IV. ENVIRONMENTAL IMPACT ANALYSIS H. LAND USE AND PLANNING

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1 IV. ENVIRONMENTAL IMPACT ANALYSIS H. LAND USE AND PLANNING ENVIRONMENTAL SETTING The Project Site is located in Los Angeles County, within the Hollywood Community Plan area of the City of Los Angeles. The Proposed Project site is located at the northwest corner of La Brea Avenue and Willoughby Avenue at the confluence of the Mid-Wilshire, Hancock Park, and West Hollywood districts of the City of Los Angeles (see Figure II-1, Regional Location Map and Figure II-2, Project Location Map). The block that includes the Project site is surrounded by Romaine Street on the north, Willoughby Avenue on the south, La Brea Avenue on the east, and Formosa Avenue on the west. The Proposed Project site consists of six separate parcels, totaling 99,150 square feet (2.27 acres) of land (see Figure II-3). The site is currently developed with a 41,469-square-foot, 2-story office/studio building; a 13,937-square-foot single-story office building; a 667-square-foot single-story guard shack; and a 600-square foot single story building. Six satellite communication dishes are located on the rooftop of the office/studio building and three satellite communication dishes are mounted on the ground within the site. Vehicular access to the site is presently provided by three gated driveways along Willoughby Avenue. A 20-foot-wide alleyway extends to a fourth gated exit at Romaine Street. Pedestrian access is provided by paved sidewalks on each of the surrounding streets. The Project site is surrounded by an eclectic mix of urban land uses. The block that includes the Project site is occupied by a four-story office building, and commercial and light industrial uses such as Mole- Richardson & Co., Pacific Radio, SuperColor Imaging, and automobile repair facilities. Mole- Richardson & Co., a studio-related company, is located immediately north of the Project site along La Brea Avenue. A multi-tenant light industrial building is located immediately north of the Project site along Formosa Avenue. North of Romaine Street in the City of West Hollywood is the West Hollywood Gateway center, which includes a Target and Best Buy. To the south of the Project site are a commercial building and multi-family residential building along Willoughby Avenue between La Brea Avenue and Detroit Street, and five small scale, California bungalow style single-family homes that appear to have been constructed during the period of the 1920s to the 1940s along Willoughby Avenue between Detroit Street and Formosa Street. Additional single family homes are located within this block. To the east along La Brea Avenue are commercial and office uses, although an aggregate materials batch plant (concrete plant) is also located at the northeast corner of La Brea Avenue and Romaine Street. A singlestory studio building is located immediately west of the Project site at the intersection of Willoughby Avenue and Formosa Avenue. Land uses located along the western side of Formosa Avenue between Willoughby Avenue and Santa Monica Avenue include multi-family residences, a major electricity grid facility and a studio facility. Refer to Figure II-8 for existing views of the surrounding area. According to the Site Assessment report for the Former KCOP Production Studios, 915 North La Brea Avenue, Los Angeles, California prepared by PES Environmental Inc., March 10, 2005, historical data indicates that an oil station owned by Shell Company was located on the eastern portion of the Project site Page IV.H-1

