Predatory Development: Crossroads Hollywood

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New development is necessary. In order for a city to grow, in order for its economy to stay healthy, it’s important to have new construction to bring investment to communities and adapt to the city’s changing needs. But new development isn’t always a good thing. New projects bring new impacts, and the larger the project the more important it is to consider carefully how it will affect the surrounding community. Most large projects are a mixed bag. Pro-business groups will inevitably argue that they bring tax revenue and jobs, and both of these are important. But large projects can also have serious negative impacts, and we need to weigh those, too. Often it’s a matter of trying to figure out if the good will outweigh the bad, and in many cases it’s hard to say for sure.

On the other hand, in some cases it’s pretty easy to make the call. Crossroads Hollywood is a clear example of predatory development. While the backers of the project tout its benefits in terms of tax revenue, jobs and economic activity, they completely ignore the downside. And the downside is considerable.

First, let’s take a look at what this whole thing entails.

Crossroads Hollywood includes about 1,381,000 square feet of floor area, consisting of 950 residential units (of which 105 are for Very Low Income Households), 308 hotel rooms, and approximately 190,000 square feet of commercial space. The project does include the preservation and rehabilitation of the historic Crossroads of the World mall and the Hollywood Reporter building. All other buildings on the project site would be demolished, including 84 Rent Stabilized apartments. The developers are also asking for a Master Conditional Use Permit to allow the sale of a full line of alcoholic beverages at a total of 22 establishments, and another Master CUP to allow eight uses with public dancing and live entertainment.

I’ve gotta say, it’s pretty ambitious. The investors behind Crossroads, Harridge Development Group, are thinking big. They’re also thinking only of themselves and the massive profits they’ll reap from this project. They don’t really give a damn about the community. If approved, Crossroads Hollywood will be devastating for the environment, devastating for housing, and devastating to the health and well-being of the Hollywood community.

Let’s take a look at the project’s environmental impacts….

These days any developer is going to tell you their project is good for the planet. They learned long ago they need to play that angle to sell it to the public. But Harridge’s claims about Crossroads being environmentally friendly are mostly just hype.

The State of California has designated Crossroads Hollywood an Environmental Leadership Development Project. (ELDP). In order to qualify, the developer has to show that it won’t result in any net additional emissions of greenhouse gases (GHGs). But a project on the scale of Crossroads represents a huge increase in square footage, so it’s to be expected that there will be a huge increase in energy use. The report by the California Air Resources Board (ARB) estimates the Crossroads project will produce 9,440 MTCO2e (Metric Tons of Carbon Dioxide Equivalent) during demolition and construction, and then 14,294 MTCO2e during the first year of operation, though they say that number will decline each year over the life of the project. This is a huge increase in emissions. So how can the State say it achieves a net reduction?

Simple. The developer buys carbon credits. Like many other states, California has an exchange where businesses that aren’t producing their maximum allowed CO2 emissions can sell what they don’t produce as “credits”. Other businesses that want to offset their own emissions can buy the credits to satisfy regulators. So while Crossroads Hollywood will be putting tens of thousands of tons of additional GHGs into the atmosphere, the State says that buying credits actually makes the project carbon neutral. There are people who have reservations about the carbon credit system, but it’s become widely accepted as a tool for reducing global warming, so let’s go along with the idea that this does represent a net reduction in CO2 emissions.

The problem is that this project isn’t just producing massive amounts of CO2. It’s also spewing out tons of ozone, nitrogen dioxide, and particulate matter. This is bad news for the people who live in the area. The South Coast Air Quality Management District (SCAQMD) has evaluated cancer risk from air pollution in its Multiple Air Toxics Exposure Study IV (MATES IV). You can see by the map below that Hollywood is near the top of the scale.

Crossroads Air Quality MATES IV from EIR

But it gets worse. After going through pages of boiler plate language about localized significance thresholds and standard methodologies, the Crossroads Environmental Impact Report (EIR) gets around to analyzing impacts during the construction phase of the project. After listing nearby sensitive uses, including Selma Elementary School/Larchmont Charter School (same campus), Hollywood High, and Blessed Sacrament School, and acknowledging that young people are at higher risk of chronic lung disease from air pollution, the EIR claims, “…, localized construction emissions resulting from the Project would result in a less-than-significant air quality impact.”

