MEMORANDUM. Mr. Sean Tabibian, Esq. Dana A. Sayles, AICP, three6ixty Olivia Joncich, three6ixty. DATE May 26, 2017

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MEMORANDUM TO FROM Dana A. Sayles, AICP, three6ixty Olivia Joncich, three6ixty DATE VIA Email RE 3409 W. Temple Street, Los Angeles, CA 90026 Zoning Analysis and Entitlement Strategy three6ixty (the Consultant ) has completed the initial research for three properties, located on 3401-3415 W. Temple Street in Los Angeles, California, 90026: APN 5156-002-011 ( Property 1 ) APN 5156-002-004 ( Property 2 ) APN 5156-002-001 ( Property 3 ) The following memorandum provides detailed information regarding the zoning and land use criteria of all three properties (the Site ). (the Client ) wishes to understand the development potential of the three adjoining properties (the Subject Property ). This memorandum also incorporates additional information about the Subject Property provided by the Client in the form of topographical survey dated May 7, 2017. It is understood that this initial memo is based upon internal research only, and all future project specifications may require verification by staff planners. No physical consultation with any City staff were performed as part of this research. SUBJECT PROPERTY The Subject Property is located within the boundaries of Council District 13, within the purview of Councilmember Mitch O Farrell, and the Rampart Village Neighborhood Council area.

3409 W. Temple Street Memorandum Page 2 of 10 The Subject Property consists of three adjoining legal lots of various sizes, comprising an approximately 19,908 square foot, or 0.46 acre, triangle-shaped sitea (according to City of Los Angeles ZIMAS, indicated in Map A). The Subject Property is bounded on the southwest side by Temple Street, on the north side by Silver Lake Boulevard and on the southeast side by Micheltorena Street. The site is currently improved with one 3,286 square foot building constructed in 1953 (according to Los Angeles County Assessors Records). The Subject Property is not classified as historically significant per public records. A full profile of each parcel is included as Attachment A. MAP A. SUBJECT PROPERTY & CURRENT ZONING BUILDING PERMIT & CASE HISTORY The following building permit summary provides a chronological history of all publically available records of development on the Subject Property. A full appendix of the building permits and certificates of occupancy is included as Attachment B. A The topographical survey provided by the Client cites the total area of the Subject Property as 19,508 square feet. As the site abuts a portion of a parcel to the north that is considered Public Facilities, three6ixty recommends that the Client pursue a subsequent boundary survey to determine any existing public easements or dedications, and the total area of the site.

Page 3 of 10 o Building Permit No. 1920LA24582, issued December 14, 1920, for the new construction of a one-story, 5-bedroom single family dwelling located at 3401 W. Temple Street. o Building Permit No. 1928LA16047, issued June 6, 1928, for an alteration to a family dwelling located at 3401 W. Temple Street. Additional remarks state that no street widening was required. o Building Permit No. 1932LA00865, issued January 15, 1932, for the relocation of the single family dwelling located at 3401 W. Temple Street to the rear of the lot to permit the excavation of Temple Street. Additional notes state that the house was to be moved forward and reset as is. The widening of Temple Street does not go west of Park View Street, no widening was to be performed at Micheltorena Street. o Building Permit No. 1953LA72137, issued October 23, 1953, for the new construction of a one-story office and equipment storage building located at 3405-3415 W. Temple Street. o Building Permit No. 1953LA72753, issued November 10, 1953, for the addition of concrete block fills to a one-story office and equipment storage building located at 3505-3415 W. Temple Street. o Building Permit No. 1953LA73040, issued November 23, 1953, for the change in construction material from masonry to wood for a one-story office and equipment storage building located at 3405-3415 W. Temple Street. o Building Permit No. 1956LA43943, issued May 23, 1956, for the addition of a 10- foot by 6-foot heater room to a one-story office and equipment storage building located at 3405-3415 W. Temple Street. o Building Permit No. 1962LA09340, issued May 9, 1962, for a one-story, 26-foot by 32-foot addition to an existing one-story office and equipment storage building located at 3409 W. Temple Street. The permit includes a highway dedication along Temple Street. o Building Permit No. 1972LA61385, issued November 16, 1972, for the demolition of all structures located at 3401 W. Temple Street. o Building Permit No. 1980LA95848, issued January 4, 1980, for a one-story addition to an existing office building creating a 44-foot by 73-foot irregular building with 13

