IV. ENVIRONMENTAL IMPACT ANALYSIS K.2. PARKING ENVIRONMENTAL SETTING The following analysis summarizes the findings and conclusions of the Traffic Analysis (Traffic Study), prepared by The Mobility Group, March 3, 2006. Specifically, this section addresses the construction and operational parking impacts associated with the Proposed Project. A more detailed examination of the parking analysis is available in the Traffic Study, provided as Appendix G to this Draft EIR. Parking Requirements The parking requirements for the Proposed Project are controlled by the City Planning Department Deputy Advisory Agency and the Planning and Zoning Code. As such, both requirements are discussed below. It should be noted that parking requirements for commercial development are only subject to the provisions of the City Code. Planning and Zoning Code Requirements - Residential. The City Code requires one parking space per dwelling unit of less than 3 habitable rooms, 1.5 parking spaces per dwelling unit of 3 habitable rooms and 2 parking spaces per dwelling unit of 3 or more habitable rooms. As shown in Table IV.K.2-1 on page IV.K.2-4, the Code would therefore require 733 spaces for the residential units. As also shown in Table IV.K.2-1, the Proposed Project parking supply of 700 residential parking spaces would be 33 spaces less than the Code requirement. City Planning Department Deputy Advisory Agency Requirements - Residential. Pursuant to the City Planning Department Deputy Advisory Agency, 2.0 regular parking spaces and 0.25 guest parking spaces per dwelling unit are required for condominium projects in non-parking congested areas. 1 The Project Site is located in a uncongested area, and would therefore be required to provide 1,044 parking spaces for the 464 proposed condominiums. As shown in Table IV.K.2-2 on page IV.K.2-6, the Proposed Project proposes to provide 700 residential spaces, which would be 344 spaces less than the number required by the Deputy Advisory Agency. Planning and Zoning Code Requirements-Commercial. Pursuant to the Planning and Zoning Code, 2 parking spaces are required for every 1,000 square feet of commercial floor area. 2 A total of 41,000 sf of 1 2 City Planning Department Deputy Advisory Agency Residential Parking Policy for Division of Land No AA 2000-1, May 2000. LAMC Section 12.21.A.4(x)(3) and Ordinance 177,103, effective December 18, 2005. Page IV.K.2-1
commercial uses, including 27,000 sf of retail and 14,000 sf of restaurant uses, is proposed. Therefore, a total of 82 parking spaces would be required for the retail/restaurant component of the Proposed Project. As shown in Table IV.K.2-2, the Proposed Project would provide 150 commercial parking spaces, which would be 68 spaces above the code requirement for the commercial uses. Based on a combination of the City Code s residential parking requirements and the City Code s commercial parking requirements, the total parking required for the Proposed Project would be 815 parking spaces. Conversely, based on a combination of the Advisory Agency s condominium parking requirements and the City Code s commercial parking requirements, the total parking required for the Proposed Project would be 1,126 parking spaces. ENVIRONMENTAL IMPACTS Thresholds of Significance The Proposed Project would be considered to have a significant impact with regard to parking if the parking requirements of the Los Angeles Municipal Code (LAMC) and City Policies are not substantially met or if the anticipated parking demand, as estimated through an appropriate analysis for the project, is not substantially met by the supply of available on-site parking spaces. Proposed Project This section addresses the parking code requirements for the Project, the estimated parking demand for the Project, and the Proposed Project parking supply. All the parking for the Project would be provided onsite. The Project proposes to provide a total of 850 spaces on-site, of which 700 spaces would be residential spaces located in an above-ground parking garage accessed from Shatto Place and 150 spaces would be commercial parking spaces located in a separate one-to two-level subterranean parking garage that would be accessible from Vermont Avenue. It is the goal of the Proposed Project to provide sufficient parking for its needs, but to not provide an oversupply of parking in an area of high transit service adjacent to a rail subway station. Construction Impacts Construction workers who choose to drive to work would need to park at or near the Project Site. There would be an estimated average of 200 construction workers, potentially peaking at 250 workers. Assuming about 20% would take transit and that with some ridesharing the average vehicle occupancy of those coming by car would be about 1.2, then an average of 135 parking spaces and 170 peak parking spaces would be necessary for construction workers. It is unlikely that on-site parking would be provided for construction workers during the construction period, so they would need to park off-site in the area of the Project. The Project will organize and provide any necessary off-site parking for Page IV.K.2-2
