also told us to expect fifteen other delivery vans, everyday, not counting garbage and recycle trucks. With the loading dock being located on this residential street, next to the store’s ingress/egress for customers, we are concerned that Garfield Place will be constantly backed-up. The semi’s and other delivery vans will queue up along Garfield, possibly Hollywood Boulevard, too. Our concerns are for the residents of Garfield who must endure this burden of added traffic congestion, pollution, and noise.
· Quantify the cumulative effects on traffic from adjacent projects. The CRA’s Hollywood/Western redevelopment project will literally surround the proposed project and result in a tremendous increase in traffic in the community. Just across the Hollywood Freeway, construction is underway on the new 1875-seat Central L.A. High School #1. Construction is well underway on the mixed-use development across the block at St.Andrews Place and Hollywood Boulevard, the Sunset-Western mixed-use development, and several other smaller developments in the area. Now doubt the City is aware of other new developments in the pipeline. The EIR must quantify the cumulative effects of these and other related projects on traffic.
· Fully consider increased demands for parking. With the Whole Foods project employing 80 people/shift and generating up to 832 customer car trips/hour during peak business hours we are very concerned that street parking will be taken by either Whole Foods customers or their employees.
The NOP states the project will provide 170 to 210 spaces, but the numbers don’t add up. Even assuming the larger number, 210 spaces in the project minus the 80 spaces needed by employees, leaves 130 spaces available. The developer, Bond Companies, has already agreed to lease up to 35 parking spaces to neighborhood residents whose parking was taken away to clear the proposed project lot. The difference leaves 95 spaces available for customers. Even assuming just 150 customers in the store during peak hours, that leaves a need for 55 more spaces. Assuming the lower, 170 number of proposed parking spaces and assuming a peak demand of 200 customers, there would be a shortfall of 145 spaces. There is no place else to park in our neighborhood. Where will these people park?
We believe the EIR could alleviate these potential traffic and parking problems by combining the following alternatives and mitigation measures.
· Consider a smaller store with more parking spaces. This seems like an elementary solution and would ensure lessened impacts.
· Close Garfield Place to through traffic, just north of the store’s ingress/egress/loading area. This would ensure no additional traffic would use Garfield Place to enter/leave the Whole Foods Market. All traffic must come and go on Hollywood Boulevard.
· Increase the number of loading bays and create a drive-through loading dock. Consider a reconfigured store layout in which the semi’s and other delivery vehicles would enter from Hollywood Boulevard, drive to the back of the store where there would be multiple enclosed unloading bays, and exit on Garfield Place, only able to make a right turn. This would alleviate the impact of semi’s attempting to back in from Garfield Place and the impact of semi’s lined up and waiting on Garfield Place.
· Widen Hollywood Boulevard and add a center turn lane. By widening Hollywood Boulevard for the length of the store (i.e., between Garfield Place and St. Andrews Place) a left-hand turn lane for Hollywood Boulevard’s eastbound traffic onto Garfield Place could be provided with a left-signal turning light. There’s currently no turn lane onto Garfield Place from Hollywood Boulevard. This turn lane would help eliminate backed-up traffic along Hollywood Boulevard.
· Go underground for additional parking. One or two levels of underground parking would ensure the neighborhood that none of our street parking would be taken. The developer says that they will encourage their employees to take public transit. But there is no law or other means to enforce that. An underground parking level providing the 55 to 145 space parking shortfall would ensure the employees a place to park and not take away from the dire parking needs of the community.
Air Quality
The health and safety of our neighbors from exposure to construction dust and fumes and long-term emissions from a tremendous increase in car traffic, as well as diesel delivery trucks, is of great concern. While we recognize pollution from construction is short term, the addition of thousands of additional car trips everyday, plus the addition of tractor-trailers and other delivery vans on Garfield Place everyday, raises a concern of pollution that will plague our community for generations.
We can suggest no alternative to mitigate air quality impacts other than considering a smaller-scale store or an alternative low-density development, which would be consistent with SNAP’s pedestrian village objectives.
Land Use/Planning
We are concerned that the neighborhood will be transformed from a pedestrian/residential orientation into a shopping district dependent on vehicle shoppers. This is particularly concerning given that Whole Foods caters to an up-scale clientele that generally live outside the immediate area.
We ask that the EIR fully consider the consistency of the proposed project with the planning objectives and requirements of SNAP. We ask that mitigation measures and design features to promote the objectives of SNAP and a pedestrian-friendly village be incorporated into the project, including setbacks, landscape areas, and pedestrian-oriented plazas and open spaces.
Aesthetics
We are concerned that the visual impact of the proposed project will not fit with the current aesthetics of the community, nor with the vision for the future of this community. Large and imposing, the project’s presence could create a canyon effect on Garfield Place (considering it’s relationship to the already existing St. Francis Hotel.) And while we understand the project is being set back seven feet from the southern property line (as is required by the Department of Transportation), this space is not given up by the project but proposed to be filled with café tables. Whether the pedestrian wished to be engaged in this store or not, its size and closeness is undeniable. In short, the project as proposed is wall-to-wall development. The EIR must fully consider these aesthetic concerns in the context of our existing environment.
We believe a smaller-scale store or alternative development proposal will be the only way to mitigate aesthetic impacts. Further, the EIR should consider how the project can incorporate significant landscape areas and setbacks to soften the project’s immense visual presence.
