our letter
to the planning commission

SILVER LAKE COALITION

Re: 3209-3227 West Sunset Blvd., Case No. CPC-2021-2035-DB-CU-CUB-SPR-HCA

Oct. 3, 2021

Dear Councilman O'Farrell and Members of the Planning Commission:

We are residents and voters in Silver Lake writing to express our concern about the nature of proposed developments along the corridor of Sunset Boulevard between Silver Lake Boulevard and Micheltorena Street.

RYDA Ventures presently has four major residential/commercial projects along this short corridor in development that will dramatically impact our community. This is not a request that development be stopped, nor an expression of concern over the inclusion of affordable housing, nor a NIMBY complaint. Rather, the purpose of this letter is to express concern over the scope of development waivers and incentives that RYDA is presently seeking from the City of Los Angeles for its third project, located at 3209-3227 West Sunset Blvd. (the “3209 Sunset Project”).

Though the exact details of RYDA’s fourth project in this corridor remain to be announced, it appears that these four projects combined will add approximately 350 household units, and as much as 30,000 sq. feet of commercial space to a short space of Sunset Blvd., but with far too few parking spaces, and with substantial height waivers that will transform this neighborhood. RYDA’s 3209 Sunset Project seeks a particularly excessive number and scope of waivers, as it proposes to build a seven-story building (apparently a first for Silver Lake, by two stories) that would block homes on the hillside, and add more than 9,000 sq. feet of commercial/restaurant space with zero commercial parking spaces.

Without RYDA’s requested waivers from the municipal code currently under consideration by the City Planning Commission, this development would be required to have approximately 102 residential parking spaces, rather than the proposed 69, plus 54 commercial parking spaces, rather than the proposed zero. The combined impact of these four developments would be to push hundreds of cars of residents, employees, and retail/restaurant customers into the narrow and crowded hillside streets on either side of Sunset. There is nowhere else for these cars to go, particularly as one of the RYDA developments is being built on the neighborhood’s only freestanding parking lot.

This is not a complaint of inconvenience. This series of projects poses grave health and safety concerns to our neighborhood. The crush of cars searching for parking on hillside streets is a matter of public safety and environmental impact. Our red zones are routinely occupied by illegally parked cars, limiting the access of emergency responders and blocking our stop signs. Cars circle around for many blocks in search of parking spots, adding carbon emissions to the atmosphere that wouldn’t occur if parking were available along Sunset. And cars speed through these narrow streets at rush hour to avoid congestion that is already present on Sunset, putting at danger the children who walk along these streets to and from Micheltorena Elementary and St. Francis of Assisi School.

I ask that you stand up for our neighborhood and ensure that Los Angeles does not permit RYDA to transform this sensitive and narrow corridor into an overdeveloped mass of new buildings that rely on side streets for parking. Several major streets that cross Hollywood deposit their traffic onto this sole east-west corridor through Silver Lake, causing substantial gridlock at busy times. The four new RYDA projects, with large numbers of new residents and visitors filling the streets in their search for parking, will further an already problematic and dangerous situation.

RYDA has requested to undertake the 3209 Sunset Project using a categorical exemption from the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines, Section 15332 (Class 32). Projects that qualify for Class 32 exemptions require a mere fraction of the process required for standard CEQA review. However, under CEQA Guidelines, § 15300.2, subds. (b)‑(e), the infill exemption cannot be used if “the cumulative impact of successive projects of the same type in the same place, over time is significant,” or if the project under consideration is subject to “unusual circumstances.” The Los Angeles Planning Commission (“Commission”) must reject the use of the Class 32 categorical exemption because the 3209 Sunset Blvd. project is disqualified under both the “cumulative impacts” test and the “unusual circumstances” test.

Specifically, the 3209 Sunset Project is one of four RYDA residential or residential/retail mixed-use projects within a few blocks, each of which lacks sufficient parking and will result in significantly increased traffic and parking in the surrounding neighborhoods, resulting in safety, environmental and health problems that arise from these “successive projects of the same type in the same place.” There are also a multitude of “unusual circumstances” at issue; to name just a few: (i) there are two elementary schools in extremely close proximity—within 0.2 and 0.4 miles—of the 3209 Sunset Project, such that the Commission must consider the health and safety of children walking to and from school; (ii) there is already a critical parking shortage in hillside neighborhoods adjacent to the project site such that adding even a dozen cars to those neighborhoods would have a significant and adverse impact on parking, safety, and health; (iii) due to the narrow and windy streets and illegally parked cars, there is already a significant risk that emergency vehicles will not be able to respond to fires or other emergencies at homes in those neighborhoods; and (iv) the project is located in Very High Fire Hazard Severity Zone (VHFHSZ).

Accordingly, we implore you to act on behalf of your constituents. RYDA’s request to take advantage of a categorical exemption from CEQA, for which the 3209 Sunset Project does not qualify, should be rejected. The Commission should fully comply with CEQA prior to granting any approval of the 3209 Sunset Project, and reject waivers that would permit the project's excessive height and density. Once this stretch of Sunset Boulevard has been allowed to become an overdeveloped corridor of gridlock, it will be too late to act.

Regarding future Silver Lake development, we need your support in demanding that the City:

1. Enforce the General Plan monitoring policy requirement as outlined in “General Plan Framework Chapter Two-Growth Monitoring Policy” to ensure that public infrastructure and public services are not overwhelmed by a disproportionate increase in housing units;

2. Require developments to comply with all height, zoning and parking requirements, and if waivers are granted, that they be evaluated within a framework of objective zoning standards and objective design review standards;

3. Require that developers engage in a structured process with the surrounding neighborhood a) to present transparently each project in full detail and b) to negotiate Community Benefits; and

4. Require the Department of Housing and Community Investment to monitor and enforce the renting of restricted units to low-income residents.
   

Once again, this is not a request to stop the addition of new housing. It is a request that you ensure that Silver Lake is home to responsible development that does not overwhelm the neighborhood landscape with height waivers or create new hazards with density that is unsupported with sufficient parking for residents, employees, and customers.

Sincerely,

Members of the Silver Lake Coalition
for Responsible Development