construction workers through arrangement with existing parking facilities, and instruct all workers to park in such parking specifically provided. Therefore, no significant parking impacts associated with construction worker parking would occur. Operation Impacts Planning and Zoning Code Requirements Residential Pursuant to the Planning and Zoning Code, the Proposed Project would be required to provide 733 spaces for the 464 proposed residential units. As shown in the Table IV.K.2-1, the Proposed Project would construct 700 spaces for the proposed residential units. Therefore, the proposed parking supply would fall short of the Planning and Zoning Code requirements by 33 parking spaces. As a result, compliance with the Planning and Zoning Code would not be met. As such, with respect to the Planning and Zoning Code requirements for residential uses, a significant impact would occur. However, the following information should be considered while assessing potential impacts with respect to the Planning and Zoning Code requirements for residential uses. The Land Use/Transportation Policy (LUTP) of the City s General Plan Transportation Element identifies a range of station area prototypes and recommends phased reductions in residential parking from citywide standards as the (transit) transportation system is constructed and developed. The LUTP identifies the project area as located within the Urban Complex and Major Bus Center prototypes. The vision in the LUTP for Major Bus Centers holds a recommended maximum residential parking ratio of 1.5 spaces per dwelling unit. Because many trips at this location can be made by transit and walking, there is less need for a car in this environment (a major attraction to people purchasing residential units in the Project), and therefore less of a need for parking spaces. If the Project were to provide an oversupply of parking, it would discourage people from using transit and walking. For the Proposed Project, a total of 390 of the 464 residential units (approximately 84 percent) would be studio or one-bedroom units, which would tend to be single occupants. It is also expected that there would be approximately 74 two-bedroom units. As discussed above, the 850 total proposed parking spaces would include 700 parking spaces for residents and guests, providing an overall parking ratio of 1.51 spaces per residential unit. This would be slightly above the City s LUTP vision of 1.5 spaces per unit as discussed above. This would allow average parking supply ratios of 1.35 space per studio/onebedroom unit, and 2.0 spaces per two-bedroom unit, as well as approximately 25 guest parking spaces. Additionally, it should be noted that the proposed parking ratio of 1.51 spaces per unit is comparable to similar projects in the Los Angeles area, including: Flower Street Lofts, which has 91 units and 108 parking spaces (ratio of 1.2); Met Lofts, which has 264 apartment units and approximately 400 parking Page IV.K.2-3
spaces (ratio of 1.5); Grand Avenue Lofts, which recently had its first phase approved for 66 units and 66 parking spaces (ratio of 1.0); the recently approved Elleven Project of 417 condominiums units and 613 parking spaces (ratio of 1.47); and the recently approved 9 th & Figueroa Mixed-Use Project of 629 condominium units and 958 residential parking spaces (ratio of 1.52). Commercial Pursuant to the Planning and Zoning Code, the Proposed Project would be required to provide 82 parking spaces for the proposed 41,000 sf of commercial floor area, including 27,000 sf of retail and 14,000 sf of restaurant space. As shown in the Table IV.K.2-1, the Proposed Project would construct 150 parking spaces for commercial (retail/restaurant) use. The proposed parking supply of 150 parking spaces would thus exceed the City Code requirements by 68 parking spaces. As such, with respect to the Planning and Zoning Code requirements for commercial uses, a less-than-significant impact would occur. Table IV.K.2-1 Parking Spaces Required and Proposed Planning and Zoning Code Requirements Parking Requirements (spaces/unit) Description Size Rate Spaces Project Parking Supply (spaces) Surplus (+)/ Shortfall (-) to Code Residences (464 du total) < 3 habitable rooms 0 du 1.0 /du a 0 3 habitable rooms 390 du 1.5 /du a 585 700-33 > 3 habitable rooms 74 du 2.0 /du a 148 Subtotal Residential Spaces 733 Retail 27,000 2.0 /1,000 sf b 54 +16 Restaurant 14,000 sf 2.0 /1,000 sf b 28 150 +52 Total Spaces 815 850 +35 a LAMC 12.21 A.4.(a). b LAMC 12.21 A.4.(x)(3). Exception for Wilshire/Koreatown Redevelopment Project Area, and Ord. 177103, Exhibit A. Source: The Mobility Group,, Traffic Study, March 3, 2006. City Planning Department Deputy Advisory Agency Requirements Residential Pursuant to the City Planning Department Deputy Advisory Agency, the Proposed Project, which is located in a non-parking congested area, would be required to provide 1,044 parking spaces for the 464 proposed condominiums. As shown in the Table IV.K.2-2, the Proposed Project would construct 700 parking spaces designated for the proposed residential uses. Thus, the Proposed Project would be 344 parking spaces short of the requirement when the Advisory Agency residential parking requirements are Page IV.K.2-4