Give me a break. Four years of construction, including demolition and excavation, thousands of diesel truck trips and extensive use of heavy machinery will have “less-than-significant” impacts on the kids at these schools? And it’s also important to point out there have been projects under construction on Selma for years now, many of them within three blocks of Selma Elementary. These kids have been inhaling construction dust and diesel fumes since 2015, and the folks behind Crossroads want to keep that going til 2021. But don’t worry. It won’t harm the students a bit.

So let’s talk about transportation. I will give the authors of the EIR credit. Usually traffic assessments for projects like these are ridiculously dishonest. In this case, the EIR acknowledges that traffic is already bad in the area, and that the project will make it worse. Here are a few shots of what it looks like at rush hour.

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Northbound traffic on Highland, the western boundary of the project.

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Traffic heading west on Selma toward Highland.

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Traffic heading north on Las Palmas toward Selma.

The EIR does analyze existing weekday rush hour conditions as required by the California Environmental Quality Act (CEQA). The problem here is, Hollywood is a special case. In addition to really awful congestion at rush hour, you can also have heavy traffic at night and on weekends because of the constant parade of concerts, movie premieres, food fairs and other miscellaneous events. There are multiple happenings in Hollywood every month, many of them involving street closures. And don’t even ask what it’s like during the Hollywood Bowl season.

I wouldn’t expect the authors of the EIR to include all this, because they’re not required to. But they should at least talk about additional traffic generated by the eight live entertainment venues that are included in the project. Crossroads Hollywood isn’t just meant to be a place where people live and work. It’s intended to be a destination. While I’m sure some of the spaces offering entertainment will be fairly small, it seems likely that at least one of them will be a dance club offering live DJs. And I wouldn’t be surprised if popular singers and bands start showing up on a regular basis. Which means that a community already overwhelmed with events that draw tons of cars and disrupt transit will have to bear an even heavier load once Crossroads is up and running.

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Apartment building to be demolished if the project is approved.

And what about the impacts that eight places featuring live entertainment will have on the LAPD’s workload? Not to mention the 22 establishments selling alcohol. Incredibly, the EIR doesn’t even discuss these things in the section dealing with police protection. They conclude again that project impacts will be “less-than-significant”. Obviously the authors of the EIR haven’t seen the research indicating that high alcohol outlet density has been linked to higher rates of violent crime.  Back in 2014, LAPD Chief Charlie Beck wrote to the Department of City Planning (DCP) pointing out that the “oversaturation” of alcohol outlets in Hollywood was contributing to increased crime, including robbery, shootings, rape, and assault. The DCP obviously paid no attention, because they’ve gone on granting liquor permits, and violent crime in Hollywood has risen every year since then. LAPD stats for Hollywood as of April 21 show violent crime has gone up 28.9% over the same period last year. The LAPD is understaffed, and doing their best to cope with a difficult situation. Too bad the DCP has no interest in helping them out. Apparently the folks at City Planning have no concern for the safety of Hollywood residents, or for the people who visit the area. And it looks like Harridge shares their total indifference.

This same indifference extends to the project’s noise impacts. Remember, the developer is asking permits for live entertainment in 8 venues. It seems like at least some of these will be outdoors. Check out this table from the EIR that lists the spaces where they plan to have amplified sound.

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It’s hard to say how much overlap there will be, since they don’t distinguish between those spaces intended for live performances and and those that will just have recorded sounds. But it’s pretty clear that there’s going to be a lot of music, and a lot of it will be outdoors. The EIR acknowledges that there could be significant impacts from noise, but don’t worry, they have a plan to take care of that. What’s their plan? They’re going to build a 12-foot wall on the project’s eastern boundary, between Crossroads of the World and Blessed Sacrament Church. And according to the EIR, that fixes everything.

