timothy g. dalunger phone: (sib) 986-2311 fax: (sib) 986

TIMOTHY G. DALUNGER

3rd Floor Phone: (SIB) 986-2311

Fax: (SIB) 986-6654 Fax to E-mail: (775) 256-8679

E-mail: tgd-esg@p_i'ISP~~.net

12925 Riverside Drive SHERMAN OAKS, ICAUFORNUA 90423

TRANSMITIAL

Date: 02/14/12

To: SHARON GIN- LEGISLATIVE ASSISTANT- PLUM COMMITTEE

Re: NEW WEST CHARTER SCHOOL MATTER COUNCIL FILE NO. 12-0088

Contents: • COPY OF LADOT APPEAL TO CITY COUNCIL

Message: MS. GIN: THIS APPEAL WAS FILED TODAY AND IS RELEVANT TO THE ABOVE-REFERENCED APPEAL PENDING BEFORE THE PLUM COMMITTEE SET FOR HEARING ON FEBRUARY 28. INDEED, UNTIL THE LADOT APPEAL IS COMPLETE, PERHAPS THE HEARING ON THE PLUM MATTER SHOULD BE POSTPONED SINCE THE DECISION OF THE TRANSPORTATION COMMITTEE COULD MATERIALLY AFFECT THE PLUM

MATTER. REGARDS, h;. A [X] For your information

[ ] Per your request

[ ] Please review and call me

[ ] Please sign and return

[ ] Please acknowledge receipt

[ ] Sent to me in error

TIMOTHY G. DALLINGER

Phone: (BIB) 9B6-2311 Fax: (BIB) 9B6-6654

Fax to E-mail: (775) 256-8679 E-mail: [email protected]

11880 NEBRASKA AVENUE

Los ANGELES, CALIFORNIA 90025

BY HAND DELIVERY

February 14, 2012

Ms. June Lagmay City Clerk CITY OF LOS ANGELES 200 South Main Street, Room 395 Los Angeles, CA 90012

Re: APPEAL TO LOS ANGELES CITY COUNCIL FROM DETERMINATION OF LADOT GENERAL MANAGER DEPARTMENT OF TRANSPORTATION CASE NO. WLA11-040 DEPARTMENT OF CITY PLANNING CASE NOS.:

CPC-2011-1923-CU-SPR AND ENV-2011-1924-MND 1905-1915 ARMACOST AVENUE, LOS ANGELES, CA 90025

Dear Ms. Lagmay:

In my capacities as a neighbor residing exactly one block north of the subject site and as a member of the unofficial Stoner Park Community Advocates, an unincorporated association consisting of many other neighbors residing within the vicinity of the proposed site, I hereby appeal to the City Council from the Letter of Determination dated January 13, 2012 issued by the LA Department of Transportation General Manager, Jaime de Ia Vega, ("Letter of Determination"]1 in response to my prior Appeal filed December 15, 2011 ["Prior Appeal"f of the LADOT Supplemental Traffic Assessment Report dated November 30, 2011 ["the Supplemental Assessment"]3 in the above referenced matter.

1 (a copy of which is attached hereto as Exhibit A) 2 (a copy of which is attached hereto as Exhibit B) 3 (a copy of which is attached hereto as Exhibit C)

Ms. June Lagmay City Clerk CITY OF LOS ANGELES Re: APPEAL TO LOS ANGELES CITY COUNCIL

FROM DETERMINATION OF GENERAL MANAGER DEPARTMENT OF TRANSPORTATION CASE NO. WLA11-040 DEPARTMENT OF CITY PLANNING CASE NO. ENV-2011-1924-MND 1905-1915 ARMACOST AVENUE, LOS ANGELES, CA 90025

February 14, 2012 Page2

Attached hereto is the substance and body of the Appeal to the City Council hereby filed with your office. Kindly advise the undersigned as to ensuing procedural steps as a result of the filing of this Appeal to the City Council.

Very tr. y yours,

Timothy G. allinger

Attachment (1) cc: Councilman Bill Rosendahl

Len Nguyen LA City Council Plum Committee Arthur L. Kassan, P.E. Members of Stoner Park Community Advocates

dot city council appeal 021412d1.1

APPEAL TO LOS ANGELES CITY COUNCIL

FROM

DETERMINATION OF LADOT GENERAL MANAGER

DEPARTMENT OF TRANSPORTATION CASE NO. WLA11-040 DEPARTMENT OF CITY PLANNING CASE NOS.

CPC-2011-1923-CU-SPR ENV -2011-1924-MND

1905-1915 ARMACOST AVENUE, LOS ANGELES, CA 90025

APPLICANT: NEW WEST CHARTER SCHOOL

APPELLANT: TIMOTHY G. DALLINGER, INDIVIDUALLY AND AS A MEMBER OF SPCA, AN UNINCORPORATED ASSOCIATION

TABLE OF CONTENTS

PAGE

INTRODUCTION

1. Facial Defects in the Letter of Determination.

2. Traffic flow and queuing problems.

i. Unacceptable levels of queuing and traffic obstruction on Armacost, Missouri and La GrangeAvenues.

Illegal stoppage of traffic northbound on Bundy Drive south of Missouri Avenue awaiting a right turn onto Missouri Avenue.

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3

5

10

ii.

iii.

iv.

v.

3. Parking

a. b.

Blockage of traffic on Bundy Drive southbound at Missouri Avenue awaiting a left turn onto Missouri Avenue in a very short left turn lane (3 vehicle capacity) located there. 10

Increased use of neighborhood streets for off-site parking due to reduction in on-site parking from 55 to 37 per proposed plan.

12 Inundation of the surrounding neighborhood by hundreds of additional parked vehicles on event nights during the school year of which the Applicant has stated there will be at least four.

12 Unaddressed after-school traffic and parking issues due to transportation needs associated with after-school activities at the site and the local park.

13 Miscellaneous traffic issues unresolved.

13 A. Danger to pedestrians from increased traffic flow B. No off-site policing or monitoring proposed 13 C. Unrealistic reliance on bicycling and public transit 13 D. Likelihood of student drivers and other TMMP 13

violations E. No busing required 14 F. Enforcement issues 14

i. Ineffectiveness, unenforceability and 14 illegality of Home-School Contract

14

15 Daily Parking Special events parking 15

16 CONCLUSION

16

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INTRODUCTION

The proposed site in question, 1905-1915 Armacost Avenue, is located on the southwest corner of Armacost and Missouri Avenues in the 90025 West LA neighborhood. That local, middle-class, mixed demographic neighborhood has consisted for almost 70 years of a community of Japanese-Americans who founded the neighborhood after World War II, elderly, renters, students from UCLA, singles and families with children. Though indeed located in the larger relatively economically blessed West LA neighborhood, the local neighborhood surrounding the site does not compare economically to the local Westwood, Brentwood or Bel Air neighborhoods nearby.

Applicant, New West Charter School, proposes to locate a State chartered middle and high school consisting of grades six through twelve at the site. The proposed school will consist of 875 students in addition to faculty, staff, vendors and visitors daily. The school as proposed and as presently operated nearby as a middle school only is a commuter school, not a community school drawing its students from a very wide geographic area on the west side of Los Angeles. The proposed commuter school use of the site therefore inherently carries with it very material traffic flow and parking challenges. There is absolutely no need for an additional high school in the local neighborhood which includes University High School within just five blocks and Venice High School within just a very few miles, both of which have the present capacity for additional students.

In connection with the proposed use of the site which is located in an M2-1 Zone, Applicant now seeks a conditional use permit. While the property has retained this zoning for decades, it is patently inappropriate to have this zoning classification, especially without any land use buffer, directly across from properties to the north and the east which are zoned R-1, single-family. Current and past land uses on contiguous parcels to the south and west include office, retain and light industrial uses, a fitness club and an LA City Animal Shelter. These uses typically carry with them intrusive conditions in the form of increased traffic, difficulty finding on street parking, vehiculargenerated noise and pollution, and deposition of trash.

This West Los Angeles local neighborhood surrounding the site is located in a traffic-congested and gridlocked area, near many arterial highways, and where vehicular commuters are increasingly using side streets to avoid the traffic back-up at major intersections. The Planning Department has recognized this dilemma. However, the West Los Angeles Transportation Improvement and Mitigation Specific Plan (West LA TIMP) to which the Planning Department has deferred provides exemptions for certain projects, including "tenant improvements with no change of use or increase in floor area." The Planning Department relies upon this exception pointing out that the Applicant in this case does not propose to increase the floor area of the existing improvements. However the Planning Department, in its deference to the West LA TIMP and its stated exception, fails to take into consideration Applicant's proposed change of use and enormous increase in density to 875 students plus faculty, staff,

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visitors and vendors totaling approximately 1,000 persons accessing the site daily. Further, the Planning Department ignores entirely the 1954 Certificate of Occupancy pursuant to which this site was approved for an oversize structure which on its face limits occupancy to no more than 500 for a site with only 55 parking spaces.

The site is located within one block of Bundy Drive, one mile of the major thoroughfares of Olympic and Pico Boulevards, as well as the 1-10 Santa Monica Freeway and the 1-405 San Diego Freeway. Vehicles from other neighborhoods traverse through this neighborhood to access these highways. As a result, many intersections are currently operating at levels of service of D, E, and F.

A traffic analysis prepared for this project by LADOT dated November 30, 2011 ("Supplemental Assessment"), included 14 study intersections, of which nine were determined to result in significant traffic impacts with the project. Of these, six intersections would experience declining levels of service at various peak traffic hours by 2015 even without the project.

The project site is improved with a single-story industrial structure built in 1954 in the M2-1 Zone. It is inappropriately located immediately adjacent to established, preexisting single-family homes in the R1-1 Zone. The Supplemental Assessment revealed that traffic is a significant issue even without the existence of the proposed school and that traffic in the vicinity will be further materially impacted as a result of this use.

Physical recreation is proposed to occur at Stoner Park located one block away from the site. 150 students, 60 at any one time, are presently contracted to utilize the park facilities which the park director has stated are overburdened and cannot accept use by additional students. Given the increased volume of street traffic associated with the proposed school, pedestrian safety would appear to be in question given the number of people whose use of Stoner Park has them walking past or close to the site during peak traffic periods. Unreasonably close attention to vehicles, especially at hazardous surrounding intersections, will be required of daily park users, many of whom are elderly or children.

Auditorium or large gathering uses are proposed to occur off-site at Beverly Hills High School with no explanation as to traffic management associated with such off-site uses. Similarly, evening gatherings at the site including parents of students proposed several times yearly have not been associated with any specific traffic management or parking plan to protect the surrounding residential neighbors from the invasion of several hundred vehicles transporting those attending such events.

The 14-foot tall, 49,885 square-foot existing structure will remain with no increase or decrease in floor area and no proposed changes to the existing inadequate setbacks. The primary pedestrian entrance is to be located along Armacost Avenue, with additional student access entrances from the parking lot. No parking plan has been proposed for those visitors utilizing the entrances planned for Armacost Avenue.