2 as early as The Shell station was no longer present at the site in By 1950, two buildings had been constructed at the site along North La Brea and Willoughby Avenues. According to a 1950 Sanborn Fire Insurance Map, the building at 915 North La Brea Avenue was occupied by Bohemian Distributing Company and the building at 7169 Willoughby Avenue was occupied by the Railway Express Agency. The entire site was later purchased, adapted, and operated by KCOP Channel 13 as a broadcast studio facility from 1960 until January The facility is intermittently leased out for short-term film studio production and post-production work. Existing Land Use Regulations The Project Site is located within the jurisdiction of the City of Los Angeles and is subject to its laws and regulations, including its General Plan designation and zoning regulations, as well as other local and regional land use plans. At the local level, development of the Project Site is guided by the General Plan of the City of Los Angeles, which provides general guidelines for land uses and planning policy for the entire city. Within the General Plan, the Hollywood Community Plan creates more specific land use policies for the area that includes the Project site. All development activity on-site is subject to the land use regulations of the Hollywood Community Plan and the City of Los Angeles Planning and Zoning Code (City Zoning Code). At the regional level, the Project Site is located within the planning area of the Southern California Association of Governments (SCAG), the region s federally-designated metropolitan planning organization. SCAG s regional planning policies are contained within the Regional Comprehensive Plan and Guide (RCPG). The Proposed Project is also located within the South Coast Air Basin (SCAB) and therefore is within the jurisdiction of the South Coast Air Quality Management District (SCAQMD). As such, the Proposed Project is subject to SCAQMD s Air Quality Management Plan (AQMP). In addition, the Project Site is subject to the Congestion Management Plan (CMP) for Los Angeles County. City of Los Angeles General Plan The City of Los Angeles General Plan is a comprehensive, long-range declaration of purposes, policies and programs for the development of the City of Los Angeles. The General Plan is a dynamic document consisting of eleven elements, ten Citywide elements (Air Quality Element, Conservation Element, Historic Preservation and Cultural Resources Element, Housing Element, Infrastructure Systems Element, Noise Element, Open Space Element, Public Facilities and Services Element, Safety Element, and Transportation Element) and the Land Use Element or plan for each of the City s 35 Community Planning Areas. The General Plan Framework Element is a strategy for long-term growth, which sets a citywide context to guide the update of the community plan and citywide elements. The Project Site is located in the Hollywood Community Plan area. The General Plan land use designation for the Project Site is Limited Manufacturing to reflect the Project site s underlying zoning, which is MR1-1 (Restricted Industrial, Height District 1). There are no height limits associated with the existing height when coupled with the existing zoning. Page IV.H-2

3 The Hollywood Community Plan The Hollywood Community Plan, dated December 13, 1988, sets forth objectives to maintain the community s distinctive character. The City is in the process of updating the Hollywood Community Plan but has not completed the update process. Some of the stated objectives include: To coordinate the development of Hollywood with that of other parts of the City of Los Angeles and the metropolitan area. To further the development of Hollywood as a major center of population, employment, retail services, and entertainment; and to perpetuate its image as the international center of the motion picture industry. To designate lands at appropriate locations for various private uses and public facilities in the quantities and at densities required to accommodate population and activities projected to the year To make provision for the housing required to satisfy the varying needs and desires of all economic segments of the Community, maximizing the opportunity for individual choice. To encourage the preservation and enhancement of the varied and distinctive residential character of the Community, and to protect lower density housing from the scattered intrusion of apartments. To promote economic well being and public convenience through: - Allocating and distributing commercial lands for retail, service, and office facilities in quantities and patterns based on accepted planning principles and standards. - Designating land for industrial development that can be so used without determent to adjacent uses of other types, and imposing restrictions on the types and intensities of industrial uses as are necessary to this purpose. - Encouraging the revitalization of the motion picture industry. - Recognizing the existing concentration of medical facilities in East Hollywood as a center serving the medical needs of Los Angeles. To provide a basis for the location and programming of public services and utilities and to coordinate the phasing of public facilities with private development. To encourage open space and parks in both local neighborhoods and in high density areas. Page IV.H-3