This is so ludicrous it’s hard to believe they expect people to buy it. A single 12-foot wall is going to addres any concerns about noise. Live outdoor performances have been a problem for years in Hollywood. Area residents can tolerate a lot, and nobody gets bent out of shape if someone puts on a show during the day. But in recent years more and more club owners have been pushing the limits at night. There have been a lot of complaints about DJs ripping it up on rooftop bars in the small hours. The EIR’s claim that amplified music will only be heard in the immediate vicinity is bull. People who live in the hills have told me they can hear late night noise from down on the boulevard, and they’re not happy about it.

But Crossroads Hollywood wasn’t meant to benefit the community. It was meant to benefit the investors who are hoping to reap huge profits. This project will put more cars on the road and more poison in the air. It will create more crime than the LAPD can handle and more headaches for residents trying to get a good night’s sleep. And what do we get in return? Yeah, there’s the tax revenue, but the City is already seeing record revenues and still can’t balance its budget. More housing? Yeah, the vast majority of it priced way beyond the reach of most people who live in Hollywood. When we put the 105 Very Low Income units gained against the 84 Rent Stabilized units lost, we see a net increase of 21 units that will be accessible to the low income families that really need housing. The gain of 21 units will quickly be erased by the project’s gentrifying impact. If Crossroads is built, you can expect to see a lot of other investors buying up apartments and kicking people out. And will the project create jobs? Sure, mostly low-paying jobs in bars, restaurants, and hotels. Most of the people who will work there could never afford to live there.

This is predatory development. A project designed by investors for investors. The reason the EIR doesn’t see any serious problems for the community is because the needs of the community were never considered in any meaningful way.

It’s just about money.

Next week the City will be holding a hearing on Crossroads Hollywood. If you want to show up and speak your mind, here’s the info.

Tuesday, May 15, 2018, 9:00 am

Los Angeles City Hall
200 North Spring St., Room 350

ENTER ON MAIN STREET.

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Crossroads of the World

 

RIP EPA

20 Harbor Fwy FINAL

If you’ve been following the news, you know that the Environmental Protection Agency is dead.  Founded in 1970 to protect the environment and human health, the EPA has played a major role in making our air clearer and our water cleaner for over four decades.

But that’s over now.  Since the appointment of a climate change denier as the agency’s administrator, the EPA has gutted protections for wetlands, slashed spending on research, and fought to delay enforcement of methane regulations.  And this is only the beginning.

So if you believe climate change is real and that we need to reduce our use of fossil fuels, you can’t look to the federal government any more.

Now it’s up to you.

If you own a car, you could start by driving 20% less.  If all Americans who believe climate change is real took this simple step, it would send a powerful message to the oil companies and the White House.  Ask your boss to let you telecommute on Fridays.  Or take transit one day a week.  Or talk to your co-workers about carpooling.  And there are other things you could do, too.  Think about the trips you take when you go out to shop, have fun, or hang with friends.  If you really put your mind to it, you might be able to reduce your driving by more than 20%.

And make no mistake.  It is down to you.  The federal government is no longer protecting the environment.  It’s now leading an assault on the environment.

If you don’t take action, who will?

 

Transit Riders Can Do More, Too

20 Bus FINAL

So far this campaign has mostly been about getting car owners to reduce their time on the road by 20%.  Transit riders may be thinking, “Hey, I’m already riding the bus to work.  I’m doing all I can.”

Actually, there is more you can do.

While riding transit instead of driving will help reduce greenhouse gas emissions, busses are still doing plenty of damage to the atmosphere.  You may think that because the Los Angeles MTA has converted its fleet to Compressed Natural Gas (CNG) that we’re doing all we can.

Wrong.  CNG busses produce significant amounts of CO2, in addition to other pollutants.  But we could really make a dent in greenhouse gas emissions by converting the fleet to electric, and the MTA is already studying that possibility.

Not that this will be easy.  The MTA has already tested a few electric busses, and the results were less than stellar.  Electric bus technology is still fairly new, so cost and reliability are both factors.  On top of that, switching the fleet to all electric would require a massive investment in new infrastructure, and that will take years to implement.

So what can you do?  Get involved.  Stay informed about the MTA’s progress on going electric, and don’t be afraid to let them know if you think the process could be moving faster.