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Vehicular access is purportedly limited to ingress only along Missouri Avenue and egress only off of Armacost Avenue according to the revised proposal from Applicant as described in the Supplemental Assessment. Loading and unloading of students will supposedly be conducted entirely on-site within the small surface parking lot. Such a plan, even with trip caps recommended by the Department of Transportation, will result in substantial queuing on both Missouri Avenue and Bundy Drive for access as well as Armacost Avenue and La Grange Avenue for egress. Such queuing is not prohibited by the Supplemental Assessment's recommendations in the TMMP which will result in substantial increased congestion on contiguous streets at critical times of day. Further, based upon the number of students gaining access by carpool to the site daily -only approximately 360 - given the trip caps recommended by LADOT, there is no valid explanation by Applicant as to how the remaining approximately 500 students will gain daily access to the site.

At its meeting held December 14, 2011, after two public hearings, the West Los Angeles Neighborhood Council voted unanimously to disapprove Applicant's request for a conditional use permit for the subject site. The reasons stated for the Council's decision stated at its hearings consisted in the main of recognition of the undue traffic, pedestrian and related burdens and intrusions into the surrounding residential neighborhood resulting from the Applicant's proposal. Council members reasoned simply that a use consisting of access by approximately 1,000 persons daily was excessive for the site involved and that proposed mitigating conditions would be ineffective and unenforceable.

Councilman Bill Rosendahl, Councilman for the 11th District in which. the site is located, has publicly and on the record at a hearing of the West Los Angeles Neighborhood Council held December 14, 2001 expressed his own opposition to the proposed project indicating that when first presented to him he understood the project to consist only of Applicant's request to move its present 340 student middle school to the subject site. Having now learned that the proposal consists of expanding the present middle school to include high school with a total combined enrollment of 875, the Councilman states his objection to the size of the student body for the proposed site. Further the Councilman states his observation that the subject facility is inappropriate for a middle and high school given that lack of proper facilities including any outdoor facilities whatsoever.

1. Facial Defects in the Letter of Determination.

The LADOT Letter of Determination was, of course, disappointing to the many residents in the neighborhood surrounding the proposed school site who will suffer increased traffic and parking intrusion as a result of LADOT's conditional approval of the subject middle and high school site. It is puzzling, for example, that a City department that deals in large outputs of statistics and numerical analyses would respond to the Prior Appeal without citing any numbers (except for references to the numbers of parking spaces). The Prior Appeal, and particularly Arthur L. Kassan, P.E.'s letter of December

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5, 2011 attached thereto as Exhibit A, was replete with numerical references and calculations, for example, to the trip caps during the peak periods, the numbers of students per vehicle (Average Vehicle Ridership) necessary for the trip caps to work, and the walking distances in feet to the nearest transit stops. Yet the Letter of Determination failed to respond to or attempt to refute a single one of those numerical citations. There appears to be no explanation for LADOTs disturbing reluctance to deal in quantitative analysis in this particular case.

However, disappointment and puzzlement were not the sole reactions to the Letter of Determination. Indeed, based upon the substance of same, it appears to be an almost inescapable conclusion that the General Manager was not furnished a copy of Mr. Kassan's traffic consulting report by staff or that the General Manager chose to ignore the substance of same if he indeed considered it prior to signing the Letter of Determination.

The Letter of Determination, at p. 1, states the following:

"The trip caps inherent in the proposed Traffic Management and Monitoring Program (TMMP) would necessitate vehicle occupancies that are well beyond reasonable expectations for the passenger capacities of the vehicles that will drop-off and pickup students when the school is at full enrollment (875 students) which would then cause off-site neighborhood pick-ups and drop-offs of students.

"As indicated in the Department's traffic assessment report, dated November 30, 2011, in order to mitigate the projected traffic impacts to a less-than-significant level and to minimize the likelihood of school traffic queue protruding onto the public right-of-way, the project is required to implement an aggressive TMMP. The consultant's study indicated that TMMP can be achieved through use of carpool, public transit. and non-vehicular modes (bicycling, walking, etc). Mr. Kassan's evaluation of our traffic assessment report did not factor all of these conditions. If the school is unable to achieve this goal within the allowed trip cap monitoring periods, school is then required to reduce enrollment until compliance is achieved. In addition, per Los Angeles City Planning Commission (LACPC)'s Conditions of Approval, dated December 29, 2011, all vehicles transporting students to and from the school shall load and unload on the surface parking lot at the site." (Emphasis added.)

That statement is completely untrue. Mr. Kassan's letter, on page 2, sets forth the following paragraph:

"Even if one-third of the students walk, bike, or use public transit, the AVRs would be 5.1 high school students in the morning peak hour, 6.6

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middle school students in the morning peak hour, and 9.3 combined school students in the afternoon peak hour. Those averages, even after reductions by one-third, are still well beyond the capacities of the parents' vehicles."

Contrary to the statement in the Letter of Determination, Mr. Kassan made a very conservative consideration of walking, biking, or using public transit to and from the school. LADOT cannot point to a charter school that has a higher rate of those alternative modes of transportation than the one-third of all students that Mr. Kassan assumes for analysis purposes in the above paragraph. As a charter school, most of the students will live at substantial distances from the proposed site according to Applicant's own statistics. It will not be safe, convenient, or attractive for many students to walk or bike to the school. The inconvenience of using transit is discussed below. Of course, carpooling was included in the evaluation; it is carpool rates- AVRs- that Mr. Kassan has calculated based on his conservative assumptions. Even with these assumptions, there is no realistic way to force parents to make their children bike, bus or walk rather than carpool. Neither Applicant, nor LADOT has ever discussed the implementation of a plan to choose which of Applicant's families would be allowed the privilege, safety and convenience of carpooling and which would be excluded. It defies reality to assume that all of Applicant's excluded families would willingly find an alternative to carpooling other than dropping off or picking up their child in the neighborhood in some manner.

Given that the existing charter school is located approximately a mile from the proposed new site, it is impossible to understand why a representative of LADOT failed to visit the school and do the necessary traffic engineering studies to determine the existing rates of walking, biking, and transit used by the current charter school students. That determination would have provided the information necessary upon which to base an accurate assessment and a valid, realistic projection of drop-off, pick-up and resulting traffic conditions.

Further, Mr. Kassan's report, at pp. 3-4, stated the following:

"4. The notion that a significant number of students will be public transit riders is unrealistic.

"The applicant's consultant states, 'New West strongly encourages its students to utilize public transportation, and many students enrolled at their current location on Pico Boulevard already do.' [Lawson report, page 5] Note that there is no quantitative information on the number or percentage of students who use public transportation at the current location. Therefore, we can make no inferences about the future transit use by students at the proposed new school site. Also, Pico Boulevard is a major east-west artery with both MT A and Santa Monica bus lines serving the vicinity of the current school location.

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"Transit service is not as convenient and attractive in the vicinity of the proposed new school site. The land use consultant's report includes the locations of four transit stops that are claimed to be welllocated for students walking to and from the new school site. [Lawson report, page 6]

• There is a bus stop at Olympic Boulevard and Bundy Drive. However, that stop is approximately 1 ,850 feet from the proposed school site, well beyond the limit of one-quarter of a mile (1 ,320 feet) that is used as a criterion for evaluating the convenience and attraction of a bus stop location. The criterion walking distance to and from that stop is exceeded by 40%.

• A stop, serving one bus line, is mentioned for the intersection of Santa Monica Boulevard and Bundy Drive. That stop is approximately 3,000 feet from the school site, well over half a mile away.

• One line is described as serving a stop at Pico Boulevard and Bundy Drive. That stop is approximately 3,300 feet from the school, almost two-thirds of a mile away.

• Lastly, the report mentions the future Exposition MetroRail Line station that is proposed for south of the Olympic Boulevard/Bundy Drive intersection. The rail line is estimated to be in operation by the year 2015, but judging from the delays that have been encountered in constructing the first phase of that line, the estimate seems overly optimistic. When completed, the rail station will be approximately 2,300 feet from the school site, almost 75% in excess of the criterion for convenient and attractive walking distance.

"Considering the distances that students would have to walk, the densities of the business areas between the stops and the school, and the volumes of traffic that use the streets between the stops and the school, it is not likely that students and parents will find the transit service for the new school site to be convenient, attractive, or pedestrian-safe."

Based upon the quoted language above from Mr. Kassan's report, it is plain that his report "factored" the very conditions which the Letter of Determination incorrectly denies were included in his report.

Further, regarding the possibility of students riding their bikes to the school site, it must be remembered that only five students out of the entire present student body live in the immediate neighborhood. All others live distances up to many miles away making reliance upon bicycling or walking no solution at all, especially in inclement weather. Indeed, the school has stated that it plans to maintain only 60 bike racks for those

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students who may desire to ride their bikes to the site, a clear admission of the low number of students projected to ride their bikes to the site.

On page 1, of the Letter of Determination, it is stated, " ... all vehicles transporting students to and from the school shall load and unload on the surface parking lot at the school." That severe restriction cannot be monitored and enforced on a continuous basis, that is, on every school day. Certainly LADOT personnel cannot do that. The school cannot afford to station staff on the surrounding neighborhood streets, and would not be unbiased. Residential neighbors cannot have on-going patrols to assure compliance with that restriction. That certainly would not be a fair or appropriate burden. Therefore, neither the school nor the City can guaranty compliance with that significant condition.

On page 2 of the Letter of Determination, it is stated, " ... students are prohibited from driving to the school and from parking at school's site or on residential streets." Again, that condition cannot be monitored and enforced on a continuous, daily basis. It is certainly not the neighborhood's responsibility. Predictably, high school students licensed to drive will find ways to skirt that restriction, and neither the school nor the City can guaranty compliance on every school day throughout the year.

Also on page 2, the Letter of Determination refers to trip cap monitoring" ... twice per year (November and April)". However, allowing a full year to correct a deficiency in the TMMP is not logical or reasonable given the school's resources and the school administration's claimed special control over parental and student behavior. Nor is it acceptable for a deficiency to be allowed to continue for the 39 or so weeks of an entire school year, causing an undue burden and a substantial negative impact on the adjacent neighborhood. At a minimum, any deficiencies should be perfectly corrected within thirty to sixty days to avoid a substantial enrollment reduction penalty.

By inference, the objective of the LADOT Supplemental Assessment was to reduce 2,170 daily trips to 367 to accomplish ingress and egress for 875 students. Based upon the number of students who could gain access by means of the proposed trip capped carpooling, 367, and accounting for another 60, assuming that many students actually ride their bikes to the site, that would leave approximately 450 students with no means to get to school other than by public transit. Based on Mr. Kassan's insightful comments quoted above, it is simply absurd to conclude that 450 students will ride the public bus to the site daily. Nevertheless, that is precisely the conclusion the Letter of Determination and the Supplemental Assessment reach if one analyzes the numbers with care.

These TMMP conditions are difficult to monitor and impossible to enforce, unfairly placing the burden of impact and management on the neighboring residents. Increases in auto and pedestrian traffic will have negative consequences on travel times and parking access for local residents and have a cumulative negative impact on existing commuters who already suffer with dense traffic and gridlock every weekday.

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2. Traffic flow and queuing problems.