4 To make provision for a circulation system coordinated with land uses and densities and adequate to accommodate traffic. To encourage the preservation of open space consistent with property rights when privately owned and to promote the preservation of views, natural character and topography of mountainous parts of the Community for the enjoyment of both local residents and persons throughout the Los Angeles Region. Relevant objectives and policies of the Hollywood Community Plan as they pertain to the Proposed Project, along with an assessment of the Project s consistency with those objectives and policies, are presented below in the Environmental Impacts subsection of this Draft EIR section. Existing Zoning The Project site is currently zoned MR1-1, which is a Restricted Industrial Zone. Commercial uses such as banks, clinics, laboratories, and offices are permitted within the MR1-1 zone, although the zone is primarily intended for industrial uses such as software development, printing, publishing, and media production. The Project site is located in Height District 1, which imposes Floor Area Ratio (FAR) limitations, but does not impose any development height limits for a MR1-1 zone. Properties to the south of the Project site along La Brea Avenue are zoned C4-1VL (Commercial) and properties located south of the Project site on Willoughby Avenue are zoned [Q] R3-XL (Multiple Dwelling). Los Angeles City Planning Commission Do Real Planning The Los Angeles City Planning Commission s presentation on April 19, 2007 announced Do Real Planning policies for the City. Among these goals are creating a walkable city, requiring density around transit, promoting housing, locating jobs near housing, promoting green buildings, promoting landscaping, and promoting smart parking solutions Industrial Land Use Policy Project The Industrial Land Use Policy Project (ILUP) is a comprehensive study of the use of industrial-zoned land within the City of Los Angeles, formerly known as the Mayor s Industrial Development Policy Initiative. In order to ensure appropriate development and foster a diverse economy, the Department of City Planning (Planning Department) and the Community Redevelopment Agency of Los Angeles (CRA) were instructed to undertake the study of the use of industrial-zoned land in the City and provide policy recommendations to guide future land use decisions. In February 2006, Planning Department staff began surveying existing land uses within certain industrial areas in the City, including Hollywood, as part of the ILUP. The Planning Department released the results of the survey and preliminary recommendations regarding the use of industrial-zoned land in Hollywood in May 2006 for public review and comment. Page IV.H-4

5 Implementation of the ILUP in the Hollywood area is expected to coincide with the Hollywood Community Plan update, which is currently underway as noted above. The Planning staff s preliminary recommendations for the Hollywood area included a recommendation that the block including the Project site be designated an industrial preservation area with no residential use. This preliminary recommendation was challenged by a number of interested parties, including staff of Council District 5, as incompatible and inconsistent with the dominant commercial use along the La Brea corridor and inconsistent with City policies promoting the location of mixed use development within transit corridors. The Planning staff subsequently recommended that the Project site be designated as industrial mixed-use, which would permit limited residential uses. The Director of Planning issued a subsequent letter dated February 22, 2008, indicating that the industrial land use memo was not intended to change existing Planning Department policy and that such policy decisions will take place as part of the currently underway Community Plan update process. The Community Plan update process is ongoing and it is unclear when the City Council and the mayor would receive a formal recommendation of policies for their consideration. Until the Community Plan update process is complete, it is anticipated that the City will not have adopted any specific policies that would affect the rezoning of industrial sites to non-industrial uses. According to the City, until a new comprehensive industrial land use policy is adopted, any application for a nonindustrial use on industrially zoned land will continue to be considered on a case-by-case basis. The Director of Planning issued a memorandum dated March 21, 2007 establishing Interim Procedures Regarding Applications for Residential Projects on Industrial Zoned Property Determined to be No Longer Viable for Industrial Use, which sets forth interim procedures for addressing discretionary actions in those areas in which the Planning Department s study (and any subsequent actions) recommends that industrial zoning may no longer be viable or appropriate and that residential use could be considered (the Interim Procedures). According to the Interim Procedures, the environmental clearance for all applications requesting uses other than industrial should address the uses to be removed or displaced, the loss of jobs, and any impacts resulting from the conversion of industrial to non-industrial use. It should also be noted that preservation of industrial land is an economic, not an environmental issue. Accordingly, the ILUP is an economic policy project and is not intended to and does not promote the reduction of the environmental impacts of other uses of the land subject to the ILUP. Regional Comprehensive Plan and Guide The Project Site is located within the six-county region, which comprises the Southern California Association of Governments (SCAG) planning area. SCAG is a Joint Powers Agency with numerous roles and responsibilities relative to regional issues that cross jurisdictional boundaries. Included in SCAG's responsibilities is the preparation of the Regional Comprehensive Plan and Guide (RCPG) in conjunction with its constituent members and other regional planning agencies. The RCPG provides a general view of the plans of the various regional agencies that will affect local governments, or that Page IV.H-5