Page 4 of 10 required parking spaces located at 3409 W. Temple Street. o Building Permit No. 1980LA01455, issued April 16, 1980, for relocation of an existing driveway from Temple Street to Micheltorena Street and a small structural change to an existing office building located at 3405-3415 W. Temple Street. o Certificate of Occupancy No. 1959LA28939, issued July 22, 1959, for a one-story single family dwelling, located at 3401 W. Temple Street. o Certificate of Occupancy No. 1980LA01455, issued August 6, 1981, for three onestory additions to an existing building creating a 44-foot by 73-foot irregular building with 13 required parking spaces located at 3401-3411 W. Temple Street. o Grading Permit No. 1980LA95847, issued January 4, 1980, for the construction of a parking lot and clearance underneath existing building located at 3409 W. Temple Street. PROPERTY ZONING & LAND USE INFORMATION The Subject Property is currently zoned R4-1VL and C2-1VL. Ordinance 165,167, enacted in 1989, established a change in zoning from C2-2 and R4-2 to C2-1VL and R4-1VL, respectively (Excerpts relevant to the Subject Property from Ordinance 165,167 are included as Attachment C). The site is concurrently designated for Community Commercial land uses by the Silver Lake Echo Park Elysian Valley Community Plan. The Subject Property has also been identified within the boundaries of the Vermont / Western Transit Oriented District Specific Plan, also known as the Station Area Neighborhood Plan (the Vermont / Western SNAP ). The Subject Property is on the easternmost border of the Industrial / Commercial Subarea or Subarea D. Subarea D is bordered by the Hollywood Freeway to the north, Hoover Street to the east, Juanita Avenue to the west and 1 st Street to the south. Map B illustrates the inclusion of the Subject Property within the boundaries of the Vermont / Western SNAP Subarea D (The complete Vermont / Western SNAP is included as Attachment D). Subarea D promotes light industrial and commercial uses by applying the use and area standards provided by the Commercial Manufacturing (CM) zone, per LAMC 12.17.1. While a portion of the Subject Property is zoned R4 for high density residential uses, the inclusion of the entire site in Subarea D of the Vermont / Western SNAP implies that all residential, hotel and motel uses are prohibited throughout the entire site. A comprehensive list of uses permitted in the Commercial Manufacturing Zone is included as Attachment E.

3409 W. Temple Street Memorandum Page 5 of 10 By-right projects located in the Industrial / Commercial Subarea D must comply with all development standards associated with the underlying zoning in addition to the standards and uses established by the Vermont / Western SNAP. Table A provides a summary of the development standards pertaining specifically to the site. TABLE A. EXISTING DEVELOPMENT STANDARDS STANDARDSA C2-1VL R4-1VL SNAP Setbacks None Required None Required Maximum FAR 1.5:1 FAR 3:0:1 FAR A minimum of 75% of all building frontages must be located 10 feet or less from the property line Defers to underlying zone Maximum Height 45 feet 45 feet, 3 stories Defers to underlying zone A Standards are assumed for a commercial or industrial building, as residential uses are prohibited. MAP B. VERMONT / WESTERN SNAP SUBAREAS ZI-2542 Transit Priority Area in the City of Los Angeles The Subject Property is located within a Transit Priority Area in the City of Los Angeles. Transit Priority Area is defined as an area within one-half mile of a major transit stop that is existing or planned. A major transit stop is defined as a rail transit station, ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the