LADOT's recommended TMMP, including trip caps, queuing capacity, on-site parking availability, monitoring and enforcement, is woefully insufficient to protect the surrounding residential neighborhood from highly significant intrusion of traffic and offsite parking at times and places at and during which traffic flow and parking are already burdened to the extent that circulation throughout the surrounding neighborhood during peak hours is presently severely impeded and will be substantially worsened by virtue of the proposed project as conditionally approved.

a. Based upon Mr. Kassan's report, the following conclusions may be drawn:

i. The trip caps inherent in the proposed TMMP result in the proposed ingress and egress of 875 students daily being a mathematical and physical impossibility.

ii. The TMMP will not effectively avoid off-site neighborhood pick-ups and drop-offs of students.

iii. Significant unaddressed neighborhood parking problems will result from the proposed TMMP.

iv. Actual use by students of public transit to the extent imagined by the Assessment is unrealistic.

v. The duration of the proposed trip cap monitoring program is too short and should be more intensive.

vi. A one year period to cure deficiencies in the proposed TMMP is far too long and renders it ineffective to accomplish its purpose.

b. In addition to the above issues and deficiencies in the TMMP proposed in the Assessment discussed by Mr. Kassan, and based on experience with other similar uses in the immediate neighborhood, the following additional negative impacts to the neighborhood, which already experiences major traffic congestion and gridlock at peak hours, will occur as a result of the predictable additional traffic flow and parking inadequacy during peak and other hours inherent in the proposed TMMP:

i. Unacceptable levels of queuing and traffic obstruction on Armacost, Missouri and La Grange Avenues.

Illegal stoppage of traffic northbound on Bundy Drive south of Missouri Avenue awaiting a right turn onto Missouri Avenue.

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Blockage of traffic on Bundy Drive southbound at Missouri Avenue awaiting a left turn onto Missouri Avenue in a very short left turn lane (3 vehicle capacity) located there.

The existing neighborhood is already plagued by "cut-through" traffic resulting mostly from round trips (estimated 300,000 ADT) between the City of Santa Monica and external origins. Addition of school-generated traffic will simply exacerbate vehicular traffic and noise. With respect to vehicle-generated noise, current street widths do not appear to be sufficiently wide to implement the construction of noise barriers or landscaping. Nor do the narrow widths of local streets permit the addition of lanes for vehicles or bicycles.

Close analysis of the capacity and flow capability of the presently proposed "reverse flow" two-lane on-site queuing emanating from a one lane ingress from Missouri Avenue on the north and egressing into Armacost Avenue via a one lane alley driveway on the south side of the site reveals that considerable off-site queuing will of necessity result during drop-off and pick-up times. Applicant's representatives have stated that 75% of the incoming traffic will come from the south of the site utilizing Bundy Drive and the remainder from the north also utilizing Bundy Drive. That being the case, according to the TMMP recommended in the Supplemental Assessment, in the morning peak time 90 vehicles will approach the Site from the south via Bundy Drive and 30 from the north. According to the present proposal, only right turns will be allowed into the site from Missouri Avenue eastbound for access to the on-site drop-off queuing lanes.

Assuming approximately 20 vehicles queuing on-site and another 12 able to queue on Missouri Avenue eastbound east of Bundy Drive, that will leave approximately 58 vehicles awaiting access from the south. Bundy Drive northbound south of Missouri Avenue is a strict no stopping zone for the right lane. Therefore no queuing can occur on Bundy Drive northbound south of Missouri Avenue. This leaves no other location for the remaining 58 vehicles to queue in the morning coming from the south to gain access to Missouri Avenue eastbound and then into the site.

At the same time, that will leave approximately 30 vehicles awaiting access from the north. Given a 3 vehicle left turn access lane on Bundy Drive southbound at Missouri, and given a traffic signal at that location, the back-up in the left lane of Bundy Drive southbound north of Missouri Avenue will be very considerable at a time of day when traffic is heavy to begin with and access to the Missouri Avenue queue will be difficult, if not impossible for these vehicles.

Missouri Avenue between Bundy Drive and Armacost Avenue consists of one lane of traffic in each direction and allows parking on the south side only. When a queuing line is added, eastbound on the south side, Missouri Avenue will be utterly impassable for eastbound through-traffic during peak hours. This presents both an unacceptable local traffic obstruction as well as a significant safety hazard should emergency vehicles require access to the neighborhood eastbound on Missouri Avenue.

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The realistically predictable result of this impeded traffic and circulation flow will be that parents will avoid the "reverse flow" plan altogether and simply adopt the strategy of dropping off elsewhere in the nearby neighborhood allowing their students to walk the remainder of the way to the site. Alternatively, high school students of driving age will predictably avail themselves of the simple expedient of driving to school, parking nearby in the surrounding neighborhood and walking into the site. Applicant has neither proposed nor offered any manner or means of monitoring or policing such violations of the proposed TMMP carpooling requirement.

ii. Increased use of neighborhood streets for off-site parking due to reduction in on-site parking from 55 to 37 per proposed plan.

The present, revised "reverse flow plan" indicates that on-site parking will be reduced to approximately 37 vehicles for teachers, administrative staff, vendors and visitors. For a proposed student body of 875 with at least 28 classrooms plus administrative staff in a 50,000 square foot structure, 37 parking places is simply too few to even consider seriously. Visitors, vendors, late coming students and others will have no choice but to park in the already over burdened local neighborhood which has suffered for years under the yoke of the nearby Bally Fitness Center's excess parking in the mornings and evenings.

The applicable parking code would appear to require one space per 500 square feet of structure in the "catch-all" commercial category since there is no specific category for middle or high schools except those with auditoriums.1 If that is the case, approximately 100 parking spaces would be required leaving Applicant short approximately 63 spaces under the current proposal. Notwithstanding hopes and prayers to the contrary, no agreement, license or covenant for extra parking is in place at this time or likely to be so.

iii. Inundation of the surrounding neighborhood by hundreds of additional parked vehicles on event nights during the school year of which the Applicant has stated there will be at least four.

Applicant states that it intends to have at least four events per school year at the site in the nature of parents' back-to-school nights, etc. These events would, given a student body of 875 as intended, necessitate several hundred parking spaces. Applicant has put forth no proposal for accommodating such a large number of vehicles in the evening hours when local residents are returning home from work expecting to utilize their own adjacent street parking.

No such events should be permitted at the Site unless and until adequate offstreet parking is provided in demonstrable fashion.

1 L.A. Zoning I Parking Code, Summary of Parking Regulations, rev. 1-9-07, §12.21A4, subsection 16.

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iv. Unaddressed after-school traffic and parking issues due to transportation needs associated with after-school activities at the site and the local park.

Applicant has mentioned but underplayed the existence of after-school activities at the site. No proposal has been put forward covering the parking or traffic flow needs associated with such activities. Given that the afternoon pick up vehicular trip cap in the Assessment is 126 which translates into 63 vehicles with a proposed student occupancy rate of 3, that only accounts for 189 students in the afternoon. When and how the remaining 686 students leave the Site is dealt with nowhere in the CPC Determination.

v. Miscellaneous traffic issues unresolved.

The following issues remain unresolved:

A. Danger to pedestrians from increased traffic flow

Local residents are used to utilizing the side streets adjacent to the site for exercise, dog walking and other typical activities carried on in a quiet residential neighborhood. Nowhere does the proposed plan take into consideration the danger and threats of harm presented by the additional traffic flow resulting from the proposed use. Elderly Japanese-American founding residents of the surrounding neighborhood are particularly potentially affected by this specific unmitigated condition given their constant, habitual use of the sidewalks and intersections on foot.

B. No off-site policing or monitoring proposed

Nowhere does the proposed plan call for any off-site policing or monitoring of traffic flow, parking or any other aspect of the intrusion into the local residential neighborhood. With the introduction of 875 teenagers into the local community pursuant to a plan proposing no off-site control, such a plan is facially unacceptable and in violation of all four of the basic findings required in order to approve a conditional use permit set forth above.

C. Unrealistic reliance on bicycling and public transit

The attached Traffic Consultant's report speaks of unrealistic expectations concerning utilization by students of public transportation. In addition, the Applicant has represented that it intends to have on site 60 bicycle racks. An examination of the location of students' homes who attend the subject school, and the distances involved between homes and the site, leads to the inexorable conclusion that not many students will resort to bicycling to the site, especially in foul weather. Further, even if 60 students ride their bikes to the site daily, given the low number of students who will gain access to the site by means of the capped daily vehicle trips, there are still hundreds of students whose means of access to the site is unaccounted for by Applicant and by the CPC Determination.

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D. Likelihood of student drivers and other TMMP violations

Not entirely unlike the resistance to public transportation and bicycles discussed above, it is entirely foreseeable that driving age teenagers will not be able to resist the temptation to drive to the neighborhood surrounding the site, park and simply walk to the site if they are among the hundreds who have no other means of getting to school. Nowhere do the Letter of Determination or the Supplemental Assessment deal with this inescapable reality of human nature. Nor do those documents deal with the likelihood that frustrated parents -who may have more than one child in different schools, who have to pick up several children in a carpool, who then have to wait in a carpool cue to enter the drop off area, drop children off, then continue to wait to funnel into an alley way and then cue out again on Bundy all the time worried about arriving to work on time -will simply resort to driving into the surrounding neighborhood dropping their students off to walk the remainder of the way to the site. Again, in inclement weather both of these means of accessing the site will simply be irresistible. Yet nothing in the plan for the site deals with these matters in a practical, effective manner.

E. No busing required

The Letter of Determination and the Supplemental Assessment fail to speak to the possibility of busing as a means of students gaining access to the site. Applicant has stated repeatedly that it simply cannot afford to provide private busing. Yet both Applicant and the LADOT are perfectly willing to saddle local residents with the costs associated with the lack of busing and the ineffective TMMP proposed.

F. Enforcement issues

When asked how the traffic control and carpooling measures recommended are to be enforced, representatives of Applicant have uniformly pointed to the Home-School Contract presently employed by Applicant with the assurance that Applicant will thus enforce the carpooling and other requirements recommended. Yet when pressed for specifics as to the methods to be employed in order to enforce the Home-School Contract, i.e., expulsion, reduction in enrollment, monetary fines, etc., Applicant has uniformly failed to describe exactly how such enforcement will in fact be accomplished. Applicant has never offered an explanation of how families will be chosen to participate in the carpooling process. Further, Applicant has at no time offered any explanation or solution to the problem presented by hundreds of students wishing to access the site by vehicle or otherwise who have not been selected to participate in the trip cap limited carpooling process, however that selection will occur.

i. Ineffectiveness. unenforceability and illegality of Home-School Contract

As stated by the LAUSD in denying Applicant's application to renew its charter in early 2011, requiring parents to agree and sign the Home-School Contract contravenes

-14-

California Education Code §47605(d)(2)(A) which requires a charter school to admit all pupils who wish to attend the school. The mere implementation of a lottery system of selecting those potential students who will gain acceptance to Applicant's school does not vitiate the effect of the provisions of the Education Code thus giving the HomeSchool Contract enforceability where none exists. Applicant's constantly repeated reliance upon enforcement of its Home-School Contract as the purported means of imposing carpooling and related traffic and parking control measures is simply without merit whatsoever.

Notwithstanding the ineffectiveness of the recommended TMMP, the Letter of Determination has in error approved Applicant's request for a conditional use permit which relies seminally upon the terms of the TMMP.

3. Parking

a. Daily Parking

The site presently has approximately 55 individual parking spaces on the western side of the structure, approximately 18 abutting the structure including two handicapped spaces and approximately 38 abutting the fence which runs along the western boundary of the site. These existing spaces are proposed to satisfy the parking needs of some 38 teachers plus administrative staff, vendors and other visitors daily. In accordance with the L.A. Zoning I Parking Code, Summary of Parking Regulations, rev. 1-9-07, §12.21A4, there is no specific parking allocation or requirement for middle or high schools except with respect to schools whose campuses include an auditorium. Therefore catch-all sub-section 16 governs the proposed use of the site and provides that a ratio of 1 parking space per 500 square feet of the building on the site would be required. Given a structure on the site of approximately 50,000 square feet, the proposed use would require approximately 100 parking spaces resulting in a shortage at the site of approximately 45 spaces minimum.