Follow the link below to read articles about this issue on the MTA’s blog, The Source.

The Source/Electric Bus News

 

 

Manufacturing the Facts

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At a hearing last week, the City Planning Commission gave a green light to the proposed Ivar Gardens Hotel, which is planned for the intersection of Sunset and Cahuenga. But like a lot of projects planned for Hollywood in recent years, it wasn’t a smooth path to approval.

The hearing room was crowded with people. Most of those who were there to speak about the hotel were against, but there were also those who wanted to support it. A representative of the Central Hollywood Neighborhood Council gave it a thumbs up, and a woman from the Hollywood Chamber of Commerce went through the usual spiel about how the hotel will bring jobs and revenue.

Let me say up front, I can see good reasons for making something happen at the corner of Sunset and Cahuenga. The Jack in the Box that ‘s been sitting there for years isn’t exactly an architectural jewel. Sure, the block is underutilized. Could it be a good place for a hotel? Maybe. But a twenty one story hotel? At one of the busiest intersections in the city? I’m not so sure that’s a good idea. Still, I should try to keep an open mind. I should think about the possible benefits. And I should trust that the City of Los Angeles would only approve such a project after the most rigorous review. I should have faith that the City would never approve such a project unless it was absolutely certain that the positive would outweigh the negative.

Yeah, right.

Before I start talking about the Department of City Planning, let me say that I believe that most of the folks who work there are smart and capable. In most of my dealings with them I’ve been impressed by how friendly and helpful they are. But I also believe the culture at the DCP has been warped by outside pressures, and I often get the impression that the state-mandated environmental review process is seen as a pointless waste of time. The documents that are supposed to assess the pros and cons of a project often seem like they’ve been slapped together as quickly as possible. In some cases the data is presented in misleading ways, and in other cases it’s clearly wrong.

Like with this hotel. To begin with, a project of this size really needs the highest level of environmental review, in other words, an Environmental Impact Report (EIR). But the folks at the DCP disagreed, and they went ahead with a much lower level of review, a Mitigated Negative Declaration (MND). By making this choice they’re basically saying that all of the impacts caused by this project can be mitigated to the point where they’re insignificant. Whether or not that’s true is not important to the City. What’s important here is that the MND is much easier to prepare and makes the approval process much faster.

So let’s get back to the hearing. Like I said, there were a few people who supported the project, but a solid majority came out against it, and the speakers represented a wide variety of interests. Many of them belonged to various unions, and they raised a number of issues, but the biggest one was jobs. They couldn’t believe the City was going to approve this project without any requirement for local hire. A woman representing the Los Angeles Film School came to the mike to say they were concerned about impacts during the construction phase. The LAFS is right across the street from the site, and their programs could be severely affected by the project, but apparently the developer has shown little interest in meeting to discuss these issues so far. A number of people expressed concern over increased traffic from the hotel. One group talked about the importance of properly assessing hazardous wastes at the site. Others asked why the City was ready to hand the developer entitlements worth millions, while the developer was offering a pathetically small package of benefits to the community. And yes, the Commission was asked why an MND was being used for a project that clearly required an EIR.

That’s what I wanted to know. And I also wanted to know why the MND being considered was such an inaccurate, dishonest piece of work. I know that’s a strong statement. But let’s take a look together.

The MND supposedly assesses greenhouse gas (GHG) emissions produced by the project. Honestly, I think the numbers are questionable, and the reductions promised by mitigation measures are pretty optimistic. There’s a lot of talk about building clean, green structures these days, but environmentalists are starting to realize that developers don’t always deliver what they promise. Still, let’s pretend the GHG numbers are accurate. The MND offers a table to show how small the impacts are.

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In assessing the production of CO2 emissions, the bottom line says the “project net total” will be 1,921.34 metric tons per year (MTY). But what it should actually say is “project net total increase”. If you look at the table carefully, you can see that the actual total is 3,102.31 MTY. They came up with the 1,921.34 figure by subtracting the estimated emissions produced by the existing fast food restaurant. In reality, the proposed hotel will be spewing out CO2 at a rate of 3,102.31 MTY, or over two and a half times what the site produces now. At a time when the state is struggling to reduce greenhouse gas emissions, and traffic in LA is getting steadily worse, can the DCP really claim that this is not a significant impact?