6 respond to the significant issues facing southern California, including growth management, and is intended to serve as a framework for decision-making with respect to growth and changes that can be anticipated by the year 2015 and beyond. In addition, the RCPG proposes a strategy for voluntary use by local governments, which will assist them in addressing issues related to future growth and in assessing the potential impacts of proposed development projects within the context of the region. Thirteen subregions have been recognized as partners in preparation of the RCPG and have submitted input to the plan to ensure that it reflects local concerns which form the basis of the region s bottom-up planning process. The Project site is located within the Los Angeles Subregion. The RCPG includes five core chapters (Growth Management, Regional Mobility, Air Quality, Water Quality, and Hazardous Waste Management), which respond directly to the federal and state requirements placed on SCAG and form the basis for certification of local plans. Ancillary chapters within the RCPG (Economy, Housing, Human Resources and Services, Public Finance, Open Space and Conservation, Water Resources, Energy, and Integrated Waste Management) reflect other regional plans but are strictly advisory and establish no new mandates or policies for the region or the local governments. Adopted RCPG polices related to land use are contained primarily in Chapter 3 Growth Management. The purpose of the Growth Management Chapter is to present forecasts which establish the socio-economic parameters for the development of the Regional Mobility and Air Quality Chapters of the RCPG, and to address issues related to growth and land consumption by encouraging local land use actions which could ultimately lead to the development of an urban form that would help minimize development costs, save natural resources, and enhance the quality of life in the region. Impacts associated with air quality and regional mobility are discussed in Sections IV.C, Air Quality and IV.L, Transportation and Traffic, respectively. Air Quality Management Plan The City of Los Angeles is also located within the South Coast Air Basin and therefore is within the jurisdiction of the South Coast Air Quality Management District (SCAQMD). In conjunction with SCAG, SCAQMD is responsible for formulating and implementing air pollution control strategies. The Air Quality Management Plan (AQMP), (adopted in 1997 by SCAQMD and recently revised in August 2003) is intended to establish a comprehensive air pollution control program leading to the attainment of state and federal air quality standards in the South Coast Air Basin, thereby addressing the requirements set forth in the state and Federal Clean Air Acts. SCAG assists SCAQMD in fulfilling these responsibilities. Section IV.C, Air Quality, provides a discussion of the Project s consistency with the 2007 AQMP. Congestion Management Plan The Congestion Management Program (CMP) is a state-mandated program enacted by the state legislature to address the increasing concern that urban congestion is affecting the economic vitality of the state and diminishing the quality of life in many communities. As a new approach to addressing Page IV.H-6

7 congestion concerns, the CMP was created to: 1) link land use, transportation, and air quality decisions; 2) develop a partnership among transportation decision makers on devising appropriate transportation solutions that include all modes of travel; and 3) propose transportation projects which are eligible to compete for state gas tax funds. The CMP, as adopted in 1992 and revised in 1995, includes a system of highways and roadways with minimum level of service (LOS) standards, transit standards, a trip reduction and travel demand management element, a program to analyze the impacts of local land use decisions on the regional transportation system, a seven-year capital improvement program, and a countywide computer model to evaluate traffic congestion and recommend relief strategies and actions. The CMP incorporates procedures for meeting deficiency plan requirements, or strategies that mitigate or improve congestion and air quality. Proposed projects which have the potential to affect the designated CMP network (mostly main-line freeway segments) are required to identify and mitigate their adverse effects on the network. Section IV.L, Transportation and Traffic, provides an analysis of the Project s potential impact on the CMP network. ENVIRONMENTAL IMPACTS Thresholds of Significance In accordance with Appendix G to the State CEQA Guidelines, the project would have a significant impact on land use if it would cause any of the following conditions to occur: (a) Physically divide an established community; (b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental impact; or (c) Conflict with any applicable habitat conservation plan or natural community conservation plan. As set forth in the L.A. CEQA Thresholds Guide, the determination of significance shall be made on a case-by-case basis, considering the following factors: Land Use Consistency Whether the proposal is inconsistent with the adopted land use/density designation in the Community Plan, redevelopment plan or specific plan for the site; Whether the proposal is inconsistent with the General Plan or adopted environmental goals or policies contained in other applicable plans; Page IV.H-7