Applicant has proposed that the parking spaces abutting the fence on the western boundary of the site be eliminated for some part or all of the day each day due to the need to utilize this area for ingress and egress during pick-up and drop-off times. No arrangements for replacement of those parking spaces have been proposed by Applicant other than hopeful speculation concerning the possibility of commercial neighbors entering into some kind of unspecified arrangements with Applicant, none of which presently exist or are likely notwithstanding that Applicant has had many months to seek and put such arrangements into place.

Plainly 55 spaces, let alone 37 or 18 spaces, are too few to service a student body of 875 plus faculty, staff, vendors and other visitors. To conclude otherwise is simply to subject the surrounding neighborhood to an unwelcome invasion of vehicles seeking parking otherwise unavailable on site.

-15-

b. Special events parking

Applicant has stated that several special events will be held each year including parents back to school nights, etc. At no time has Applicant presented any plan whatsoever .for parking arrangements to accommodate such special events which would likely draw literally hundreds of vehicles. To the extent that such special events would occur in the early evenings, they would result in intrusion into the surrounding neighborhood of a potentially enormous number of vehicles taking up parking normally utilized by the surrounding residential neighbors upon returning home from work, etc.

Given that Applicant has utterly failed to provide for appropriate daily parking as well as special event parking, approval of Applicant's request for a conditional use permit cannot possibly satisfy the requirement that the proposed location not be materially detrimental to the character of development in the immediate neighborhood.

CONCLUSION

The site as proposed would operate amidst a local neighborhood which is already experiencing extremely high volumes of traffic which is often impeded and obstructed during peak hours daily. This existing uncomfortable situation may well be exacerbated in the future depending on proposed development of nearby sites including large areas west of Bundy Drive (formerly referred to as Bundy Village) as well as the now vacant parcel at the southeast corner of Bundy Drive and Missouri Avenue formerly occupied by the City Animal Shelter.

Based upon the foregoing matters, it is respectfully requested that the City Council reconsider the Letter of Determination and either:

(a) conclude that the proposed site is simply inappropriate and inadequate for the intensity of the proposed use by 1000 persons daily based on the insurmountable, unmitigated traffic and parking impacts or, alternatively,

(b) impose stringent conditions which are properly designed to avoid with certainty significant intrusion of traffic and parking into the surrounding residential neighborhood and which are manifestly enforceable including independent real time monitoring and appropriate consequences for violation including, without limitation, prompt and explicit substantial enrollment reduction and monetary penalties designed to benefit the neighborhood.

Dated: February 14, 2012

-16-

EXHIBIT A

Jaime de Ia Vega GENERAL MANAGER

January 13, 2012

Timothy G. Dallinger 11880 Nebraska Avenue Los Angeles, CA 90025

CITY OF LOS ANGELES CALIFORNIA

ANTONIO R. VILLARAIGOSA MAYOR

DEPARTMENT OF TRANSPORTATION 100 S. Main St., lOth Floor Los Angeles, CA 90012

(213}972-8470 FAX (213) 972-8410

AF:PEAL OF THE SUPPLEMENTAL TRAFFIC ASSESSMENT REPORT FOR THE PROPOSED CHARTER SCHOOL PROJECT AT 1905 ARMACOST AVENUE, DEPARTMENT OF TRANSPORTATION CASE NO. WLA11·040, AND CITY PLANNING COMMISSION CASE NO. CPC-2011-1923-CU-SPR

Dear Mr. Dallinger:

After a careful review of your appeal, dated December 15, 2011 (and required appeal fee received on December 15, 2011), and under the provisions of the West Los Angeles·

. Transportation Improvement and Mitigation Specific Plan (WLATIMSP), Ordinance No 171,492, in which you expressed concern that the project's "Reverse Flow Access" alternative would create a significant intrusion of traffic and off-site parking within the surrounding residential neighborhood, the Los Angeles Department of Transportation (LADOT) has made the following determination:

REVIEW OF CONCERNS

The trip caps inherent in the proposed Traffic Management and Monitoring Program (TMMP) would necessitate vehicle occupancies that are well beyond reasonable expectations for the passenger capacities of the vehicles that will drop-off and pickup students when the school is at full enrollment (875 students) which would then cause off-site neighborhood pick-ups and drop-offs of students.

As indicated in the Department's traffic assessment report, dated November 30, 2011, in order to mitigate the projected traffic impacts to a less-than-significant level and to minimize the likelihood of school traffic queue protruding onto the public right-of-Way, the project is required to implement an aggressive TMMP. The cons4ltant's study indicated that TMMP can be achieved through use of carpool, public transit, and non-vehicular modes (bicycling, walking, etc). Mr. Kassan's evaluation of our traffic assessment report did not factor all of these conditions. If the school is unable to achieve this goal within the allowed trip cap monitoring periods, school is then required to reduce ·enrollment until compliance is achieved. In addition, per Los Angeles City Planning Commission (LACPC)'s Conditions of Approval, dated December 29, 2011, all vehicles transporting students to and from the school shall load and unload on the surface parking lot at the site.

AN EQUAL EMPLOYMENT OPPORTUNITY- AFFIRMATIVE ACTION EMPLOYER

Timothy G. Dallinger 2 January 13, 2012

Prohibiting student drivers to enter school site and park on-campus could result in

significant parking problems within the adjacent residential neighborhood.

Per LACPC's Conditions of Approval for Parking, students are prohibited from driving to

the school and from parking at school's site or on residential streets.

The duration of trip cap monitoring program is too short to be of substantial value in

protecting the neighborhood. Allowing the school a period of one year to correct

deficiencies in the TMMP's trip cap monitoring program will reduce the mitigation

effectiveness to negligible levels.

DOT does not agree that the trip cap monitoring program period is too short. Per LACPC's

Condition of Approval for the project, TMMP's trip cap review period shall be for a minimum

of five (years), twice per year (November and April), at which time the review must show

accomplishment of the trip goal reduction for this entire 5-year period. Should the review

show that the trip cap goal was not achieved, the school will have one (1) year to correct

the deficiency. If the school cannot achieve the trip cap goal within the corrective year, the

school will be required to reduce enrollment in an amount commensurate with the trip cap

and a new five (5) year review period will commence with the following school year.

School is scheduled to be at full enrollment (875 students) in Fall of 2015. This would still

allow two years of monitoring or 4 TMMP reporting. In addition, one (1) year to correct the

trip cap deficiency is a typical time allowed by DOT for similar school-related projects.

There will be unacceptable levels of queuing and traffic obstruction on Armacost,

Missouri, and La Grange Avenues during the drop-off and pick-up periods. Also,

queuing of school traffic would result in gridlock at the intersection of Bundy Drive

and Missouri Avenue.

Per traffic consultant's study for the "Reverse Flow Access" alternative, there would be two

(2) lanes of queuing on-site with six (6) drop-off/pick-up spaces (three per lane). DOT

evaluated and agreed with the consultant's analysis that on-site queuing will be sufficient

under these conditions during the anticipated peak vehicular arrival rates with no

significant queuing onto the public right-of-way. This is not to say that there would not be

any traffic congestion at or around the school's property during the students' loading and

unloading periods. However, it is DOT's opinion that the traffic congestion during these

periods would not be significant to create a gridlock at the intersection of Bundy Drive and

Missouri Avenue, as suggested.

Reduction of on-site parking from 55 spaces to 37 spaces would result in increased

use of adjacent neighborhood streets.

It should be noted that 55 on-site parking spaces are still retained. However, during the

drop-off and pick-up periods, only 37 on-site parking spaces would be available which is

sufficient to allow parking for the faculty and staff. It should also be noted that under the

"Reverse Flow Access" scenario, on-street parking is allowed on Missouri Avenue and on

Armacost Avenue adjacent to school frontages.


Timothy G. Dallinger 3 January 13, 2012

Night events or other activities during the school year would inundate the

surrounding neighborhood by hundreds of additional parked vehicles. After-school

traffic and parking related issues associated with the after-school activities are not

addressed.

Per LACPC's Conditions of Approval for Events, events and activities involving parents

and/or other visitors where more than 55 vehicles are anticipated at one time are

prohibited from parking at the site and shall be arranged to occur at an off-site location

where the vehicles can be properly accommodated. In addition, activities outside normal

school hours, including open house, parent-teacher conferences, school meetings, and

other customary school activities shall be scheduled so as to adequately provide parking

on-site for all staff and visitors. Arrangements shall be made to provide off-street parking

for events exceeding the parking capacity on-site.

CONCLUSION

Based on the various points discussed above, it is the opinion of LADOT that the traffic

assessment report, dated November 30, 2011, has properly evaluated the traffic impacts

for the project and has properly asserted conditions to mitigate significantly impacted

intersections.

In accordance with Section 8.C of the WLATIMSP, an applicant or any other person

dissatisfied with this determination may appeal to the City Council. However, please note

that the deadline for filing an appeal to the City Council is 15 days following the date of

mailing of the letter of determination by LADOT. For a full description of this process,

please refer to Section 8 of the WLATIMSP. Electronic access to this document is

available at: http://citvplanning.lacitv.org/complan/specplan/pdf/WLATIMP.PDF

If further assistance is needed in regard to this determination, please contact Mo

Blorfroshan at LADOTs West Los Angeles, Coastal & San Pedro Development Review

Office at (213) 485-1062.

Sincerely,

JTV:MHV

cc: Honorable Bill Rosendahl, Councilmember, District 11

Carmen A. Trutanich, City Attorney James K. Williams, City Planning Commission Michael LeGrande, City Planning Jay Kim, Sean Haeri, Mo Blorfroshan, DOT


EXHIBIT B

TIMOTHY G. DALLINGER

Phone: (SIB) 9S6-2311 Fax: (SIB) 9S6-6654

Fax to e-mail: (775) 256-S679 e-mail: [email protected]

11880 NEBRASKA AVENUE Los ANGELES, CALIFORNIA 90025

BY HAND DELIVERY

December 15, 2011

Mr. Jaime de Ia Vega General Manager CITY OF LOS ANGELES DEPARTMENT OF TRANSPORTATION 1 00 South Main Street, 1oth Floor Los Angeles, CA 90012

Re: APPEAL FROM SUPPLEMENTAL TRAFFIC ASSESSMENT DEPARTMENT OF TRANSPORTATION CASE NO. WLA11-040 DEPARTMENT OF CITY PLANNING CASE NO. ENV-2011-1924-MND 1905-1915 ARMACOST AVENUE, LOS ANGELES, CA 90025

Dear Mr. de Ia Vega:

In my capacities as a neighbor residing exactly one block north of the subject site and as a member of the unofficial Stoner Park Community Advocates consisting of many other neighbors residing within the vicinity of the proposed site, I hereby appeal from the Supplemental Traffic Assessment dated November 30, 2011 referenced above prepared by Mr. Mohammad H. Blorfroshan of your staff ("the Assessment").