Under Public Services the MND talks about police protection. Now, the LAPD has been pretty up front in admitting that it’s struggling to deal with increases in crime across the city. The MND includes a table showing that crime has been steadily rising in Hollywood since 2013. In light of the fact that the LAPD has said they don’t have enough staff to deal with current levels of crime, how can the DCP claim this hotel, along with a number of other projects under construction in Hollywood, won’t put an even greater strain on law enforcement? In addition to the hotel’s security lighting and secure parking facilities, the MND claims that, “the continuous visible and non-visible presence of guests staying at the hotel at all times of the day would provide a sense of security during evening and early morning hours.” Actually, there are already plenty of people on the street in this area, and it doesn’t seem to be doing much to discourage crime.

To demonstrate how little the DCP cares about facts, under Population and Housing they say, “The Hollywood Community Plan (HCP) projected a 2010 population of approximately 219,000 persons….” This is true. The HCP did make that projection. What the MND doesn’t say is that the Plan was written back in the 1980s, and that according to the US Census, Hollywood’s actual population in 2010 was 198,228, about 20,000 people less than the figure they reference. The DCP surely knows that the projection was mistaken, because a judge threw out their HCP Update in 2011, largely because the population figures were wildly off base.

One of the biggest problems with the MND is its cavalier approach to cumulative impacts. This project is just one of more than sixty planned for the Hollywood area, but I haven’t seen a single environmental document come out of the DCP in the last five years that sees any significant cumulative impacts. The DCP always inserts endless bureaucratic double-speak citing regional planning reports and state guidelines. And they always find ways to ignore anyone who produces real data to call their conclusions into question. CalTrans has made numerous attempts to get the DCP to do a serious analysis of traffic impacts from all these projects. The DCP’s response is to pretend that CalTrans doesn’t exist.

I’ve saved the best for last, because it’s such a classic example of the City’s shameless dishonesty. Under Transportation/Traffic, a study included in the MND states that PM rush hour traffic at the intersections of Cahuenga/DeLongpre, Cahuenga/Sunset and Cahuenga/Hollywood flows at Level of Service A, in other words that there’s no congestion at all. Here’s a table from the MND.

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This is so absurd it’s laughable. Anyone who’s travelled north on Cahuenga during evening rush hour knows it’s a parking lot. And in case you don’t live in the area, here are a few photos of what traffic really looks like on Cahuenga after working hours are over.

Rush hour on Cahuenga, July 2014.

Rush hour on Cahuenga, July 2014.

Rush hour on Cahuenga, same day as above.

Rush hour on Cahuenga, same day as above.

Rush hour on Cahuenga, July 2016.

Rush hour on Cahuenga, July 2016.

Rush hour on Cahuenga, same day as above.

Rush hour on Cahuenga, same day as above.

A lot of the people who spoke at the CPC hearing complained that traffic was bad enough and that this project would only make things worse. Knowing that this was a hot topic, Commission President David Ambroz realized he had to do something to prop up the MND’s ridiculous claim that rush hour traffic flowed smoothly. So he called on a guy from the DCP to get up and talk about the traffic study. And this guy rambled on for a few minutes about how the analysis was done in accordance with LA Department of Transportation standards, and that LADOT had approved the analysis, and that any variation may have been due to the fact that counts were taken during a holiday week. In other words, he didn’t claim that the traffic study actually reflected reality. Just that the people who compiled it followed the rules.

But it gets better. At the hearing, Commission President Ambroz mentioned that he lives in Hollywood, and that he’s familiar with the site for the proposed hotel, which means that he must know how bad the traffic is on Cahuenga at rush hour. And that means he also knows that the traffic report in the MND is substantially incorrect. But of course, he would never acknowledge that, because then he’d have to ask for the report to be done again, and done correctly. Instead, Ambroz sat there, somehow keeping a straight face, while the bureaucrat from the DCP went through his routine, trying to legitimize a traffic study that most of the people in the room knew was rubbish.