8 Land Use Compatibility The extent of the area that would be impacted, the nature and degree of impacts, and the types of land uses within that area; The extent to which existing neighborhoods, communities, or land uses would be disrupted, divided or isolated, and the duration of the disruptions; and The number, degree, and type of secondary impacts to surrounding land uses that could result from implementation of the proposed project. Project Impacts Land Use Consistency Regional Plans As discussed previously, the Project site is located within the six-county region that comprises the SCAG planning area. Adopted policies included in SCAG s RCPG (1996) that are related to land use are contained primarily in Chapter 3, Growth Management. The Proposed Project would be consistent with policies set forth in this chapter, as they would: 1) be located in an area where improvements would not cause adverse environmental impacts, and 2) be located in an area that is generally developed or landscaped, thereby preserving open space areas. Furthermore, as the Proposed Project would involve the construction of a mixed-use retail/residential use on a previously developed site in an urbanized area, it would not result in substantial growth in the City or sub-region and, thus, would be consistent with SCAG s growth projections. Project consistency with the SCAQMD s AQMP is discussed in Section IV.C, Air Quality along with the determination that the Proposed Project would be consistent with the AQMP. Project consistency with the CMP is discussed in Section IV.L, Transportation and Traffic along with the determination that the impact of the Proposed Project would be less than significant and that no additional CMP analysis is necessary. Hollywood Community Plan Objectives As discussed previously, the City of Los Angeles General Plan contains goals, numerous policies and objectives to guide development and uses planned within the City. Existence of an inconsistency between a proposed project and an applicable general plan is a legal determination, vested in the City Council and subject to court review if challenged. Inconsistency is not an impact under CEQA plan inconsistencies in and of themselves are not significant impacts on the environment under CEQA. The City of Los Angeles Hollywood Community Plan identified objectives and their applicability to the Proposed Project are discussed in Table IV.H-1. Page IV.H-8

9 Table IV.H-1 Hollywood Community Plan Objectives Discussion Proposed Project Objectives To further the Development of Hollywood as a major center of population, employment, retail services, and entertainment; and to perpetuate its image as the international center of the motion picture industry. To designate lands at appropriate locations for various private uses and public facilities in the quantities and at densities required to accommodate population and activities projected to the year To make provision for the housing required to satisfy the varying needs and desires of all economic segments of the Community, maximizing the opportunity for individual choice. To promote economic well being and public convenience through: - Allocating and distributing commercial lands for retail, service and office facilities in quantities and patterns on accepted planning principles and standards. - Designating land for industrial development that can be used without determent to adjacent uses of other types, and imposing restrictions on the types and intensities of industrial uses as are necessary for this purpose. - Encouraging the revitalization of the motion picture industry. To encourage open space and parks in both local neighborhoods and in high density areas. Discussion The Project applicant proposes a mixed-use project that includes additional housing opportunities, as well as neighborhood-serving retail space, that would provide jobs and benefit the general community and specifically serve the immediate area surrounding the Project site. Demolition of the underutilized studio at the Project Site would not substantially affect the Hollywood area s image. The Project as proposed would intensify the use on site and provide additional housing in Hollywood, along with retail and commercial uses that would serve the population of the surrounding area beyond the projected year of The Proposed Project provides 219 dwelling units, and would include varying unit sizes from singles (studios) to 2- bedroom units, thus accommodating various economic segments of the Hollywood Community by offering different choices in housing types. The Project applicant proposes a mixed-use project that includes additional housing opportunities, as well as neighborhood-serving retail space, that would benefit the general community and specifically serve the immediate area surrounding the Project site. Development of the Proposed Project would require a General Plan Amendment from Limited Manufacturing to Neighborhood Commercial for the property as well as a Zone Change from MR1-1 to RAS4-1. This would locate new commercial and residential uses in close proximity to existing residential, commercial, and industrial uses. Demolition of the underutilized studio at the Project Site would not discourage the revitalization of the motion picture industry in Hollywood since the existing buildings have been used infrequently for studio uses over the past few years and no entertainment entity has pursued the purchase of the property. The Project would provide private open space and recreational areas for Project residents. Payment of the required Recreation and Park mitigation fees would alleviate impacts on existing parks. Page IV.H-9