The Assessment results in conditional approval of the subject project submitted by New West Charter School ("Applicant") consisting of a proposed middle and high school with a target combined enrollment of 875 students to occupy a building consisting of approximately 50,000 square feet located at the southwest corner of Armacost Avenue and Missouri Avenue in West Los Angeles ("the Site") directly across the street and cattycorner from long standing residential uses. The Assessment approves the Site for the proposed use as a school based upon a recommended Traffic Management and Monitoring Program ("TMMP") to

Mr. Jaime de Ia Vega General Manager CITY OF LOS ANGELES DEPARTMENT OF TRANSPORTATION Re: APPEAL FROM SUPPLEMENTAL TRAFFIC ASSESSMENT

DEPARTMENT OF TRANSPORTATION CASE NO. WLA11-040 DEPARTMENT OF CITY PLANNING CASE NO. ENV-2011-1924-MND 1905-1915 ARMACOST AVENUE, LOS ANGELES, CA 90025

December 15, 2011 Page2

reduce 2,170 daily trips to 367 to accomplish ingress and egress for 875 students as well as certain other recommended off-Site infrastructure and on-Site improvements subject to further engineering review and feasibility study.

I. THE ASSESSMENT'S RECOMMENDED TMMP IS

INSUFFICIENT TO PROTECT THE SURROUNDING RESIDENTIAL NEIGHBORHOOD FROM HIGHLY SIGNIFICANT

INTRUSION OF TRAFFIC AND OFF-SITE PARKING

The gravamen of this Appeal is that the Assessment's recommended TMMP, including trip caps, queuing capacity, on-site parking availability, monitoring and enforcement, is woefully insufficient to protect the surrounding residential neighborhood from highly significant intrusion of traffic and off-site parking at times and places at and during which traffic flow and parking are already burdened to the extent that circulation throughout the surrounding neighborhood is presently severely diminished and will be substantially worsened by virtue of the proposed project as conditionally approved.

A. Consulting Traffic Engineer's Report.

Submitted herewith as Exhibit A is a letter dated December 5, 2011 addressed to the Los Angeles City Planning Commission prepared by Arthur L. Kassan, P.E., Consulting Traffic Engineer. You will see that Mr. Kassan has evaluated with care the Assessment and has commented on its contents extensively. All of Mr. Kassan's analysis and comments are hereby adopted and made a part of this Appeal. 1

1 It should be noted that the Applicant's own traffic consultant's underlying data have been wrongfully withheld from those opposing the Assessment and their consultants as "not for public distribution." It is difficult to imagine a more "public" document under the circumstances.



December 15, 2011 Page 3

There is no need to reiterate the substance of Mr. Kassan's study here. However, for purposes of identifying the issues which formulate the basis for this Appeal, it may be summarized as follows:

1. The trip caps inherent in the proposed TMMP result in the proposed ingress and egress of 875 students daily being a mathematical and physical impossibility.

2. The TMMP will not effectively avoid off-Site neighborhood pickups and drop-offs of students.

3. Significant unaddressed neighborhood parking problems will result from the proposed TMMP.

4. Actual use by students of public transit to the extent imagined by the Assessment is unrealistic.

5. The duration of the trip cap monitoring program is too short and should be more intensive.

6. A one year period to cure deficiencies in the proposed TMMP is far too long and renders it ineffective to accomplish its purpose.

B. Additional Negative Impacts.

In addition to the above issues and deficiencies in the TMMP proposed in the Assessment discussed by Mr. Kassan, and based on experience with other similar schools in the immediate neighborhood, the following additional negative impacts to the neighborhood will occur as a result of the predictable additional traffic flow and parking inadequacy during peak and other hours inherent in the proposed TMMP:

1. Unacceptable levels of queuing and traffic obstruction on Armacost. Missouri and La Grange Avenues. Illegal stoppage



December 15, 2011 Page4

of traffic northbound on Bundy Drive south of Missouri Avenue awaiting a right turn onto Missouri Avenue. Blockage of traffic on Bundy Drive southbound at Missouri Avenue awaiting a left turn onto Missouri Avenue in a very short left turn lane (3 vehicle capacity) located there.

Close analysis of the capacity and flow capability of the presently proposed "reverse flow" two-lane on-Site queuing emanating from a one lane ingress from Missouri Avenue on the north and egressing into Armacost Avenue via a one lane alley driveway on the south side of the Site reveals that considerable off-Site queuing will of necessity result during drop-off and pick-up times. Applicant's representatives have stated that 75% of the incoming traffic will come from the south of the Site utilizing Bundy Drive and the remainder from the north also utilizing Bundy Drive. That being the case, according to the TMMP recommended in the Assessment, in the morning peak time 90 vehicles will approach the Site from the south via Bundy Drive and 30 from the north. According to the present proposal, only right turns will be allowed into the Site from Missouri Avenue eastbound for access to the on-Site drop-off queuing lanes.

Assuming approximately 20 vehicles queuing on-Site and another 12 able to queue on Missouri Avenue eastbound east of Bundy Drive, that will leave approximately 58 vehicles awaiting access from the south. Bundy Drive northbound south of Missouri Avenue is a strict no stopping zone for the right lane. Therefore no queuing can occur on Bundy Drive northbound south of Missouri Avenue. This leaves no other location for the remaining 58 vehicles to queue in the morning coming from the south to gain access to Missouri Avenue eastbound and then into the Site.

At the same time, that will leave approximately 30 vehicles awaiting access from the north. Given a 3 vehicle left turn access lane on Bundy Drive southbound at Missouri, and given a traffic signal at that location, the back-up in the left lane of Bundy Drive southbound north of Missouri Avenue will be very considerable at a time of day when traffic is heavy to begin with and access to the Missouri Avenue queue will be difficult, if not impossible for these vehicles.




Missouri Avenue between Bundy Drive and Armacost Avenue consists of one lane of traffic in each direction and allows parking on the south side only at this time. When a queuing line is added, eastbound on the south side, Missouri Avenue will be utterly impassable for eastbound through traffic during peak hours. This presents both an unacceptable local traffic obstruction as well as a significant safety hazard should emergency vehicles require access to the neighborhood eastbound on Missouri Avenue.

The obvious result of this impeded traffic and circulation flow will be that parents will avoid the "reverse flow" plan altogether and simply adopt the strategy of dropping off elsewhere in the nearby neighborhood allowing their students to walk the remainder of the way to the Site. Alternatively, high school students of driving age will predictably avail themselves of the simple expedient of driving to school, parking nearby in the surrounding neighborhood and walking into the Site.

2. Increased use of neighborhood streets for off-Site parking due to reduction in on-Site parking from 55 to 37 per proposed plan.

The present, revised flow plan indicates that on-Site parking will be reduced to approximately 37 vehicles for teachers, administrative staff, vendors and visitors. For a proposed student body of 875 with at least 28 classrooms plus administrative staff in a 50,000 square foot structure, 37 parking places is simply too few to even consider seriously. Visitors, vendors, late coming students and others will have no choice but to park in the already over burdened local neighborhood which has suffered for years under the yoke of Bally Fitness' excess parking in the mornings and evenings.

The applicable parking code would appear to require one space per 500 square feet of structure in the "catch-all" commercial category since there is no specific category for middle or high schools. 2 If that is the case, approximately 100 parking spaces would be required leaving Applicant short approximately 63

2 See LA Zoning I Parking Code, Summary of Parking Regulations, rev. 1-9-07, §12.21A4, subsection 16


DEPARTMENT OF TRANSPORTATION CASE NO. WLA11-040 DEPARTMENT OF CITY PLANNING CASE NO. ENV-2011-1924-MNO 1905-1915 ARMACOST AVENUE, LOS ANGELES, CA 90025


spaces under the current proposal. Notwithstanding hopes and prayers to the contrary, no agreement, license or covenant for extra parking is in place at this time or likely to be so. Further, were any such agreement, license or covenant to become available, it should be required by its terms to be co-terminus with Applicant's occupancy of the Site, however long that might be.

3. Inundation of the surrounding neighborhood by hundreds of additional parked vehicles on event nights during the school year of which the Applicant has stated there will be at least four..

Applicant states that it intends to have at least four events per school year at the Site in the nature of parents' back-to-school nights, etc. These events would, given a student body of 875 as intended, necessitate several hundred parking spaces. Applicant has put forth no proposal for accommodating such a large number of vehicles in the evening hours when local residents are returning home from work expecting to utilize their own adjacent street parking.

No such events should be permitted at the Site unless and until adequate off-street parking is provided in demonstrable fashion.

4. Unaddressed after-school traffic and parking issues due to transportation needs associated with after-school activities at the Site and the local park.

Applicant has mentioned but underplayed the existence of after-school activities at the Site. No proposal has been put forward covering the parking or traffic flow needs associated with such activities. Given that the afternoon pick up vehicular trip cap in the Assessment is 126 which translates into 63 vehicles with a proposed student occupancy rate of 3, that only accounts for 189 students in the afternoon. When and how do the remaining 686 students leave the Site? How many of those will be participants in after-school activities? How many trips and parking places will be required to accommodate these activities. No where does the Assessment deal with this issue. ·




CONCLUSION

The Site as proposed would operate amidst a local neighborhood which is already experiencing extremely high volumes of traffic which is often impeded and obstructed during peak hours daily. This existing uncomfortable situation may well be exacerbated in the future depending on proposed development of nearby sites including large areas west of Bundy Drive (formerly referred to as Bundy Village) as well as the now vacant parcel at the southeast corner of Bundy Drive and Missouri Avenue formerly occupied by the City Animal Shelter.

Based upon the foregoing matters, it is respectfully requested that the Department of Transportation reconsider its Assessment and publish a revised version which either:

(a) concludes that the Site is simply inappropriate and inadequate for the intensity of the proposed use by 1000 persons daily based on the insurmountable, unmitigated traffic and parking impacts or, alternatively,

(b) imposes stringent conditions which are properly designed to avoid with certainty significant intrusion of traffic and parking into the surrounding residential neighborhood and which are manifestly enforceable including independent real time monitoring and appropriate consequences for violation including, without limitation, prompt and explicit substantial enrollment reduction and monetary penalties designed to benefit the neighborhood.

Exhibits ( 1) cc: Councilman Bill Rosendahl

Len Nguyen - Councilman Rosendahl's Office




James K Williams - City Planning Commission - Executive Assistant Luciralia Ibarra- City Planning Associate Jay Handal- WLA Neighborhood Council Arthur L. Kassan, P.E.

Dotappeal121511d1.2

EXHIBIT A

ARTHUR L. KASSAN, P.E. Consulting Traffic Engineer

December 5, 2011

Honorable Members of the City Planning Commission Department of City Planning City of Los Angeles Room 721, City Hall 200 North Spring Street Los Angeles, CA 90012

Subject: New West Charter Schools Case No. ENV-2011-1924-MND

Dear Commissioners:

At the request of residents of the neighborhood adjacent to the proposed site of New West Charter Middle School and High School, I have reviewed traffic-related documents that have been prepared by the school's consultants and by the staff of the City Department of Transportation (LADOT). Specifically, the documents are: "Inter-Departmental Memorandum", dated November 30, 2011, from Mohammad H. Blorfroshan, LADOT, to Hadar Plafkin, Department of City Planning; and "Requests for Discretionary Approval, New West Charter Middle School, Inc., 1905 S. Armacost Avenue, Los Angeles, CA 90025", dated July 28, 2011, prepared by Craig Lawson & Co., LLC, land-use consultants to the school (Lawson report).