Noise
New project-generated noise project is also a major concern to the community, both from construction and long-term effects. Residential use surrounds the project site on three sides. Existing noise is already at unbearable levels for a residential area, and significant new noise sources are unacceptable.
· Construction noise. When Bond Development demolished the bungalows, they stated at 7:00 a.m. They were also there on Sunday mornings, continuing with demolition. This inconsideration to the neighborhood is unacceptable for construction of the proposed project, particularly when considering that construction will go on for months and months.
· Noise from delivery trucks. We recognize that many of the semis have refrigerators that continue to run, even when the trucks’ engine are turned off, and need to run in order to keep produced and other perishables cool. So with the semis line-up waiting to deliver, the excessive noise will be a substantial impact. In addition, beeping from truck reversing horns when backing for loading or turning around is a significant – and irritating – noise source that needs to be considered in the EIR.
We suggest the following mitigation measures to reduce noise impacts:
· Limit construction hours to between 8:00 a.m. and 6:00 p.m., and never on Sunday.
· Require sound barriers. Placing sound barrier mats around the perimeter of the construction site can greatly diminish construction noise, as well as shield the visual eyesore of a massive construction site.
· Provide for drive-through, enclosed loading bays. Do not allow back-in loading. By reconfiguring the store layout as previously suggested to allow trucks to enter from Hollywood Boulevard into a drive-through loading bay, exiting on Garfield Place, we believe noise impacts on the community from standing and backing delivery trucks could be eliminated.
Public Services
The availability of parking and safety go hand-in-hand. Limited on-street parking increases vacancies and results in default tenants, which equals an increase in crime. Since the project site was purchased by Bond Development, approximately 35 parking leases to the neighbors were terminated. This resulted in tenants relocating out of the neighborhood. There is an increase in vacancies on Garfield Place, which influences an economic downturn. Landlords have not been able to rent properties because of the lack of parking available. This tends to attract default tenants with lower income and brings with it a higher crime rate.
The solution to this concern is simple. Make sure the proposed development places no new demand on the community’s limited available on-street parking.
ALTERNATIVES
CEQA requires the lead agency to examine a range of reasonable alternatives that would feasibly obtain most of the project objectives, but avoid or substantially lessen any significant adverse effects of the project. (14 Cal. Code Regs. § 15126.6.) In its screening and review of alternatives, the EIR must provide more than “cursory” analysis and should adopt or construe project objectives so that only the proposed project could conceivably be capable of achieving them.
The following presents our recommendations for a smaller store alternative and for the CEQA-required no-project alternative.
A Smaller Store Alternative
As noted throughout our comments, many of our concerns could be addressed by simply considering a much smaller store. We believe a smaller-scale store could also achieve our proposed objectives for this project as well as the objectives already established by SNAP. Based on information obtained from Whole Foods’ website and as provided in Exhibit 1, the average size of all Whole Foods’ stores is about 32,000 square feet, or approximately 40-percent less than the project as proposed. Many Whole Foods stores are less than 10,000 square feet. Based on the fact that a store of approximately 30,000 square feet is not only feasible, but is the norm for Whole Foods, we request that a store development of not more than this size be evaluated in detail in the forthcoming EIR.
In addition to the reduction in traffic and parking impacts, a smaller-scale store would provide flexibility in the use of the lot to incorporate other mitigation measures and design elements to benefit the community. Attached as Exhibit 2 is an alternative store layout that includes some of the mitigations measures we have suggested in these comments, including an enclosed drive-through truck delivery feature and the widening of Hollywood Boulevard. Such a smaller-sized store would also be more fitting with the community character, provide an opportunity for greater set-backs and green space, and help further the neighborhood’s desire and SNAP’s objective of creating a predestrian-oriented village atmosphere.
The No-Project Alternative
CEQA requires evaluation of a no-project alternative that addresses “existing conditions” as well as “what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.” (14 Cal. Code Regs. §15126(e)(2).)
The Eastwood Coalition does not suggest that under the no-project condition, the existing lot would remain undeveloped indefinitely. We recognize the value of land and the development pressures in the community, and that if the City did not approve the Whole Foods proposal, it is likely some other development would be proposed in the future. However, we strongly disagree that the likely no-project future is development of a mega-sized grocery store similar to the current Whole Foods proposal.
There are currently four major grocery stores within a 1/3-mile radius of the project site; one a brand-new Ralph’s grocery store just a block away. We therefore do not believe a strong need or demand for new grocery stores exists in the area and suggest an alternative development would occur under the no-project future. All other major developments now underway in our area are housing or a mixed-use of housing and small-scale retail/office. Based on this demonstrated demand, we suggest an appropriate no-project alternative consider development of the site for residential or mixed residential/office/small-retail use. For the EIR, this no-project alternative should be construed to be fully consistent with the SNAP objectives.
CONCLUSION
We hope that these scoping comments assist the City in preparing an exemplary EIR that will succeed in informing decision-makers and the public of the environmental consequences of the proposed Whole Foods project. We also look forward to working with the City, Bond Development, and Whole Foods Markets in a spirit of cooperation and inclusion as the EIR studies progress. We believe that with the community’s input, adequate mitigation, and incorporation of design elements to eliminate all lasting significant impacts, the community would fully support the project.
Very truly yours,
K.C. Schmidt