applied. As such, with respect to the City Planning Department Deputy Advisory Agency requirements for residential uses, a significant impact would occur. However, it should be considered that while the Advisory Agency policy may be appropriate in other more suburban parts of the City, it is far less appropriate in the high density Wilshire Boulevard Corridor. For example, the Advisory Agency s policy is not consistent with other transportation-oriented policies such as the LUTP, which recommends a residential parking ratio of 1.5 for projects within the Urban Complex and Major Bus Center prototypes. The Project Site is served by high levels of public transit service, including the Metro Red Line subway, MTA Rapid Bus Lines on Wilshire Boulevard and Vermont Avenue, and several standard MTA bus routes. Additionally, many of the destinations to and from the Project Site would be within walking distance, and vehicular parking needs would be reduced. Nonetheless, with respect to the City Planning Department Deputy Advisory Agency requirements for residential uses, a significant impact would still occur. Commercial Parking requirements for commercial development are not outlined with respect to the City Planning Department Deputy Advisory Agency. Please refer to the previous discussion on page IV.K.2-4 of this Section for commercial parking requirements as outlined by the Planning and Zoning Code. Estimated Commercial Parking Demand The parking need for the residential component of the Proposed Project was addressed in the preceding sections. An estimate of parking demand for the commercial component of the Proposed Project was also prepared and is described below. This analysis is based on typical base parking demand rates for retail and restaurant uses, and then adjusted to reflect the characteristics of the Project Site and to account for the potential for shared parking between commercial uses. The parking analysis is detailed in Appendix A to the Traffic Study (the Traffic Study can be found in Appendix G to this Draft EIR) and is summarized here. Page IV.K.2-5
Table IV.K.2-2 Parking Spaces Required and Proposed--Advisory Agency Requirements for Residential & Code Requirement for Commercial Parking Requirements (spaces/unit) Description Size Rate Spaces Project Parking Supply (spaces) Surplus (+) /Shortfall (-) to Advisory Req./Code Condominiums 464 du 2.25 /du a 1,044 700-344 Retail 27,000 sf 2 /1,000 sf b 54 150 +68 Restaurant 14,000 sf 2 /1,000 sf b 28 c Total Spaces 1,126 850-276 CDP Advisory Agency Policy AA-2000-1. b LAMC 12.21 A.4.(x)(3). Exception for Wilshire/Koreatown Redevelopment Project Area, and Ordinance 177103, Exhibit A. Source: The Mobility Group,, Traffic Study, March 3, 2006; Christopher A. Joseph & Associates, March 2006. Base parking demand rates were adjusted to reflect the characteristics of the Project Site by reductions of 20 percent for retail uses and 10 percent for restaurant uses, to account for the high level of transit service at the Project Site, the high density of development and proximity of destinations within walking distance, and on-site interaction between the uses on the Project Site. These factors would tend to reduce the number of auto trips, and hence parking demand, through higher levels of walking and use of transit. These are very conservative reduction factors, in that for this project location in reality the levels of transit use and walking could be expected to be much higher. However, these reduction factors are consistent with those used in the traffic analysis (Section IV.K.1, Traffic/Transportation) which were set conservatively low in order to produce a worst-case traffic analysis. The study then addressed monthly variations in parking demand and determined that the peak month would be December, followed closely by June and July. The subsequent analysis then focused on the peak month. The analysis also looked at parking demand variations by time of day and - because different uses peak at different times at the potential for sharing parking between commercial uses. Peak Month (December) Weekday Parking Demand This analysis showed that the peak commercial parking demand on a weekday would occur during the evening. The actual peak demand would be 186 parking spaces between 7:00 p.m. and 8:00 p.m. This would exceed the 150 spaces in the garage by 36 spaces. During the weekday daytime, the parking demand would peak at 161 spaces at 1:00 p.m. to 2:00 p.m. which would exceed the 150 spaces in the garage by 11 spaces. Page IV.K.2-6
Saturday Parking Demand The Saturday parking demand would peak at 160 spaces in the evening between 8:00 p.m. and 9:00 p.m. This would exceed the 150 space supply by 10 spaces. During the Saturday daytime, the parking demand would peak at 137 spaces between 2:00 p.m. to 4:00 p.m., which would be less than the parking supply of 150 spaces. Secondary Peak Months (June and July) December is a unique month because of the holidays, so analysis was also conducted for the secondary peak months of June and July. Weekday Parking Demand This analysis showed that the peak commercial parking demand on a weekday would occur during the evening. The actual peak demand would be 181 parking spaces between 7:00 p.m. and 8:00 p.m. This would exceed the 150 spaces in the garage by 31 spaces. During the weekday daytime, the parking demand would peak at 150 spaces at 1:00 p.m. to 2:00 p.m. which would be the same as the 150 space supply which would therefore be adequate. Saturday Parking Demand The Saturday parking demand would peak at 162 spaces in the evening between 8:00 p.m. and 9:00 p.m. This would exceed the 150 space supply by 12 spaces. During the Saturday daytime, the parking demand would peak at 122 spaces between 2:00 p.m. to 4:00 p.m., which would be less than the parking supply of 150 spaces. Typical Month Parking Demand The above analysis identified parking demand for the peak and secondary peak months of the year (June, July and December). During the rest of the year, the typical month parking demand would be lower. During a weekday evening the peak parking demand would be 161 spaces 11 spaces over the proposed supply, and during the weekday daytime the peak demand would be 137 spaces less than the proposed supply. During a Saturday evening the peak parking demand would be 143 spaces less than the proposed supply, and during the Saturday daytime the peak demand would be 113 spaces also less than the proposed supply. Page IV.K.2-7
