Beruflich Dokumente
Kultur Dokumente
org
adam.villani@lacity.org
Raymond Klein
Raymond Klein
Secretary
Board of Directors
Brentwood Homeowners Association
copies to:
Page 2 of 33
ADDENDUM
Page 3 of 33
Deficiency: This is misleading and deceptive because the student population should
infrequently be at 518. Since no increase in enrollment is part of the Project, current
CUP Condition No. 6 would continue to control and states, the targeted baseline
enrollment is 450, and 518 is not intended to be reached.
Further, the statement is deficient because there is no explanation of why 132 faculty
and staff would be needed to accommodate 518 students when the 11/7/2007 traffic
count shows 79 faculty and staff for 500 students at that time.
The NOP and DEIR are misleading and deficient throughout, whenever they state 518 is
the permitted enrollment. The DEIR is deficient in not clarifying if the current
enrollment condition cited above will be retained.
Page 5 of 33
Page 6 of 33
Deficiency: This table is misleading and deficient because it does not disclose how
many of the competitions overlap and occur on the same day, thereby multiplying the
traffic impact.
Page 7 of 33
Page 8 of 33
7:30 a.m. to 6:00 p.m., Monday through Friday for class instruction,
6:00 p.m. to 7:30 p.m., Monday through Thursday for athletic practice,
6:00 p.m. to 7:30 p.m., Monday through Thursday for competitions/other
schools (notice to neighbors required),
6:00 p.m.to 9:00 p.m., Fridays for athletic practice,
6:00 p.m. to 9:00 p.m., Fridays as needed for competitions/other schools
(notice to neighbors is required),
10:00 a.m. to 9:00 p.m., Saturdays for athletic practice and,
10:00 a.m. to 6:00 p.m., Saturdays as needed for play offs (notice to neighbors
required).
No gymnasium use is permitted on Sundays with exception of 3 admissions
open houses between the hours of 12:00 p.m. to 5:00 p.m. (notice to the
neighbors is required) or national holidays.
7:40 a.m. to 6:00 p.m., Monday thru Friday, with a limitation of 100 students at
one time,
6:00 p.m. to 7:00 p.m., Monday through Friday for athletic practice.
Saturday use is limited to 4 days a year with a 4 hour period between 10 a.m.
and 6 p.m. for a school use within the established school program. No
activities of any kind [e.g., setting up, deliveries, warm ups] shall take place on
the field prior to 9 a.m. Within the 4 hour period limit, the 4 Saturday uses shall
permit practices between the hours of 9 a.m. and 6 p.m., as
needed, and competitions/other schools with a goal of being played between
the hours of 3:30 p.m. and 6 p.m. Notice to the neighbors is required for
competitions/other schools.
Athletic use is not permitted on Sundays or national holidays, with the
exception of Columbus Day and Veterans Day when those days are used as
regular school days.
Page 9 of 33
Page 10 of 33
Page 11 of 33
Event Name
Time/Day
Parked Cars On Site
Approximate Attendance
Permitted Maximum Attendance (on 15 Events)
The information in the table on pages 1-3 may be an interesting additional disclosure of
Archers experience with Special Events during a recent year, but full disclosure of
impact requires a direct comparison of the current CUP Special Events table with the
same information in a table for the Projects proposed 98 School Functions. The new
name may be an attempt to enhance palatability, but also causes confusion, as they
remain non-curriculum Special Events.
Page 12 of 33
p.m. 7:00 p.m. This information is necessary for a decision maker to estimate whether
the potential net new trips from the proposed Project from the aggregate of all
additional activities during the weekday PM peak traffic hours is 20,000 or 30,000, or
some other number. This omission must be rectified and the DEIR re-circulated.
Deficiency: The entire analysis is grossly deficient because the scenarios and time
periods analyzed are incorrect, inadequate, deficient, and defy common sense.
Instead of 37 Special Events during weekday hours 3:00 p.m. to 7:00 p.m., Archer
proposes an increase to 69 Special Functions (and that doesnt include 10 proposed
Interscholastic Athletic Tournaments hosting 200 guests each). Of those 69 Events, 24,
instead of the current 20, would have a proposed attendance of 100, and 26, instead of
the current 14, would have a proposed attendance of 200.
