ARTHUR L. KASSAN, P.E. Consulting Traffic Engineer Honorable Members of the Planning and Land Use Management Committee c/o City Clerk Room 395, City Hall 200 North Spring Street Los Angeles, CA 90012 Subject: Target Retail Shopping Center Project 5520 W. Sunset Boulevard, Los Angeles, CA 90028 C 09-2092 APCC 2008-2803 SPE-CUB-SPP-SPR-1A CD13 Dear Honorable Councilmembers: Date:.&-.:I 0=--.--.;;.o..;;l:,_...;o~4".k... _ Submitted in PL I.t1 t:"'..committee Council ile No: 0 "l- "26&f 2 Item No.: I am unable to attend your hearing on the subject project because of a prior commitment that takes me out of the City. However, I appreciate the opportunity to present my comments to you in the following letter. I have been reviewing and commenting on the Mitigated Negative Declaration (ENV-2008-1421-MND) regarding this project since the beginning of 2009 when the document first became available to the public. I have submitted my comments in letters to staff members of the Department of City Planning in ebruary and April, 2009. I have reviewed the staff responses to my comments. ollowing are the comments that, I feel, have not been answered sufficiently and which leave open several issues concerning the significance of the traffic impacts of the proposed ~~ect.. 1. The trip generation estimates for the proposed project are low, because the credits for transit use are unreasonably high. That results in the underestimation of the potential significance of the impacts at several intersections. The TraffiC Impact Analysis (TIA) takes a 20% "'Transit Credit" for trips to and from the proposed discount store and shopping center that will comprise the new development. To quote from the TIA report, "Given the site's proximity to various attractions and transit opportunities, a 20% transit reduction was applied to the retail components of the proposed project." [page 12] That "transit credit" does not include pedestrian trips resulting from the development's pedestrian enhancements. The next sentence in the TIA report states, "An additional 10% internal reduction was applied to the proposed shopping center uses for voluntary pedestrian enhancements to the project." [page 12] l3 Telephone (310) 558-0808 5105 Cimarron Lane Culver City, CA 90230 AX (310) 558-1829
Page 2 The reader must infer that the benefits of the pedestrian enhancements are covered by the extra 10% reduction and are not included in the 20% "transit credit". No documentation or empirical evidence is presented for such a high percentage of transit use based on experience at actual operating retail businesses in the Hollywood area or similar areas. The Target site is located approximately 1,400 feet (that is, more than one-quarter of a mile) from the nearest Metro Red Line station at Hollywood Boulevard and Western Avenue. It is also approximately 2,640 feet (that is, one-half mile) from the transit hub intersection of Santa Monica Boulevard and Western Avenue. We have researched City files, and we have identified the trip generation estimates for four comparable developments with which to compare the 20% transit credit for the subject development. All of the following developments will be located"... at a major transit hub...jj and will have high density, two characteristics that are emphasized for the Target development in the inal Study. Three of the four project sites are in Hollywood in proximity to the Target project site. Paseo Plaza Hollywood Mixed-Use Project, on Santa Monica Boulevard, between Wilton Place and St. Andrews Place - The site is served by five MTA bus lines and an LADOT DASH line. It is just over 500 feet from the busy transit hub of Santa Monica Boulevard and Western Avenue. The retaill restaurant component of the development will contain 377,900 square feet of floor area. The credit for "Walk-lnlTransitn trips was 5%. [Crain & Associates report dated December 2005, as a component of the Draft EIR for the development] Hollywood/Garfield Mixed-Use Project, on Hollywood Boulevard at Garfield Place - The site is served by four MTA bus lines. It is less than 600 feet from the nearest Metro Rail Red Line station at Hollywood Boulevard and Western Avenue. The credit for "Walk-In/Transit" trips was 5%. [Meyer, Mohaddes Associates report, as a component of the Draft EIR for the development] Columbia Square Mixed-Use Project, on the north side of Sunset Boulevard between Gower Street and EI Centro Avenue - The site is served by two MTA bus lines and two DASH lines. It is approximately 1,300 feet from the Metro Rail Red Line station at Hollywood Boulevard and Vine Street (Argyle Avenue portal), that is, closer to its nearest station than the Target site is to its nearest station. The development will contain 400 multiple-family dwelling units, a 125-room hotel, 380,000 square feet of offices, and 41,000 square feet of retaill restaurant; that is a development program that would attract significant transit usage by employees and residents. The credit for "Walk-In/Transit" trips was 15%. [ehr & Peers report dated May 2009, as a component of the Draft EIR for the development; use of the 15% transit credit was approved by the Department of Transportation (LADOT) in September 2008]