The finding of the applicant's traffic impact study, as reviewed by LADOT, was that the New West Charter Middle School and High School located at the subject site would result in significant traffic impacts at nine of the 14 intersections that were studied. That is almost two-thirds of the studied intersections. In addition, there would be significant impacts on one of the two residential street segments that were studied.

The mitigation that was proposed by the applicant and accepted by LADOT is to reduce the trip generation of the proposed schools by applying trip caps to the morning and afternoon peak-hour traffic entering and exiting the school site. The trip caps that were accepted by LADOT would result in reductions of approximately 65% in the high school trips during the morning peak hour, 75% reduction in the middle school trips in the morning peak hour, and 75% reduction in the combined schools trips in the afternoon peak hour. LADOT recommended a "Traffic Management and Monitoring Program" to be implemented by the school to evaluate the compliance with the trip reduction program. [LADOT report, page 4]

However, evaluation of the trip caps and the monitoring program leads to the conclusion that they will not be feasible when the school is at full enrollment (875 students) and that the mitigation measure will not be sufficient to overcome the significant impacts at the studied intersections and within the adjacent neighborhood.

Telephone (310) 558-0808

5105 Cimarron Lane Culver Ci1y, CA 90230

FAX (310) 558-1829

,,•-

Honorable Members of the City Planning Commission December 5, 2011

Page 2

1. The trip caps would necessitate vehicle occupancies that are well beyond

reasonable expectations for the passenger capacities of the vehicles that will drop-off and pick-up students.

For the high school, the morning peak-hour trip cap will be 151 trips to deliver 500

students and 19 faculty/staff members. Subtracting 19 trips for the faculty/staff members leaves 132 trips, total entering plus exiting, for the 500 students. As there

is no substantial reason for parents to remain at the school after dropping off their

students, it can be taken that half of the 132 trips -that is, 66 trips -will be entering

the campus and half will be exiting. If 500 students are dropped off by 66 parent vehicles, there will have to be an Average Vehicle Ridership (AVR) of 7.6 high

school students per vehicle.

For the middle school, the morning peak-hour trip cap will be 90 trips to deliver 375

students and 15 faculty/staff members. Subtracting the 15 trips for the faculty/staff

members, there will be 38 entering trips and 37 exiting trips for the parents dropping off middle school students. That is an A VR of 9.9 middle school students per

vehicle.

In the afternoon peak hour, the trip cap for the two schools combined will be 126

trips for 875 students. Assuming that all of the faculty and staff members leave after

the peak hour, all of the trips will be parents' vehicle. There will be 63 entering trips and 63 exiting trips for parents picking up their 875 children. That is an AVR of 13.9

students per vehicle.

Obviously, those AVRs are well beyond the capacities of typical privatelyowned parents' vehicles. Those levels will be infeasible without school buses to

reduce the numbers of students arriving and exiting by parents' vehicles. According

to the applicant's submittal documents, "There will be no buses." [Lawson report,

page 16]

Even if one-third of the students walk, bike, or use public transit, the AVRs would be

5.1 high school students in the morning peak hour, 6.6 middle school students in the

morning peak hour, and 9.3 combined school students in the afternoon peak hour. Those averages, even after reductions by one-third, are still well beyond the

capacities ofthe parents' vehicles.

2. Many parents, who are not able to meet the requirements of the mitigation

program, will drop-off and pick-up their students in either the residential neighborhood or the commercial/industrial area.

The mitigation plan calls for a "minimum vehicle-occupancy of 3 students per

vehicle for on-site student pick-up and drop-off activities". [LADOT memo, page

4] That means that parents who are able to transport only one or two students will not be permitted to enter the campus for drop-off and pick-up. The reasons that a parent will have fewer than three students in a vehicle may be because of the


Page 3

locations of student residences or because of parents' work schedules or because the students have after-school activities that do not involve other students {music lessons, medicaVdental appointments, etc.).

Parents who are transporting one or two students will simply drop them off or pick them up a short distance from the school - a half-block or whole block away - in the residential neighborhood that is immediately north of or east of the school or in the commercial/industrial area that surrounds the other sides of the campus. While those vehicles will not count against the trip caps for vehicles entering and exiting the school site, the vehicles will pass through several of the significantly impacted intersections to get to and from the school vicinity, and there will be no real reductions in school-related traffic through those intersections. The proposed mitigation measure will be substantially less effective than has been estimated.

3. Prohibiting student drivers to enter the school site and park on-campus could result in significant parking problems within the adjacent residential neighborhood.

The school has proposed that " ... high school students will be prohibited from driving to school ... " [Lawson report, page 4] The only way that the school can enforce the rule that a student cannot drive to school is by prohibiting access to the school grounds and the parking area.

However, a student could easily park one block (or less) from the school in the residential neighborhood north or east of the school and walk to and from the school. (That behavior has been observed at other schools that I have evaluated in the past.) The" ... strictly-enforced Home-School contract .. ." [Lawson report, page 4] will not be enforceable for this issue unless the school implements continuous mobile patrols of the neighborhood streets during the peak hours.

The potential for a parking impact in the neighborhood is realistic and may be significant. It may become necessary to implement permit parking restrictions, which would be detrimental to the neighborhood. The off-campus parking issue should be analyzed realistically considering the shortcomings of a school-operated parking enforcement program.

4. The notion that a significant number of students will be public transit riders is unrealistic.

The applicant's consultant states, "New West strongly encourages its students to utilize public transportation, and many students enrolled at their current location on Pico Boulevard already do." [Lawson report, page 5] Note that there is no quantitative information on the number or percentage of students who use public transportation at the current location. Therefore, we can make no inferences about the future transit use by students at the proposed new school site.


Page4

Also, Pico Boulevard is a major east-west artery with both MTA and Santa Monica bus lines serving the vicinity of the current school location.

Transit service is not as convenient and attractive in the vicinity of the proposed new school site. The land use consultant's report includes the locations of four transit stops that are claimed to be well-located for students walking to and from the new school site. [Lawson report, page 6]

• There is a bus stop at Olympic Boulevard and Bundy Drive. However, that stop is approximately 1 ,850 feet from the proposed school site, well beyond the limit of one-quarter of a mile ( 1 ,320 feet) that is used as a criterion for evaluating the convenience and attraction of a bus stop location. The criterion walking distance to and from that stop is exceeded by 40%.

• A stop, serving one bus line, is mentioned for the intersection of Santa Monica Boulevard and Bundy Drive. That stop is approximately 3,000 feet from the school site, well over half a mile away.

• One line is described as serving a stop at Pico Boulevard and Bundy Drive. That stop is approximately 3,300 feet from the school, almost two-thirds of a mile away.

• I ~c:.tly, tht::~~ r~!*port mQntionc: the futuro bxpoc:ition MotroP.ail Lino ctation that io

proposed for south of the Olympic Boulevard/Bundy Drive intersection. The rail line is estimated to be in operation by the year 2015, but judging from the delays that have been encountered in constructing the first phase of that line, the estimate seems overly optimistic. When competed, the rail station will be approximately 2,300 feet from the school site, almost 75% in excess of the criterion for convenient and attractive walking distance.

Considering the distances that students would have to walk, the densities of the business areas between the stops and the school, and the volumes of traffic that use the streets between the stops and the school, it is not likely that students and parents will find the transit service for the new school site to be convenient, attractive, or pedestrian-safe.

5. The duration proposed for the trip cap monitoring program is too short to be of substantial value in protecting the neighborhood.

As proposed, "The trip cap review period shall be for a minimum of five (5) years ... " [LADOT memo, page 4] However, the plan for phasing-in the numbers of students to reach the proposed maximum enrollment shows that there will not be 875 students at the school until the fourth year after its opening. [Lawson report, Table 1, page 3] Therefore, the trip cap monitoring program will be evaluating the experience at full student enrollment for only two years - the fourth and fifth year after the school opens.

Beginning with the sixth year of the school operation, there would be no monitoring, and the school administration could treat the trip cap in any way it desired, including eliminating it completely. The neighborhood would be completely at the


Page 5

mercy of the school administration's good will to receive any protection from the school traffic, and the arterial street intersections that comprised the traffic impact study would be impacted, perhaps, significantly with no future opportunity of the school being responsible for effective mitigation.

6. Allowing the school a period of one year to correct any deficiencies in the trip cap program will reduce the mitigation effectiveness to negligible levels.

According to LADOT, "Should the review show that the trip cap goal was not achieved, the school will have one (1) year to correct its deficiency." [LADOT memo, page 4]1f that long a correction period is provided, the neighborhood and the arterial intersections could be impacted for approximately 36 weeks with no penalty to the school and no incentive to correct the problem speedily. The program would call for the trip cap review to take place in the third week of the school year. Assuming a 39-week long school year, the deficiency that is detected in the third week could be in effect for the remaining 36 weeks of the school year.

There is no reason that the deficiency, once detected, could not be corrected within four weeks through an education and ride-share matching program. The limit for correction and a new field study to evaluate compliance should be reduced to within six weeks of detecting the deficiency.

In summary, the applicant's proposed traffic mitigation program, as currently formulated, is flawed in both its concept of an infeasible trip cap program and in its proposed method of implementation. The mitigation monitoring program would not cover the entire range of potentially impacted locations, and the program would end before it has had a chance to prove the effectiveness and endurance of the measure. The traffic impact study slhould be resumed with the goal of identifying feasible mitigation measures that will !be both effective and enduring. If those cannot be identified, then the proposed school should be reduced in size sufficiently to mitigate the significant impacts.

If the Commissioners or staff members have any questions about my comments, I would be pleased to respond.

Very truly yours,

Original signed by Arthur L. Kassan, P.E.

Arthur L. Kassan, P.E. Registered Traffic Engineer No. 152 Registered Civil Engineer No. 15563

EXHIBIT C

DATE:

TO:

FROM:

SUBJECT:

CITY OF LOS ANGELES INTER-DEPARTMENTAL MEMORANDUM

November 30, 2011

Hadar Plafkin, City Planner Department of City Planning

.M. ~. p,j~ Mohammad H.Biorfroshan, Transportation Engineer Department of Transportation

Supplemental traffic assessment for the proposed 875-student charter school project at1905 Armacost Avenue ("Reverse Flow Access" alternative, Dept of Transportation case no. WLA11-040, Dept of City Planning case no. ENV-2011-1924-MNDl

Pursuant to the West Los Angeles Transportation Improvement and Mitigation Specific Plan Ordinance No. 171,492 (WLA TIMP), the Department ofTransportation(DOT) issued a traffic impact assessment letter of the proposed 875-student charter school project located at 1905 Armacost Avenue on October 6, 2011. Since this letter was released, the applicant has submitted a supplemental traffic analysis with a revised "Rever!:}e FlowAccess" alternative (see Project Requirem~nt C noted below for details). This supplemental traffic analysis is based on a report prepared by Hirsch/Green Transportation Consulting, Inc., received by DOT on November 4, 2011. After a. careful review of the pertinent data, DOT has detenmined that the traffic study adequately describes the project-related impacts of the proposed development under the ''Reverse Flow Access" alternative.

Project Description

The proposed project consists of converting the existing 49,885 square foot vacant warehouse building to house a new 875-student charter school, including a 375-student middle school (grades 6 to 8) and a 500-student high school (grades 9 to 12), with separate arrival/dismissal times. The high school class time will be from 7:30 a.m. to 3:00p.m. while the middle school will operate from 8:30a.m. to 3:30p.m. The project is anticipated to be completed and fully occupied by the year 2015, with the initial occupancy to start in Fall2012 with approximately 575 students (450 middle school students and 125 high school students).