This intensified use and resulting environmental impact must be included in the event
day analysis. It takes very few trips to significantly impact Sunset/Barrington and the
omission of these proposed, additional 16 Events makes the analysis deficient.
The omission is magnified when proposed athletic competitions are added to omitted
Events.
The analysis fails to study departures between 6:00 p.m - 7:00 p.m. from athletic
competitions or school functions.
The analysis fails to study athletic competitions with arrival times between 6:00 p.m 7:00 p.m.
The analysis fails to study all the Events during weekday hours 3:00 p.m. 7:00 p.m.
with attendance of more than 300 (7 proposed instead of 1 as currently).
The deficiency of the analysis is not remedied by the possibility that LADOT has
consented to a deficient analysis.
Page 15 of 33
Page 16 of 33
were based on eastbound numbers and eastbound capacity, it is likely that each Sunset
intersection LOS would be much worse. And the number of cars going eastbound that
would create a significant impact would be much fewer.
Deficiency: The entire analysis of Table 3 and the EIR is deficient because it is
executed by combining proposed athletic competitions and proposed school functions.
In order for a decision maker to be able to determine whether to approve the
construction and use of athletic facilities, the impacts of the proposed athletic
competitions must be analyzed separately from the impacts of proposed school
functions, which would use different proposed facilities. Archer Forward is not an all or
nothing proposal. For example, a decision maker might consider approving the
proposed increase in Special Events, but no increase in athletic competitions, and must
be able to discern the impacts of that choice.
Page 18 of 33
Document Reference: DEIR Appendix P-1, page 24, Table 3; and page 27 (net new
trips data)
Document Citation: See Previous Table and Net New Trips Data
Deficiency: In January 2014, Archer advised community organizations that the
proposed 177 athletic competitions would generate at least 9,100 guests per school
year during weekday peak PM traffic hours, and 4,400 guests at school functions during
the same hours. These numbers must be converted into vehicle trips in and out. And a
higher ratio than 1.5 guests per car must be used for afternoon athletic competitions
when parents will be arriving separately from different locations. Only then can it be
determined whether there is a consistency between the information being provided.
Page 19 of 33
Page 20 of 33
Deficiency: The traffic analysis and EIR are deficient because it is obviously a gross
error to blindly use these intersection criteria without recognizing that eastbound traffic
on Sunset Blvd during weekday PM peak traffic hours is more than double the traffic
going westbound. Hence, the number of vehicles having a significant impact is far less if
the lack of capacity going eastbound is studied rather than studying an average of both
directions.
Page 21 of 33
Page 22 of 33
Page 23 of 33
an intersection now rated F will be an F after the Project. But if the information
discloses that a one-mile segment of Sunset Blvd that now takes one hour during PM
peak hours will take an hour and a half after the Project, then the decision maker has
the necessary information that should be in an EIR. Without this information, the traffic
study and the EIR are legally deficient.
3:00 PM to 4:00 PM, Monday through Friday Arrival Limit the number of
vehicles generated by guests arriving at the Archer Campus to attend
school functions and interscholastic athletic competitions to no more than
72 vehicles.
5:00 PM to 6:00 PM, Monday through Friday Departure Limit the number of
Page 25 of 33
vehicles generated by guests departing from the Archer Campus after attending
school functions and interscholastic athletic competitions to no more than 72
vehicles.