And then the Commission voted to adopt the MND and send the project on to the City Council. Interestingly, some of the Commissioners did vote no, not because of the MND, but because they felt the community benefits being offered by the developer were totally inadequate. This in spite of the fact that a last minute deal was cobbled together where the developer committed to 50% local hire.

So is the hotel a done deal? Not quite yet. It still has to go before the Planning & Land Use Management Committee (PLUM), and then on to the full City Council. Many of the people in the room were disappointed in the CPC’s decision. Afterwards I wrote to Elle Farmer of Unite Here, a labor group that spoke against the project, to ask how they felt about the outcome. Here’s a quote from their response.

We are still in this, and we still oppose the project as it currently stands, with no real community benefits, and no care for the environmental protection process.

And Unite Here is not satisfied with the last minute promise of local hire, as they feel it’s impossible to enforce.

I also asked for a statement from the Los Angeles Film School. Here’s an excerpt.

We support a vibrant Hollywood community and believe we played a major role in kickstarting the current renaissance. We are also the largest and most impacted stakeholder of this proposed project. Although the Commission did not grant a continuance, representatives for the developer did convey their willingness to sit down with us and discuss the project and its impacts to our campus after the hearing. We look forward to that opportunity.

And what am I looking forward to? The day when the DCP can put together an MND that actually reflects reality. And in the process shows a willingness to put the interests of the community ahead the interests of developers.

Fire Season

Fire 05 Red Sun

Saturday morning I went outside while it was still dark. As I walked past an overhead light I looked up and saw a stream of tiny particles drifting down to the ground. It was ash. I knew there was a fire somewhere.

It wasn’t until later in the day that I found out the fire was in Santa Clarita. I was in Burbank, and looking toward the north you could see a massive, dark, grey cloud spreading across the sky.

A view of the sky over Burbank on Saturday.

A view of the sky over Burbank on Saturday.

The older I get, the more uneasy I feel during the fire season. I’m not worried about my own safety. The most destructive fires generally happen far away from the center of the city. What really scares me is knowing that thousands of acres and millions of trees are going up in smoke. Tune in to the news and you can see raging infernos sweeping across California’s hills and mountains. Sometimes it feels like the whole state is on fire.

I just mentioned how uneasy I felt during the fire season, but I should have said “seasons”. In California there are actually two periods when fires are likely to burn. The summer season, when high temperatures dry out our forests, and the Santa Ana season, when hot winds drive fast-burning blazes that generally threaten coastal areas. In recent years, both of these periods have grown longer, and the fires have grown larger. See this article from KCET’s web site for more details.

California Has Two Fire Seasons, and Climate Change Will Make Both Worse

The sun seen through smoke from the Santa Clarita fire.

The sun seen through smoke from the Santa Clarita fire.

There’s a growing body of evidence that suggests that the hotter, drier weather we’ve been experiencing for years now isn’t just a drought, but that the climate in the Western US is changing. Snow packs have been declining for decades, and warmer temperatures are causing the snow to melt earlier. This is one of the reasons that our summer fire season has grown longer and more destructive.

If climate change is a factor in causing more large scale fires, this is doubly disturbing, because these fires also release huge amounts of carbon into the air. More carbon in the atmosphere accelerates climate change, which scientists believe will lead to even hotter, drier weather, which will lead to more intense and more destructive fires. This article from Berkeley News summarizes the findings of a study conducted by the National Park Service and UC Berkeley.

Wildfires Emit More Greenhouse Gases than Assumed

Watching thick, dark smoke billow across the sky on Saturday was scary. But what’s even scarier is what will happen in the years to come if the scientists are right. The evidence has been mounting for years that our addiction to fossil fuels will cause irreversible damage to the planet. We’ve made some progress on reducing greenhouse gas emissions in California, but we need to do a lot more. Otherwise our skies, and our future, will continue to grow darker.

A view of the sky from Riverside Dr. on Saturday.

A view of the sky from Riverside Dr. on Saturday.