HHA responds to the Draft of the Hollywood Community Plans Draft Environmental Impact Report

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HHA responds to the Draft of the Hollywood Community Plans Draft Environmental Impact Report.

 

 

January 25, 2019

City of Los Angeles Department of City Planning
Linda Lou, City Planner
200 N. Spring Street, Room 667 mail stop 395
Los Angeles, CA 90012
Email: linda.lou@lacity.org

RE: HCPU2, DEIR ENV-2016-1451-EIR

SCH N0.2016041093

Dear Ms. Lou and City Planning Officials,

We wish to respond to the DEIR of the draft Hollywood Community Plan–HCPU2. The Hollywoodland Homeowners Association (HHA) is the organization which solely represents the hillside residential (R1) community known as “Hollywoodland” (Tract 6450) and its 575 homeowners. We are advocates for the preservation of Hollywoodland property values and overall safety in our neighborhood.

As such we are concerned with how DEIR project objectives to preserve low density and single family residential neighborhoods, provide adequate infrastructure, maintain land use and zoning consistency can be met while meeting the additional objectives of promoting the vitality and expansion of Hollywood’s entertainment and tourism industry especially due to the fact that our community abuts the iconic Hollywood Sign.

HCP RELATIVE TO HOLLYWOODLAND (TRACT 6450)

Hollywoodland, established in 1923, is one of the oldest planned hillside communities in Los Angeles.  Understanding the distinctive design and architectural characteristics of Hollywoodland, the neighborhood, Council Office and City planning worked for five years to develop a Specific Plan (established 1992) to insure development of lots within the community would remain consistent with the characteristics of this unique hillside area. (Ordinance 168,121).

Today, the Hollywoodland community is under siege by elements that have created chaotic conditions in our single family hillside neighborhood, directly affecting the environment.  From lack of code enforcement to unsanctioned development of park entry points and Hollywood Sign tourist viewing areas; public safety is put in jeopardy every day. Hollywoodland’s fragile 1923 infrastructure is filled with winding, narrow, blind curve, dead ended streets with no turn-arounds and limited parking/sidewalks, –substandard even by hillside standards. Hollywoodland is also in a very high fire severity zone that unlike any of the other surrounding communities, is 80% surrounded by dry brush parkland making this area not only extremely vulnerable to fire, but also making the possible cutoff of the entire neighborhood in the event of a wind driven fire a strong possibility. With very limited ingress and egress, dangerous conditions are made infinitely worse due to tourism/park traffic intrusion and gridlock.

Couple this complexity with development which disregards both current zoning and Specific Plan requirements: Questionable C of O’s on projects that do not fulfill off street parking requirements push more parking on already crowded streets (6096 Rodgerton), unpermitted additions for the purpose of short term rentals (6080 Rodgerton); new builds that go for years without C of O all the while be rented out for party’s and short term rentals (6075 Rodgerton) or homes owned by foreign nationals set up as commercial drug rehab ventures in the middle of this R1 hillside community (6100 Rodgerton) further degrade safety in this designated high fire severity zone. (All these sites have been reported to the authorities with little recourse)  When planning and safety laws are not followed the burden rests on the city.

Without enforcement a plan is cannot be effective, zoning is a mere suggestion.  Safety for law abiding citizens does not exist.   How will the city assure planning approvals are enforced for the new HCP when they are failing currently?

Effectively, the city of Los Angeles has altered our historic residential community by making it an unauthorized entertainment zone for park use and Hollywood Sign Tourism — all with no process, plans or studies.  These illegal alterations and zone changes are in violation of our Specific Plan, the General Plan Framework and the Hollywood Community plan.  We request that the laws be strictly adhered and the illegal actions corrected.  We want Hollywoodland restored to its R1 residential status.  Nothing in the 1988 HCP supported a change in community character, zoning and use.  This is a violation of the plan.