10 Table IV.H-1 (Continued) Hollywood Community Plan Objectives Discussion Proposed Project Objectives To make provision for a circulation system coordinated with land uses and densities and adequate to accommodate traffic. Source: Hollywood Community Plan and Christopher A. Joseph & Associates, Discussion The Project applicant has prepared a Traffic Study that analyzes the potential impacts to the area s circulation system. The Traffic Study is required to be reviewed and approved by the Los Angeles Department of Transportation prior to any other project approvals and permits. (See Section IV. L, Transportation and Traffic) The Project applicant is requesting a General Plan Amendment to change the land use designation for the Project site from Limited Manufacturing to Neighborhood Commercial. As discussed previously, the Project site is surrounded by a mix of commercial, industrial and residential uses. Accordingly, a change in the land use designation to Neighborhood Commercial would be consistent with uses surrounding the Project and would be consistent with the general commercial nature of the La Brea corridor. The Project applicant is also requesting a Zone Change to the RAS4-1 designation. According to Los Angeles City Ordinance No. 174,999 (effective 1/15/03), the stated purpose of this zoning designation is to provide a mechanism to increase housing opportunities, enhance neighborhoods, and revitalize older commercial corridors. The RAS 4 Zone is intended to provide a tool to accommodate projected population growth in mixed use and residential projects that is compatible with existing residential neighborhoods. The RAS 4 zoning is allowed in areas designated as General Commercial in the applicable community plans. The proposed zone change to RAS 4 would support the goals of the City of Los Angeles General Plan and the stated purpose of L.A. City Ordinance No. 174,999 in establishing the RAS4 zone. Based on this information, approval of the requested General Plan Amendment and Zone Change would be a less than significant impact. One block north of the Proposed Project site, the City of West Hollywood has a designated Commercial- Regional Center at the corner of Santa Monica Boulevard and La Brea Avenue. Under the Transportation Element of the City of Los Angeles General Plan, Santa Monica Boulevard is designated as a Transit Priority Arterial Street. 1 Therefore the proposed zone change to RAS 4 would support the goals of the City of Los Angeles General Plan and the stated purpose of L.A. City Ordinance No. 174,999 in establishing the RAS4 zone. Although the Project would have more signage than generally allowed in a RAS4 zone, the nature of a RAS zone is to require ground floor commercial activities to enliven and activate the street. If the Project 1 Page IV.H-10

11 had multiple ground floor commercial tenants, each would be allowed signage. Additionally, La Brea Avenue is a major commercial corridor where signage is allowed and commonplace. As proposed, the signage would be primarily located along La Brea Avenue and the western commercial portion of Willoughby Avenue. The Project applicant is requesting approval of a Variance to allow the amount of signage proposed consistent with other businesses along La Brea Avenue. As discussed in Section IV.B, Aesthetics, a mitigation measure is recommended to require signage on Willoughby Avenue to be turned off by 10:00 PM to reduce potential nighttime illumination impacts to a less than significant level. Accordingly, if the decision makers should determine that the amount of signage is appropriate by approving a Variance, then the impact created with the inconsistence with the Code regarding the amount of signage in the RAS4 zone would be reduced to a less-than-significant level. Industrial Land Use Policy Project Although the Planning staff has preliminarily recommended the Project site be designated an industrial preservation area, no formal recommendation has been made to the Planning Commission. Accordingly, the City has not adopted any specific policies that would affect the rezoning of industrial sites to nonindustrial uses. The interim procedures articulated by the director of Planning require such projects to file a zone change and plan amendment. As a result, based on the approval of the requested entitlements, implementation of the proposed Project would not conflict with any applicable plans or policies adopted by agencies with jurisdiction over the Project. Additionally, policies involving the preservation of industrial land, when and if adopted by the City, would not be adopted for the purpose of mitigating or avoiding an environmental impact but rather to address economic impacts from the loss of industrial land. Moreover, locating housing adjacent to existing commercial and light industrial activities would fulfill the City s goals, as set forth in the General Plan Framework, to establish multi-family neighborhoods which enhance the quality of life for the City s existing and future residents and to concentrate housing in the City s centers and along primary transit corridors such as La Brea Avenue. The Project would also promote the Do Real Planning policies relating to requiring density around transit, promoting housing, and locating jobs near housing. Based on the foregoing, change of the land use designation and rezoning of the Project site is consistent with the General Plan and adopted environmental goals or policies contained in other applicable plans and would not constitute a significant impact with respect to any land use plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental impact. Applicable Conservation Plan or Natural Community Conservation Plan The Project site is not subject to any conservation plan or natural community conservation plan. As previously discussed, the Project site is located in a highly urbanized area of the City of Los Angeles. The Project site is built with structures and surface parking lots. Therefore, the Proposed Project would not conflict with any habitat conservation plan or community conservation plan and there would be no impact. Page IV.H-11