Page 6 of 10 morning and afternoon peak commute periods. The Project is exactly one half mile from the Vermont / Beverly Metro Light Rail Station, and therefore qualifies as a Transit Priority Area under ZI-2542. Under ZI-2542, aesthetic and parking impacts shall not be considered an impact subject to mitigation under the California Environmental Quality Act (CEQA) for all residential, mixed-use residential, and employment center projects in Transit Priority Areas. However, all applicable standards for evaluating parking or aesthetic impacts may be imposed by relevant specific plans, design guidelines, or zoning overlays. ZI-2427 Freeway Adjacent Advisory Notice for Sensitive Uses As the Subject Property is located directly adjacent to the Hollywood Freeway, it is addressed by ZI 2427 Freeway Adjacent Advisory Notice for Sensitive Uses. The Advisory Notice is informational in nature and does not impose any additional land use or zoning regulations. It is intended to inform applicants of the significance of this issue for the City Planning Commission. Several recommended approaches are provided by the City to assist property owners and developers in navigating through this complex issue. However, applicants need not adhere to any one particular method for addressing air quality impacts on a particular project. Project design features or conditions may be tailored to individual projects as deemed appropriate, but the notice does not impose any additional regulations on development projects. The full text of Zoning Information No. 2427 is included as Attachment F. ZI-2374 Los Angeles State Enterprise Zone The Site is located within the Los Angeles State Enterprise Zone. This zone provides economic incentives to stimulate local investment and employment through tax and regulation relief and improvement of public services. Projects located within a State Enterprise Zone are afforded certain incentives for development related to reduced parking for commercial/retail uses, and a waiver of Site Plan Review entitlement fees, if required. This zoning designation will not impose additional development standards or mandatory requirements on projects proposed on the Subject Property, but may be considered during future development processes on the Site. HIGHWAY DEDICATIONS Temple Street, a designated Avenue II, requires a full right-of-way width of 86 feet and a half right-of-way width of 43 feet. The north half of Temple Street, which abuts the Subject Property to the south, is currently dedicated to varying widths of 80 to 86 feet. Future dedications are anticipated to range from 1 to 3 feet.

Page 7 of 10 Silver Lake Boulevard, a designated Avenue II, requires a full right-of-way width of 86 feet and a half right-of-way width of 43 feet. The southeast half of Silver Lake Boulevard, which abuts the westernmost point of the Subject Property to the north, is currently dedicated to a half right-of-way width of 40 feet, requiring an anticipated 3-foot dedication and corner cut. Micheltorena Street, a designated Standard Local Street, requires a full right-of-way width of 60 feet and a half right-of-way width of 30 feet. The east half of Micheltorena Street, which abuts the Subject Property to the west, is currently dedicated to a half right-of-way width of approximately 30 feet and no future dedications are anticipated. (Note: All information regarding street dedications has been determined from public records and must be verified with the City of Los Angeles Bureau of Engineering). RELATED PROJECTS An complete analysis of the Subject Property includes an examination of the current improvements on surrounding properties, as well as development proposals that may alter land use determinations on the site. Review of the surrounding properties revealed an application for the development of a residential apartment building directly across from the Subject Property, at 235 North Hoover Street. Titled Pinnacle 360, the proposed project includes the construction of a 261,184 square foot building containing 221 residential units. Pinnacle 360 is located within Subarea B Mixed-Use Boulevards of the Vermont / Western SNAP, permitting both residential and commercial uses by-right. The existence of strictly residential development within such close proximity demonstrates the appropriate nature of similar porjects in the area and may support future entitlement requests to permit residential, mixed-use, or hospitality oriented proposals on the Subject Property. By demonstrating that the area is not only conducive to residential development, but also experiencing the imminent expansion of residential uses in the surrounding community, an entitlement application for habitable uses may be more amenable to approval by the City. Pinnacle 360 may be leveraged as evidence of the anticipated demand for additional residential or hospitality uses in this particular location. Future entitlement applications for the site should recognize the direction and climate of adjacent development, and present project proposals that tangibly contribute to a compatible synergy of uses. A brief description and case information for the Pinnacle 360 project is included as Attachment G.