Areas to be addressed under the new HCP include but are not limited to the following:

  1. Hollywood Sign viewing areas outside of residential zones, park access only in areas that have the infrastructure to support the volume and requirements of visitors
  2. All the destroyed historic walls and infrastructure compromised by excessive tourist/hiker traffic and overweight tour vans must be restored the original concrete streets.
  3. Update the DEIR to include proper designation of Hollywoodland streets (i.e. remove Beachwood as a collector street)
  4. Illegal entrances of Deronda Drive, Mulholland must be closed until proper review is conducted
  5. Remove and restore with native plantings on the nonconforming pathways and the nonconforming vistas.
  6. Restore the original intent of the Lake Hollywood Park to become neighborhood park
  7. Remove and restore the nonconforming, illegal switchback and 20 space parking lot near the easement road at the terminus of Beachwood Drive and the Hollyridge bridle trail.
  8. Remove all media references to access the hiking trails and viewing of the Hollywood sign from the Hollywoodland community
  9. Restrict the commercial vehicles, (Uber, Lyft, taxis, vans, tours) that traverse through the residential streets of Hollywoodland
  10. Restore the original purpose of our substandard residential streets: to access Hollywoodland residential homes
  11. Enforce the restricted access court order at the terminus of Beachwood Drive going north at the easement road.
  12. Enforce the state fire code 49.
  13. Develop restrictions for drug rehab centers in residential communities that are immersed in a VSFHZ
  14. Accept wildlife documentation from the Hollywoodland camera trap program that substantiates wildlife corridors and behavior patterns in the residential area. Include the residential area as a SEA along with the already noted park borders.
  15. Make the Mt. Lee communication tower off limits to all non-city, non-government personnel. A portion of Mt. Lee Drive is private and should prohibit use and entry into this sensitive and vital area.

EIR DRAFT COMMENTS

4.1 Aesthetics

4.1-8  COMMENT The image of the Hollywood sign (as shown on your cover page) is a mis-representation of the Lake Hollywood Park area.  This was originally part of the Hollywoodland tract 6450, later given to the city in 1944.  It included 444 acres of open space.  In the early 1960’s When Lake Hollywood Estates was developed, the natural meadow was flattened with fill from that development’s grading.  See RAP commission files for details and planning docs. The neighborhood pocket park aka Lake Hollywood Park, has limitations in terms of use and intent.  The surrounding hillside communities are comprised of homes without flat pads and usable yards.   There are over 100 apartment houses along Beachwood Drive.  There is limited parking and narrow, winding substandard streets from the Beachwood approach.  The intent and purpose of the park is/was to serve the immediate community not to be a tourist destination, gathering spot.  The adjacent two, bootlegged “vistas” (on both sides of the park) are nonconforming installations without any approvals, budgets or authorizations by any city departments. There is fact verification through photos and staff statements indicating the non conformance.  Government must be held to the same standards as the people it governs.  Please, recognize the purpose and intent of this area and assist the adjacent communities with administering proper, safe use, removal and restoration of nonconforming elements.  Please, encourage key departments to retain the residential status and discourage the promotion and nonconforming re-characterization from residential to recreation/commercial zoning.  Your plan should also be an advocate for a visitor tourist center outside of all residential communities abutting Griffith Park open space.

4.1-8 The City’s General Plan Conservation Element defines scenic views or vistas as the panoramic public view access to natural features, including views of the ocean, striking or unusual natural terrain, or unique urban or historic features. Public access to these views is typically from parklands, publicly-owned sites, and public rights-of-way.  

COMMENT It is the city’s responsibility to protect the private property in residential communities from destruction created when the public views scenic sites.  There are NO official “vista” “view” “scenic” sites in Hollywoodland, Tract 6450.  The city has bootlegged unauthorized sites that are nonconforming and have had NO public input or proper process, per LA city charter.  The city has allowed the continued promotion and use of these areas despite locations of residential homes, substandard streets, VSFHZ and SEA.  Even when citizens try to protect their private property they are admonished.  For example, a property owner close to Deronda Drive has visitors standing on his private, steep hillside property every day to view the Hollywood sign.  Concerned with liability should they fall and get hurt he planted large trees to discourage the activity.  A former city councilman recently came to the area and expressed his views against the effective trees.  Support for protection of private property should be encouraged by the plan.  Nonconforming vistas should be restored. Any public view access points must have the infrastructure to handle the intrusion.  Residents should not have to sacrifice their private property to support public access.