12 Land Use Compatibility Physically Divide an Established Community The potential for the Proposed Project to physically divide an established community is based on comparison of the existing land uses on and adjacent to the Proposed Project site. The Proposed Project site is located at the southwestern corner of a developed urban block and is currently developed with television studio uses. The block that includes the Project site is occupied by a four-story office building, and commercial and light industrial uses such as Mole-Richardson & Co., Pacific Radio, SuperColor Imaging, and automobile repair facilities. Mole-Richardson & Co., a studio-related company, is located immediately north of the Project site along La Brea Avenue. A multi-tenant light industrial building is located immediately north of the Project site along Formosa Avenue. The Proposed Project is a mixed-use retail/residential development which would replace the existing studio facility at the site. As such, the Proposed Project would neither physically divide an established community on the block that includes the Project site, nor in the surrounding community. No separation of uses or disruption of access between land use types would occur as a result of the Proposed Project. Therefore, implementation of the Proposed Project would not disrupt or divide the physical arrangement of the established surrounding community. No impact would occur. General Compatibility As discussed previously, the Project applicant is requesting a community plan change in land use designation from Limited Manufacturing to Neighborhood Commercial and a zone change to the RAS4-1 designation. The RAS4 Zone is intended to provide a tool to accommodate projected population growth in mixed use and residential projects that is compatible with existing residential neighborhoods. The RAS4 zoning is allowed in areas designated as General Commercial in the applicable community plans. The RAS4-1 zone and height district designation would allow a floor area ratio (FAR) of 3.0. The 3.0 FAR and proposed 75-foot height would be greater than any existing development located near the Project site along La Brea Avenue. The proposed buildings would be taller than the one- and two-story buildings located immediately around the Project site. The Proposed Project includes townhouses along the Willoughby Avenue side and reduced heights to 37 feet gradually stepping back to the north rising 53 feet to 65 feet on the north side of the Project site to respond to the residential character of the neighborhood across Willoughby Avenue. In addition, new projects which could utilize the current zoning, as well as the RAS4 zone, are unlimited as to their height. Compatibility issues can also occur when a new land use would cast shadows for a long period of time over sensitive uses with outdoor activity areas such as residences. The proposed new buildings would be located to the north and east of existing residential units and the new buildings would not cast shadows on the existing residences during the prime daytime hours of 9:00 A.M. to 3:00 P.M, as illustrated previously in Section IV.B, Aesthetics, Figures IV.B-1 through IV.B-3. The industrial and commercial properties Page IV.H-12

13 located north of the Project site are not sensitive to shadows. Therefore, the Proposed Project would be compatible with the existing land uses in the vicinity of the Project site. MITIGATION MEASURES As discussed above, there would be no significant impacts on land use associated with the Proposed Project. Accordingly, no mitigation measures are recommended or required. CUMULATIVE IMPACTS Development of the Proposed Project in conjunction with the related projects would result in further infilling of various urban land uses in the cities of Los Angeles and West Hollywood. Each related project would be subject to individual review for conformance to current land use designations and zoning, and compatibility with surrounding land uses. Additionally, each related project would be subject to independent environmental review. These procedures would provide assurances that potential cumulative impacts related to land use consistency and compatibility would generally be less than significant. LEVEL OF SIGNIFICANCE AFTER MITIGATION Since there are no significant impacts associated with the Project, no mitigation is recommended or required and any remaining impact would be less than significant. Page IV.H-13