Conclusions on Estimated Commercial Parking Demand A comprehensive analysis of estimated commercial parking demand has addressed the peak month, secondary peak months and typical months. During the peak month of December, the commercial peak parking demand for the Proposed Project would exceed the proposed commercial 150 space supply by 36 spaces on a weekday evening and by 10 spaces on a Saturday evening. Also during a peak month, the commercial peak parking demand during the weekday daytime demand would exceed the commercial supply by 11 spaces and during the Saturday daytime would be adequately accommodated by the proposed commercial 150 space supply. During the secondary peak months of June and July, the commercial peak parking demand for the project would exceed the proposed commercial 150 space supply by 31 spaces on a weekday evening and by 12 spaces on a Saturday evening. During these secondary peak months, the commercial peak parking demand during the weekday daytime and during the Saturday daytime would be adequately accommodated by the proposed commercial 150 space supply. During a typical month, the commercial peak parking demand for the Proposed Project would exceed the proposed commercial 150 space supply by 11 spaces on a weekday evening. During a typical month, the commercial peak parking demand during the weekend evening and during the daytime (weekday or weekend) would be adequately accommodated by the proposed supply. It is therefore concluded that there would be significant parking impacts due to the Proposed Project, because at certain peak times the proposed parking supply would be less than the estimated peak parking demands. As such, impacts with respect to estimated commercial parking demand would be significant. On-Street Parking Some amount of on-street parking is allowed on all three street frontages of the Project Site. There are currently a total of 12 on-street parking spaces, three commercial loading zone spaces, and four driveway curb cuts on streets adjacent to the Project. On Vermont Avenue there are currently six on-street spaces, and two driveway curb cuts, adjacent to the Project Site. On-site parking is not allowed between 7:00 a.m. and 9:00 a.m. and between 4:00 p.m. and 7:00 p.m. except on Saturday and Sunday. Parking is allowed outside of these hours, with a one hour time limit between 9:00 a.m. and 4:00 p.m., except Sundays. It is not anticipated that the Project would cause any of these parking spaces to be removed. The two proposed Project driveway curb cuts would be in approximately the same location as the existing two curb cuts. It is possible, however, that LADOT may require the removal of one or two existing on-street parking spaces immediately south of the Project Site to provide enhanced visibility to the Project s commercial driveway. On Wilshire Boulevard, there are currently four on-street parking spaces, one commercial loading zone, and one driveway curb cut, adjacent to the Project Site. On-street parking is not allowed between 7:00 Page IV.K.2-8
a.m. and 9:00 a.m. and between 4:00 p.m. and 7:00 p.m. except on Saturday and Sunday. Parking is allowed outside of these hours, with a one hour time limit between 9:00 a.m. and 4:00 p.m., except on Sundays. The Project would not cause any of the parking spaces or the loading zone to be removed. The existing curb cut would not longer be necessary and would be removed. The curb space created could be re-utilized. It is proposed to replace the curb-cut with a passenger loading zone. On Shatto Place, on-street parking is allowed at all times, with a one hour time limit between 8:00 a.m. and 6:00 p.m., except on Sundays. There are currently two on-street parking spaces, two commercial loading zones, and one driveway curb cut adjacent to the Project Site on Shatto Place. A curb cut would remain for the Proposed Project. It is proposed that the existing two on-street parking spaces and two loading zones in front of the Project Site would remain as is. The Project could thus cause for the possible removal of one or two on-street parking spaces on Vermont Avenue. This is not considered to be a significant impact given that there would continue to be on-street parking available at many other locations in the vicinity of the Project, as well as at numerous off-street garages. As such, impacts associated with on-street parking would be less than significant. CUMULATIVE IMPACTS Development of the Proposed Project in conjunction with the 49 related projects identified in Section III (Environmental Setting) would increase the parking demand in the Mid-Wilshire area of the City of Los Angeles. The Proposed Project would meet the commercial parking requirements as outlined by the Planning and Zoning Code, and with mitigation, would also meet the estimated demand