Page 3 Crenshaw Rodeo Shopping Center, at the southeast corner of the Crenshaw Boulevard/Rodeo Road intersection - The site is served by four MTA Bus Lines (one of which is a "RapidLine H ) and a DASH line. The MetroRaii Expo Line, which will be completed about the same time as the shopping center, will have a station approximately 450 feet north of the shopping center, less than one-third the distance at the Target Hollywood site. The current plan for the shopping center is for a total floor area of approximately 330,000 square feet, of which approximately 150,000 square feet will be a Target store (similar in order of magnitude to the 162,415 square feet of floor area planned for the Hollywood Target store). In estimating the future trips to and from the shopping center, the "Transit/Pedestrian Trips" credit allowed by LADOT was 15%. [Arthur L. Kassan, P.E., Consulting Traffic Engineer report dated April 2008 and supplemental report dated July 2009] The transit credit for the Target Hollywood development is not in line with the credits allowed by LADOT in analyzing the other four developments, exceeding the higher credits by 33% and the lower credits by 300% with no documentation or explanation for the higher magnitude. Considering the quantities and sizes of the types of merchandise typically purchased by Target patrons, it is unlikely that they will choose to or be able to walk to either the Metro Rail station or the bus transit hub on Santa Monica Boulevard in large enough numbers to justify the extraordinary level of transit credit. If the credit for transit use by project customers were reduced from 20% to 15%, the afternoon peak-hour project trips would increase by 16%, and the impacts of project traffic would be significant at four intersections, as follows: 1) Western Avenue & ountain Avenue; 2) Westem Avenue & Hollywood reeway Northbound On-Ramp; 3) Western Avenue & Santa Monica Boulevard; and 4) Sunset Boulevard & Vermont Avenue. Having received no further documentation or empirical evidence of the unusually high transit credit (which is notably not referred to as partially a "pedestrian" or "walk-in" credit) for the proposed development, my original comment to the Department of City Planning staff in the ebruary and April letters is still valid. The net trip generation for the future development is significantly under-estimated, and the potential impacts are not fully identified.
Page 4 2. The findings of future traffic operations levels in the TIA for Target Hollywood are significantly more favorable than the findings for the same intersections in the impact studies for other nearby projects. The findings of future intersection Levels of Service for the Target project and four other Hollywood projects were compared. The other projects are 1) Paseo Plaza; 2) Hollywood/Garfield; 3) Columbia Square; and 4) Hollywood Passage. The first three are described earlier. The fourth is proposed for the Hollywood BoulevardlWestern Avenue vicinity, directly across from the Metro Rail Red Line station. It will have 216 dwelling units and approximately 18,000 square feet of retail space. The Level of Service findings for the future conditions, without the subject project, that is, the background conditions, are compared and tabulated below. uture Level of Service Without Subject Project Peak Target Paseo Hollywood/ Columbia Hollywood Intersection Hour Hollywood Plaza Garfield Sguare Passage Western Ave.! Morning E N/A N/A N/A northbound Hollywood Afternoon E rwy. on-ramp Sunset BlvdJ Morning C N/A C N/A C S1.Andrews PI. Afternoon B E Western AveJ Morning 0 N/A N/A N/A Santa Monica Blvd. Afternoon Sunset Blvd.! Morning A N/A N/A B B southbound Hollywood Afternoon C 0 rwy. on-ramp Sunset Blvd.! Morning C N/A N/A N/A Bronson Ave. Afternoon C Hollywood Blvd.! Morning B N/A N/A C N/A Bronson Ave. Afternoon B E N/A - Intersection was not included in the TIA evaluation for that project. E
Page 5 Comparing the findings, in every case, the Level of Service predicted for the Target Hollywood project during the critical future afternoon peak hour was more optimistic than the findings for any of the comparable projects (with the single exception of the Western Avenue/Santa Monica Boulevard intersection, where the future Level of Service [LOS] is projected as in the two studies that include that intersection). At the three intersections studied for both the Target Hollywood project and the Columbia Square project, the differences in the findings for the afternoon peak hour are both significant and meaningful: at Sunset Boulevard/southbound Hollywood reeway on-ramp - LOS C for Target vs. LOS 0 for Columbia Square; at Sunset Boulevard/Bronson Avenue - LOS C for Target vs. LOS for Columbia Square; and at Hollywood Boulevard/Bronson Avenue - LOS B for Target vs. LOS E for Columbia Square. That contradicts Response 8-6 that City staff made to a comment on the original Initial Study for the Target Hollywood project. The staff response claimed that the findings of the two studies were similar, when they were actually substantially different. The meaningful trend in disparity between the Target Hollywood project study and the others cannot be explained by large differences in the study parameters; all of the studies were done at approximately the same time using comparable background data. In fact, the Hollywood Passage study was done by the same traffic engineering consultant firm as did the Target Hollywood project study; yet the results are significantly different comparing those two studies. The overly optimistic findings of the Target Hollywood TIA should be justified in light of the, perhaps, more realistic findings of the other four studies. We respectfully request that the City Council direct staff to re-evaluate the potential traffic impacts of the proposed Target Hollywood project considering the under-estimation of the trip generation using the extraordinarily high "transit credit" and considering the substantial discrepancies in the findings of future traffic operations levels for the Target Hollywood project compared with the findings for the other projects in the vicinity. Thank you for your attention to the issues that I have raised. Very truly yours, Arthur L. Kassan, P.E. Registered Civil Engineer No. C 15563 Registered Traffic Engineer No. TR 152 -