4.8 Hazards & Hazardous materials

Emergency Response Plans

Impact 4.8-7: Would the Proposed Plan impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

COMMENT  Hollywoodlanders are very concerned about the probability of a sweeping wild fire in our VSFHZ.  In 1961 we experienced a significant fire that burned numerous homes including writer Aldous Huxley’s ( Deronda), Etre’ s(Beachwood) and the Norman Castle at 6200 Rodgerton Drive.  Limited ingress/egress, growing Hollywood density as well as promotion of our area as an unauthorized Hollywood sign tourist destination results in gridlock on any given day. The probability of a “Paradise” type fire situation happening here is a reality today.  The HCP plan for more density in Hollywood does not adequately address current traffic congestion.  The limited egress of Hollywoodland requires that the bulk of residents evacuate

down Beachwood to Franklin. As Franklin dead ends into the 101 and is often gridlocked, evacuation would be ineffective and put residents at risk of loss, injury or death.  Give the encapsulated nature of this community, the limited alternative egress options involves miles of serpentine hillside streets that would not be a feasible option for the bulk of Hollywoodland residents.

 

Until remedies to improve current traffic flow  in this area to accommodate emergency response and emergency evacuation are implemented for current population and density requirements the proposed plan should not be considered.

Wildland Fire

Impact 4.8-8: Would implementation of the Proposed Plan expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?

COMMENT – see above.

4.15-Transportation and Traffic

Neighborhood Traffic Intrusion

 Impact 4.15-3: Would the implementation of the Proposed Plan exceed the City’s thresholds related to neighborhood traffic intrusion?

COMMENT  Yes.  The plan used incorrect BOE street width designation data to identify Hollywoodland.  It did not indicate the unusual configurations of the dead end streets going into the park (Beachwood, Hollyridge, Deronda, Mulholland).  It did not understand that essentially our neighborhood is a self contained community without throughfares.  The marketing of the Hollywood sign and park access without any official openings into the park from Hollywoodland residential has created a significant traffic intrusion.  Environmental considerations neglected include the impact on the SEA and the VSHFZ of the area.

Figure 4.15-1 shows Beachwood Dr. in Hollywoodland as a Collector Street

According to the description used in the EIR 4.15-9 “Collector Streets generally have one travel lane in each direction, with a roadway width of 40 feet and a sidewalk width of 13 feet” (total of 66 feet).  As Beachwood in Hollywoodland has a max. roadway width of 30 feet (less in some areas) and lacks sidewalks on a majority it doesn’t even qualify as a hillside collector.

(A Hillside Collector Street is described as having a 40 foot wide street with 5 feet sidewalks/set backs on each side for a total of 50 feet.)  Beachwood in Hollywoodland is closer to a hillside limited street: 28 feet wide street with 4 feet sidewalk/setback (ROW 36). As this inaccuracy was called out during the Mobility Plan process it is not clear why it has not been corrected. With so many City Planning and Engineering decisions being made on these classifications, gross errors in vehicular and pedestrian traffic flow are made leading to dangerous conditions related to fire, emergency response, evacuation etc..

Beachwood Drive is a hillside street and must be classified correctly, but it is impossible in this DEIR because it only references standard streets, 4.15-9.  It is not understood why hillside street standards are not mentioned in the DEIR as hillside streets are included. This a major flaw in the very guidelines, format, and structure of this EIR. We are requesting that this be corrected.

Beachwood Drive is included on several DEIR maps. ( Figures 4. 15-1,2,3,4,8,9,10,11) but it is not understood why others, such as Canyon Drive, a true designated collector street, having adequate width, ease of access to major roadways, full size sidewalks and parkways and has been a legal entrance into Griffith Park with built infrastructure since the 1940’s, disappears from the other maps.  What is the purpose of highlighting a substandard hillside limited street such as Beachwood when so few streets in Hollywood are highlighted including streets with much better infrastructure and park access. Upper Beachwood Drive must be immediately removed from ALL of these maps and plans so as to prevent gross errors in vehicular and pedestrian traffic flow calculations that would worsen already negatively impacted conditions existing today in our neighborhood. Beachwood Dr, is one of the most vulnerable and limited very high fire zones, Hollywoodland, must be the City’s highest priority. This is best and ONLY achieved by keeping usage low and local, rather than accommodating inappropriate volume

Thank you for the opportunity to share our comments. Can you please confirm that these have been received and will become part of the public record.  Please also include us in any notices for hearings, deadlines etc in regards to this draft EIR and the Hollywood Community Plan.

Regards,

Tara Stephenson-Fong, President, HHA

Alexa Williams, Vice President, HHA

Email: Info@hollywoodland.org