Deficiency: This proposed limit on only the number of vehicles arriving 3:00 p.m. 4:00
p.m. and departing 5:00 p.m. 6:00 p.m. is a meaningless number without describing
the arrivals for school functions and interscholastic athletic competitions between 5:00
p.m. 6:00 p.m and between 6:00 p.m. 7:00 p.m. It is misleading, deceptive and
inaccurate to describe such limits as being capable of reducing or eliminating eventrelated significant impacts. Throughout its history, the Schools Permit has included an
Exhibit listing the number of Special Events, the days and hours of those Events, the
number of cars that may be parked on-site for each Event, and permitted attendance at
each Event (including faculty and staff). This Special Event Exhibit has been amended
several times. The EIR is legally deficient without a new Exhibit of proposed Special
Events (school functions) in the same format as the current Permit Exhibit that would
give the public and a decision maker the ability to compare the use of the proposed
physical additions to the campus with the use currently permitted on the existing
campus. A similar comparison must be included in the EIR of (A) current interscholastic
athletic competitions occurring on campus, days and hours, and spectator and other
non-Archer attendance, with (B) proposed competitions on campus, days and hours,
and spectator and other attendance. Otherwise, a decision maker has no way of
determining the impacts of the proposed physical additions to the campus, and no way
of determining the conditions and limitations that should be imposed (on the physical
additions, or on the use of those physical additions, or both).
between the hours of 8:00 A.M. and 10:00 P.M., Monday through Saturday.
Deficiency: The DEIR is deficient in that it fails to describe or analyze in greater detail
the noise and traffic effects of the 24 days of leasing of facilities as described in the
above passage. There is no reference to vehicle restriction and therefore we must
assume a maximum of 282 vehicles will enter and exit the campus, resulting in an
additional 13,536 car trips.
Page 27 of 33
Page 28 of 33
Page 29 of 33
Page 30 of 33
Page 31 of 33
The DEIR is faulty and deficient because it does not analyze adverse and significant land
use compatibility and consistency impacts due to the proposed change to school use of
properties that have always been zoned and used for residential use. Changing the
permitted use of residential properties by way of a CUP from residential use to school
institution use would have a unique set of impacts that must be studied, including
visual, noise, and traffic impacts. It is a matter of common sense that a homeowner will
have a different viewpoint if a residence is constructed on an adjacent lot compared
with the construction of a school institution on the adjacent lot. Given the density of the
regional area, assumptions of annual traffic growth eastbound on Sunset Blvd are
significantly understated for the weekday peak PM traffic hours 3:00 p.m. - 7:00 p.m.
All construction of Sunset and Wilshire ramps are complete and the congestion
eastbound on Sunset Blvd during weekday peak PM traffic hours 3:00 p.m - 7:00 p.m is
as bad as ever. Any assumption that the final few months of the 405 project will lessen
that congestion is faulty and deficient.
The DEIR is faulty and deficient because the impacts of the Metro BRT project on
Wilshire Blvd are not studied. A few years ago, a trial of dedicated bus lanes that
removed 1/3 of the eastbound capacity had to be shut down because the LADOT
found and stated in writing, among other reasons, it caused traffic to be diverted off
Wilshire and north onto residential streets in Brentwood. The Wilshire BRT project is
underway, and was approved by Metro and City Council because the diversion off
Wilshire (they were told by LADOT) would not occur this time because an extra lane
would be added by narrowing the sidewalks and widening Wilshire. However, current
plans do not include narrowing the sidewalks and widening Wilshire between
Barrington and Federal. In addition, eastbound traffic on Wilshire coming from Santa
Monica (which will not have bus lanes) will run up against a loss of 1/3 of the roadway at
the L.A. border at Centinela. It makes only common sense that some Santa Monica
traffic will get off Wilshire and come north to Sunset. All these impacts must be studied.
The DEIR is deficient because it does not analyze for a decision maker and the public
what would be REASONABLE objectives as opposed to MAXIMIZED objectives. The
description of Project Objectives starting on page II-13 describes Archers desire to
maximize every aspect, and the DEIR needs to study the impacts of a reasonable
Project.
Page 32 of 33
The DEIR is deficient because it does not study and disclose the greater traffic impacts
from athletic competitions and special events that overlap at the same time, or follow
one another, such that guests will be coming and going during the same hour.
The DEIR is deficient because it does not analyze for a decision maker and the public
the impacts related to each separate requested addition to the physical plant and use
of each requested addition to the physical plant. It is unlikely that a decision maker will
make an all or nothing decision. Therefore, the impacts must be separately studied for
each major element of the Project. For example, the impacts of an addition to the
North Wing may be minor, but the impacts of adding a Performing Arts Center may be
major, and decisions cant be made if the only impacts studied are from the entire
Project as a whole.
- end -
Page 33 of 33