Discussion and Findings

The project is expected to create a net increase of2,170 daily trips, an increase of 814 net new a.m. peak hour trips and an increase of 508 net new p.m. peak hour trips. The trip generation estimates are based on rates from Appendix "A" of the WLA TIMP and

./

Hadar Plafkin 2 November 30,2011

formulas published by the Institute ofTransportation Engineers (ITE) Trip Generation, 8th Edition, 2008. The attached table, Attachment A, lists the trip generation results.

DOT has determined that the proposed project will create significant traffic impacts at the following nine (9) intersections, as shown in the summary of volume-to-capacity (V/C) ratios and levels of service (LOS) for the study intersections (Attachment B):

1. Bundy Drive & La Grange Avenue 2. Bundy Drive & Olympic Boulevard 3. Bundy Drive & Pico Boulevard 4. Bundy Drive & 1-10 EB On-ramp 5. Barrington Avenue & La Grange Avenue 6. Barrington Avenue & Mississippi Avenue 7. Barrington Avenue & Olympic Boulevard 8. Barrington Avenue & Pico Boulevard 9. Sawtelle Boulevard & Olympic Boulevard

In addition, the residential impact analysis revealed a significant impact at the following location, as shown in the summary of average daily traffic (ADT) volumes of the street segment studied (Attachment C):

1. La Grange Avenue east of Westgate Avenue

To mitigate the identified traffic impacts to a less-than-significant level, the project proposes an aggressive trip cap reduction thru the implementation of a Transportation Demand Management (TOM) program. DOT recommends that the following project requirements be adopted as conditions of project approval. These requirements must be completed and/or guaranteed before the issuance of any building permits for the proposed project.

Project Requirements

In response to the findings of the traffic study, DOT recommends that the following project requirements be adopted as conditions of project approval. Furthermore, these requirements must be. completed and/or guaranteed prior to the issuance of any building permits for the proposed project.

A. Application Fee Pursuant to Section 4.0 of the WLA TIMP, the applicant shall submit $4,593.00 for the application/ study review fee. This fee was paid on September 20, 2011.

B. Covenant and Agreement Pursuant to Section 4.B of the WLA TIMP, the owner(s) ofthe property must sign and record a Covenant and Agreement prior to issuance of any building permit, acknowledging the contents and limitations of this Specific Plan in a form designed to run with the land.

Hadar Plafkin 3 November 30, 2011

C. Site Access and Internal Circulation This determination does not include approval of the project's driveways, internal circulation and parking scheme. Adverse traffic impacts could occur due to access and circulation issues. The applicant is advised to consult with DOT for driveway locations and specifications prior to the commencement of any architectural plans, as they may affect building design.

The project proposes that vehicular access be provided thru ingress at driveway off of Missouri Avenue and egress at driveway off of Armacost Avenue. During normal drop-off and pick-up periods, these driveways shall be restricted to rightturn only ingress and egress. In addition, the existing on-site parking facility shall be re-striped to provide head-in parking stalls along the westerly segment, and to provide two travel lanes at the middle segment which would be used for queuing of incoming vehicles off of Missouri Avenue driveway. Drop-off and pick-up operations shall take place strictly on-site. To improve traffic flow and enhance vehicular and pedestrian safety, the project shall consult with DOT's Western District office to determine the feasibility of installing the following traffic controls:

a. All-way stop sign control at Missouri Avenue and Armacost Avenue intersection ·

b. All-way stop sign control at Armacost Avenue and La Grange Avenue intersection.

Final DOT approval shall be obtained prior to issuance of any building permits. This should be accomplished by submitting detailed site/driveway plans, <tl a scale of at least 1" = 40', separately to DOT's WLA!Coastal Development Review Section at 7166 West Manchester Avenue, Los Angeles 90045 as soon as possible but prior to submittal of building plans for plan check to the Department of Building and Safety.

In order to minimize and prevent last minute building design changes, it is hrghly imperative that the applicant, prior to the commencement of building or parking layout design efforts, contact DOT for driveway width and internal circulation requirements. This would ensure that such traffic flow considerations are designed and incorporated early into the building and parking layout plans to avoid any unnecessary time delays and potential costs associated with late design changes.

D. Highway Dedication and Physical Street Improvements Pursuant to Section 4.E.2 of the WLA TIMP, and in order to mitigate potential access and circulation impacts, the applicant may be required to make highway dedications and improvements. The applicant shall consult the Bureau of Engineering for any additional highway dedication or street widening requirements.

Hadar Plafkin 4 November 30,2011

These requirements must be guaranteed before the issuance of any building permit through the B-permit process of the Bureau of Engineering, Department of Public Works. They must be constructed and completed prior to the issuance of any certificate of occupancy to the satisfaction of DOT and the Bureau of Engineering.

E. Traffic. Management and Monitoring Program (TMMP) Pursuant to Section 4.G. of the WLA TIMP, and in order to mitigate the projected traffic impacts to a less-than-significant level, as well as to minimize the likelihood of a vehicle queue protruding into the public roadway, DOT recommends that a TMMP be implemented to survey the actual on-site queuing and insure that sufficient queuing capacity is available on-site. If the school is unable to maintain its ingress traffic entirely on-site, enrollment should be reduced until compliance is achieved.

The TMMP should also document the school's requirement to maintain a 65% reduction in its student enrollmenttrips for the high school morning peak hour (7:00a.m. to 8:00p.m.), a 75% reduction in trips for the middle school morning peak hour (8:00 to 9:00a.m.), .and a 75% reduction in trips for the combines high school and middle school afternoon peak hour (2:45 to 3:45. p.m.), which corresponds to a trip cap of 15ftrips for high school during the a.m. peak hour (7:00 to 8:00 a.m.). 90 trips for the middle school during the a.m. peak hour (8:00 to 9:00 a.m.) and 126 trips for the combined high school and middle school during the p.lll .. peak hour (2:45 to 3:45 p.m.), for the school at full.occupancy. The school proposes to achieve these trip reductions through an aggressive TOM Program that would require a minimum vehicleoccupancy of 3 students per vehicle for on-site student pick-up and drop-off activities (no student driver allowed).

The measurements of actual trips and. monitoring shall cover the peak hours that include the school's two separate starting times and combined dismissal time, Tuesday through Thursday (excluding school holidays), over a one-week period during the third week of each school term. The monitoring shall take place at the school drop-off zone and project driveways, at the school's expense.

The trip cap review period shall be for a minimum offive (5) years, in which time the review must show accomplishment of the trip cap goal reduction for this entire 5-year review period. Should the review show that the trip cap goal was not achieved, the school will have one (1) year to correct its deficiency. If the school cannot achieve the trip cap goal within the corrective year, the school will be required to reduce its enrollment in an amount commensurate with the trip cap and a new five year review period will commence with the following school year.

A full detailed description of the TMMP (TMMP Plan), and all subsequent TMMP reporting, should be prepared by a licensed Traffic Engineer and submitted to

Hadar Plafkin 5 November 30, 2011

DOT for review. The TMMP Plan should be submitted to DOT and the Department of City Planning for review and approval, prior to the issuance of any certificate of occupancy.

F. Construction Impacts DOT recommends that a construction work site traffic control plan be submitted to DOT's Western District Office for review and approval prior to the start of any construction work. The plan should show the location of any roadway or sidewalk closures, traffic detours, haul routes, hours of operation, protective devices, warning signs and access to abutting properties. DOT also recommends that construction related traffic be restricted to off-peak hours, as well as school off-peak hours when school is in session.

DOT Assessment Appeal Process

Pursuant to Section 8.A of the WLA TIMP, an applicant or any other interested person adversely affected by the proposed project who disputes any determination made by DOT pursuant to this Ordinance may appeal to the General Manager of DOT. This appeal must be filed within a 15 day period following the applicant's receipt date of this letter of determination. The appeal shall set forth specifically the basis of the appeal and the reasons why the determination should be reversed or modified.

If you have any questions, please feel free to call Hui Huang of my staff or me at (213) 485-1062.

MB:hmh

Attachments

cc: Whitney Blumenfeld, Paul Backstrom, Len Nguyen, Eleventh Council District Jay Kim, Sean Haeri, Michael May (Western District), DOT David Weintraub, DCP Mike Patonai, BOE Ron Hirsch, Hirsch/Green Transportation Consulting, Inc.

ATTACHMENT A 875-student charter school project at 1905 Armacost Avenue- "Reverse Flow Access" alternative

Trip Generation Estimates

Table 2 Project Trip Generation

Size/Use

Proposed Uses

375 -student Middle School (Grades 6- 8)

500 -student High School (Grades 9- 12)

Subtotal School Trips

Less Existing Uses (Removed)

49,980 sq. ft. Warehouse Building (vacant)

Total Net New Project Trips

Existing Students Relocated to Proposed Site

340 -student Middle School (Grades 6- 8) l3l

Notes:

Daily =

930

1,240

2,170

-- n/a --

2,170

843

Morning School Arrival Period !11

In Out Total

213 136 349

284 181 465 -- --497 317 814

----- n/ a -----

497 317 814

193 123 316

Afternoon School Dismissal Period 121

In Out Total

92 126 218

122 168 290 -- --214 294 508

----- n/ a -----== === 214 . 294 508

83 114 197

[1] Peak morning arrivals for high school occur between 7:00 and 8:00AM; for middle school between 8:00 and 9:00AM.

[2] Peak afternoon dismissals for both high school and middle school occur between 2:45 and 3:45 PM. [3] Existing school located at 11625 W. Pica Boulevard. Some of these trips already exist at the selected study intersections.

ATTACHMENT B 875-student charter school project at 1905 Armacost Avenue- "Reverse Flow Access" alternative

Summary of Volume to Capacity Ratios (\//C) and Levels of Service (LOS)

Table 8 Critical Movement Analysis Summary

Existing (2011) and Future (2015) Without and With Project Conditions· "Reversed" Site Access Scenario

Year 2011 Conditions Year 2015 Conditions Existing Without

Int. Peak (No Project) Existing With Project Project With Project

No. Intersection Hourl'J CMA LOS CMA LOS Impact CMA LOS CMA LOS Impact = = = ==

1 Bundy Drive AM - High School 0.489 A 0.495 A 0.006 0.555 A 0.561 A 0.006

and Santa Monica Boulevard/Ohio Avenue 111 AM - Middle School 0.625 B 0.641 B 0.016 0.689 B 0.689 B 0.000

School PM 0.681 B 0.681 B 0.000 0.765 c 0.765 c 0.000


and Idaho Avenue AM - Middle School 0.657 B 0.672 B 0.015 0.693 B 0.709 c 0.016

School PM 0.615 B 0.631 B 0.016 0.654 B 0.670 B 0.016


and Missouri Avenue AM - Middle School 0.469 A 0.561 A 0.092 0.498 A 0.590 A 0.092

School PM 0.540 A 0.637 B 0.097 0.577 A 0.675 B 0.098


and La Grange Avenue AM - Middle School 0.537 A 0.631 B 0.094 0.568 A 0.663 B 0.095

School PM 0.617 B 0.755 c 0.138 * 0.658 B 0.796 c 0.138 '

5 Bundy Drive AM - High School 0.622 B 0.668 B 0.046 0.681 B 0.726 c 0.045 *

and Olympic Boulevard AM - Middle School 0.925 E 0.960 E 0.035 * 1.027 F 1.062 F 0.035 *