for commercial parking. However, the Proposed Project would fail to meet the residential parking requirements as outlined by both the Planning and Zoning Code and the City Planning Department Deputy Advisory Agency. It should be noted that these impacts would be site-specific and would not be common to (nor shared with, in an additive sense) the parking impacts on other sites. Furthermore, development of each of the related projects would be subject to parking requirements as outlined by the Planning and Zoning Code and the City Planning Department Deputy Advisory Agency. As such, cumulative parking impacts would be less than significant. MITIGATION MEASURES Construction Mitigation Measures (K.2-1) In order to mitigate potential parking impacts from construction workers the Project shall, prior to commencing construction, develop a Construction Parking Plan requiring construction workers to park off-street and not use on-street parking spaces. The Project may need to enter into some form of temporary arrangement with parking garages in the area of the Project to provide a sufficient supply of off-street spaces for the construction workers. Page IV.K.2-9
Operation Mitigation Measures (K.2-2) The Project Applicant shall request and obtain approval for a variance seeking relief from the City Planning Department Deputy Advisory Agency s parking standards; (K.2-3) The Project Applicant shall request and obtain approval for a variance seeking relief from the Planning and Zoning Code s residential parking standards; (K.2-4) The Project Applicant shall provide on-site valet parking at peak times (i.e., on peak evenings and in the peak month of December) in an effort to provide and additional 36 commercial parking spaces on-site (for a total of 186 commercial spaces). LEVEL OF SIGNIFICANCE AFTER MITIGATION The preceding analysis identified significant parking impacts as follows: Residential Parking There would be potentially significant parking impacts from not meeting the Advisory Agency Policy parking requirement for condominiums, and by being slightly below the City Code for residential units. For the reasons identified in the earlier discussion essentially because the Proposed Project is adjacent to a rail transit station and to high levels of bus transit service, as well as being located in a higher density corridor with greater opportunities for walk trips, the analysis concluded that sufficient residential parking would be provided by the Proposed Project. The Proposed Project is located next to a Metro Red Line rail stations, and in an area with high levels of bus transit. It is also located in an area of high density development with many destinations within walking distance. Providing additional, and possible excess parking, is in contradiction of City goals to encourage people to take transit and providing land uses in the vicinity of transit stations that are transit supportive. Providing an abundance of parking would encourage greater auto use. The Proposed Project parking supply is consistent with the vision for residential parking supply of 1.5 spaces per dwelling unity in the City s Land Use/Transportation Policy (LUTP) of the Transportation Element in the City s General Plan for a Major Bus Center. No additional residential parking is therefore proposed. The Proposed Project design for the garage has been developed to be as efficient as possible, with the maximum possible amount of tandem spaces. It has also been designed to minimize the impact of parking on the building and visual environment. Adding an additional parking level would result in a higher building podium and a higher overall building height neither of which is considered desirable by the developer. The Proposed Project proponent is prepared to support the provision of Flexcar in the Project area. Flexcar is an organization that provides cars available for registered members to use only when they need Page IV.K.2-10
to. In effect, it is a shared car available to many users. It can be an affective way of reducing overall car ownership. It is anticipated that an on-street parking space could be provided outside the Proposed Project for Flexcar. The Flexcar would be available to both the Proposed Project and non-project users as long as they were Flexcar members. The Project developer has successfully collaborated with Flexcar in multiple developments and is currently working with them to bring such ride-share vehicles to downtown Los Angeles. With respect to CEQA, however, this impact would remain significant and unavoidable. Commercial Parking The earlier parking analysis determined that there would be a significant project parking impact, in that the peak parking demand would exceed the proposed parking supply at certain peak times. For much of the time however, the proposed commercial parking supply would be adequate to meet parking demands. As a mitigation measure, the project proposes to provide on-site valet parking at peak times (i.e., on peak evenings and in the peak month of December). This would provide an additional 36 parking spaces onsite, to bring the total to 186 spaces when valet operations were provided. This measure would provide sufficient parking for all parking needs for all time periods (weekday and weekend).with the implementation of this mitigation measure, there would be no significant commercial parking impacts due to the Proposed Project. Page IV.K.2-11