School PM 0.820 D 0.856 D 0.036 * 0.904 E 0.937 E 0.033 *

6 Bundy Drive AM - High School 0.821 D 0.859 D 0.038 * 0.888 D 0.926 E 0.038 *

and Pico Boulevard AM - Middle School 0.947 E 0.969 E 0.022 * 1.049 F 1.069 F 0.020 *

School PM 0.980 E 1.005 F 0.025 * 1.127 F 1.152 F 0.025 *

7 Bundy Drive AM - High School 0.558 A 0.575 A 0.017 0.589 A 0.607 B 0.018

and 1-10 EB On-Ramp AM - Middle School 0.731 c 0.751 c 0.020 0.795 c 0.816 D 0.021 *

School PM 0.666 B 0.702 c 0.036 0.715 c 0.751 c 0.036

8 Barrington Avenue AM - High School 0.591 A 0.599 A 0.008 0.679 B 0.688 B 0.009

and Santa Monical Boulevard AM - Middle School 0.690 B 0.694 B 0.004 0.783 c 0.790 c 0.007

School PM 0.645 B 0.650 B 0.005 0.737 c 0.742 c 0.005

Table 8 (continued) Critical Movement Analysis Summary

Existing (2011) and Future (2015) Without and With Project Conditions. "Reversed" Site Access Scenario

Year 2011 Conditions Year 2015 Conditions Existing Without

Int. Peak (No Project) Existing With Project Project With Project

No. Intersection Hour 12J CMA LOS CMA LOS Impact CMA LOS CMA LOS Impact = = =

9 Barrington Avenue AM - High School 0.525 A 0.538 A 0.013 0.561 A 0.575 A 0.014

and Nebraska Avenue AM - Middle School 0.562 A 0.572 A 0.010 0.605 B 0.615 B 0.010

School PM 0.693 B 0.711 c 0.018 0.751 c 0.773 c 0.022

10 Barrington Avenue AM - High School 0.536 A 0.583 A 0.047 0.573 A 0.619 B 0.046

and La Grange Avenue AM - Middle School 0.627 B 0.663 B 0.036 0.673 B 0.709 c 0.036

School PM 0.645 B 0.721 c 0.076 * 0.696 B 0.773 c 0.077 *

11 Barrington Avenue AM - High School 0.574 A 0.592 A 0.018 0.613 B 0.631 B 0.018

and Mississippi Avenue AM - Middle School 0.708 c 0.740 c 0.032 0.756 c 0.788 c 0.032

School PM 0.758 c 0.836 D 0.078 ' 0.812 D 0.890 D 0.078 *

12 Barrington Avenue AM - High School 0.661 B 0.697 B 0.036 0.719 c 0.756 c 0.037

and Olympic Boulevard AM - Middle School 0.893 D 0.920 E 0.027 * 0.968 E 0.995 E 0.027 *

School PM 0.724 c 0.763 c 0.039 0.811 D 0.850 D 0.039 *

13 Barrington Avenue AM - High School 0.699 B 0.729 c 0.030 0.759 c 0.789 c 0.030

and Pice Boulevard AM - Middle School 0.798 c 0.819 D 0.021 * 0.869 D 0.891 D 0.022 *

School PM 0.685 B 0.703 c 0.018 0.791 c 0.809 D 0.018

14 Sawtelle Boulevard AM - High School 1.058 F 1.068 F 0.010 * 1.147 F 1.158 F 0.011 *

and Olympic Boulevard AM - Middle School 1.367 F 1.373 F 0.006 1.478 F 1.484 F 0.006

School PM 0.880 D 0.894 D 0.014 0.985 E 0.999 E 0.014 *

Notes: [1] Intersections of Bundy Drive and Santa Monica Boulevard and Bundy Drive and Ohio Avenue analyzed as a single location, per LADOT.

[2] "AM - High School" represents 7:00 to 8:00 AM; "AM -Middle School" represents 8:00 to 9:00 AM; "School PM" represents 2:45 to 3:45 PM.

''"" Indicates significant impact per LADOT Traffic Study Policies and Procedures, August 2011.

Table 12(a) Critical Movement Analysis Summary

Existing (2011) Without, With Project, and With Mitigation Conditions "Reversed" Site Access Scenario

Existing With Project Int. Peak (No Project) Existing With Project Plus Mitigation

No. Intersection Hour 1'1 CMA LOS CMA LOS Impact CMA LOS Impact = = = =

4 Bundy Drive and AM-H. S. 0.390 A 0.516 A 0.126 0.431 A 0.041

La Grange Avenue AM-M.S. 0.537 A 0.631 B 0.094 0.561 A 0.024

School PM 0.617 B 0.755 c 0.138 ' 0.651 B 0.034

5 Bundy Drive and AM- H. S. 0.622 B 0.668 B 0.046 0.638 B 0.016

Olympic Boulevard AM-M.S. 0.925 E 0.960 E 0.035 ' 0.934 E 0.009

School PM 0.820 D 0.856 D 0.036 * 0.830 D 0.010

6 Bundy Drive and AM- H. S. 0.821 D 0.859 D 0.038 ' 0.833 D 0.012

Pico Boulevard AM-M.S. 0.947 E 0.969 E 0.022 ' 0.953 E 0.006

School PM 0.980 E 1.005 F 0.025 * 0.986 E 0.006

10 La Grange Avenue and AM- H. S. 0.536 A 0.583 A 0.047 0.551 A 0.015

Barrington Avenue AM-M.S. 0.627 B 0.663 B 0.036 0.637 B 0.010

School PM 0.645 B 0.721 c 0.076 ' 0.663 B 0.018

11 Barrington Avenue and AM-H. S. 0.574 A 0 .. 592 A 0.018 0.580 A 0.006

Mississippi Avenue AM-M.S. 0.708 c 0.740 c 0.032 0.713 c 0.005

School PM 0.758 c 0.836 D 0.078 * 0.777 c 0.019

12 Olympic Boulevard and AM- H. S. 0.661 B 0.697 B 0.036 0.602 B -0.059

Barrington Avenue AM-M.S. 0.893 D 0.920 E 0.027 * 0.879 D -0.014

School PM 0.724 c 0.763 c 0.039 0.734 c 0.010

13 Barrington Avenue and AM-H. S. 0.699 B 0.729 c 0.030 0.709 c 0.010

Pico Boulevard AM-M.S. 0.798 c 0.819 D 0.021 * 0.803 D 0.005

School PM 0.685 B 0.703 c 0.018 0.689 B 0.004

14 Olympic Boulevard and AM-H. S. 1.058 F 1.068 F 0.010 * 0.977 E -0.081

Sawtelle Boulevard AM-M.S. 1.367 F 1.373 F 0.006 1.368 F 0.001

School PM 0.880 D 0.894 D 0.014 0.884 D 0.004

Notes: [1] "AM- H. S." represents 7:00 to 8:00AM; "AM· M.S." represents 8:00 lo 9:00AM; "School PM" represents 2:45 to 3:45PM.

"*" Indicates significant impact per lADOT Traffic Study Policies and Procedures , August 2011.

Table 12(b) Critical Movement Analysis Summary

Future (2015) Without, With Project, and With Mitigation Conditions "Reversed" Site Access Scenario

Int. Peak Hourl'l

Without Project With Project

With Project Plus Mitigation

No. Intersection CMA LOS CMA LOS Impact CMA LOS Impact =

4 Bundy Drive and La Grange Avenue

5 Bundy Drive and Olympic Boulevard

6 Bundy Drive and Pico Boulevard

7 Bundy Drive and 1-1 0 EB On-Ramp

10 Barrington Avenue and La Grange Avenue

11 Barrington Avenue and Mississippi Avenue

12 Barrington Avenue and Olympic Boulevard

13 Barrington Avenue and Pico Boulevard

14 Sawtelle Boulevard and Olympic Boulevard

Notes:

AM- H. S. AM-M.S. School PM









0.413 0.568 0.658

0.681 1.027 0.904

0.888 1.049 1.127

0.589 0.795 0.715

0.573 0.673 0.696

0.613 0.756 0.812

0.719 0.968 0.811

0.759 0.869 0.791

1.147 1.478 0.985

= A A B

B F E

D F F

A c c A B B

B c D

c E D

c D c F F E

0.539 A 0.663 B 0.796 c 0.726 c 1.062 F 0.937 E

0.926 E

1.069 F 1.152 F

0.607 B 0.816 D 0.751

0.619 0.709 0.773

c B

c c

0.126 0.454 A 0.095 0.592 A 0.138 ' 0.693 B

0.045 * 0.695 B 0.035 * 1.036 F 0.033 * 0.911 E

0.038 ' 0.899 D 0.020 ' 1.054 F 0.025 ' 1.133 F

0.018 0.595 A 0.021 ' 0.801 D 0.036

0.046 0.036

0.724 c 0.587 A 0.683 B

0.077 * 0.715 c 0.631 0.788 0.890

B O.Q18 0.619 B

0.756 0.995 0.850

0.789 0.891 0.809

1.158 1.484 0.999

c 0.032 0.761 c D 0.078 * 0.831 D

c 0.037 0.731 c E 0.027 '' 0.975 E D

c D D

F F E

0.039 ' 0.821 D

0.030 0.769 c 0.022 * 0.875 D 0.018 0.795 c 0.011 * 1.151 0.006 1.480 0.014 ' 0.989

F F E

[1] "AM- H. S." represents 7:00 to 8:00AM; "AM- M. S." represents 8:00 to 9:00AM; "School PM" represents 2:45 to 3:45PM.

""" Indicates significant impact per LADOT Traffic Study Policies and Procedures, August 2011.

0.041 0.024 0.035

0.014 0.009 0.007

0.011 0.005 0.006

0.006 0.006 0.009

0.014 0.010 0.019

0.006 0.005 0.019

0.012 0.007 0.010

0.010 0.006 0.004

0.004 0.002 0.004

ATTACHMENT C 875-student charter school project at 1905 Armacost Avenue- "Reverse Flow Access" alternative

Summary of Average Daily Traffic (ADT) Volume

Table 11 Local/Neighborhood Street Traffic Impact Analysis Summary

Existing (2011) and Future (2015) Average Daily Traffic Volumes

"Reversed" Site Access Scenario

Existing (2011) Future (2015)

Project With Percent Without With Percent

Street Segment Existing Traffic* Project Increase Project Project Increase

Missouri Avenue, E/o Westgate Avenue 3,082 0 3,082 0.0% 3,207 3,207 0.0%

La Grange Avenue, E/o Westgate Avenue 4,275 456 4,731 10.7% 4,449 4,905 10.2%

* Note:

Includes both high school and middle school components, and is the same for both "Existing" and "Future"conditions.

Table 13 Local/Neighborhood Street Traffic Impact Analysis Summary

Existing (2011) and Future (2015) "With Mitigation" Average Daily Traffic Volumes "Reversed" Site Access Scenario

Existing (2011) Future (2015) Project With Percent Without With Percent

Street Segment Existing Traffic • Project Increase Project Project Increase

La Grange Avenue, E/o Westgate Avenue 4,275 124 4,399 2.9% 4,449 4,573 2.8%

* Note:

Includes recommended TOM program trip reductions, and is the same for both "Existing" and "Future" conditions.

timothy g. dalunger phone: (sib) 986-2311 fax: (sib) 986

Documents