Page 8 of 10 TABLE B. ZONING SUMMARY By-Right Per the SNAP With Application for Entitlements C2-1VL A / R4-1V (DB-SPE) Lot Area 19,908 SF 19,908 SF Net Lot Area * 19,473 SF 19,473 SF Floor Area Ratio 1.5:1 3.0:1 2.31:1 Maximum Floor Area 24,819 SF 9,213 SF 45,943 SF B Height Stories Setbacks Front on Temple St Side on Silver Lake Blvd A Side on Micheltorena St Density 11% VLI Set Aside 20% LI Set Aside 45 ft 3 stories 0 ft for commercial / industrial None Required at Commercial Level 25 units (base density) TOTAL * Subject to verification by Project architect or survey. Gross lot area less required dedications. A. Assumes proposal of a mixed-use building with ground floor commercial space. B. With incentive for averaging and 35% FAR bonus. C. With incentive 11 feet of additional height. DEVELOPMENT SCENARIO 1: BY-RIGHT Given the current application of the Vermont / Western SNAP, the Subject Property only permits by-right commercial and industrial development. A development application on the site would not require an application to the Department of City Planning, if designed to comply with all applicable development standards summarized above and illustrated in Attachment F: Zoning Analysis Spreadsheet. Due to the spatial constraints imposed by the shape, orientation and limited size of the Subject Property, proposed commercial developments should utilize the reduced parking requirements offered by the provisions of ZI-2374 Los Angeles State Enterprise zone, permitting the minimum allocation of two spaces per 1,000 square feet of gross floor area. Parking calculations for a hypothetical commercial development are also included in Attachment H. 56 ft C 0 ft for commercial / 15 ft for residential 5 ft + 1 ft for every story after 2nd 3 VLI units 5 LI units 34 units

Page 9 of 10 DEVELOPMENT SCENARIO 2: SPECIFIC PLAN EXCEPTION In order to expand the development potential on the Subject Property to include multi-family residential or mixed use developments, three6ixty may recommend the following entitlements. It is understood that this scenario is proposed, and must be confirmed via consultation with Vermont / Western SNAP staff planners to ultimately determine the City s support for residential or hospitality uses on the Subject Property. 1. Specific Plan Exception Pursuant to LAMC Section 11.5 7 F (1)(d), a Specific Plan Exception request to grant relief from Section 10.A of the Vermont / Western Station Area Neighborhood Plan permitting residential uses and area standards in accordance with the C2-1VL and R4-1VL zones. In requesting a Specific Plan Exception, the Subject Property may accommodate residential/mixed-used, or hospitality development per the C2-1VL zone that applies the underlying development standards dictating density, setbacks, and floor area. This request is subject to approval by the City Planning Commission upon the determination that the request satisfies the applicable findings. Given that the underlying C2 and R4 zoning and Community Commercial land use support residential or mixed-use development, the Specific Plan Exception will alleviate the burden of exceptional circumstances imposed by the Vermont / Western SNAP on the Subject Property. Additionally, the exception of the residential prohibition on the Subject Property is consistent with the zoning patterns to the east and south, which is predominantly residential and commercial. 2. Density Bonus Pursuant to LAMC Section 12.22 25, a density bonus request for a 35% increase in density. a. On-Menu Incentive for Averaging of Floor Area Ratio (FAR): The underlying R4-1VL zone permits a maximum FAR of 3.0:1 and the C2-1VL zone permits a maximum of 1.5:1. By applying a weighted averaging across both zones (based on the proportion of the site with each corresponding FAR), proposed projects may apply a base FAR of 1.71:1. b. On-Menu Incentive for Increase in Floor Area: By achieving a higher base FAR across the entire site, the project may apply for a second incentive for a 35% increase in FAR, resulting in a total maximum FAR of 2.31:1. By pursuing a density bonus, the residential development potential on the Site may be substantially expanded. A proposed project utilizing a 35% density bonus and an incentive for FAR averaging would allow the project to achieve an increase in Floor Area Ratio (FAR) to 2.35:1 FAR, resulting in an approximate maximum floor area of 45,943 square feet. The Site is not within 1,500 feet of major transit, per Los Angeles Municipal Code 12.22.A.25, so it is not eligible for an on-menu FAR incentive of 3.0:1 via the City s Density Bonus ordinance.

Page 10 of 10 However, the Site is exactly one half mile from the Vermont / Beverly Metro Station, which qualifies as major transit and is eligible for reduced parking requirements per Assembly Bill 744. Future projects may also utilize the density bonus to request additional incentives to allow for more flexible development standards and greater project potential. With the Specific Plan Exception, Development Scenario 2 permits residential or mixed-use development as depicted in Table B and Attachment H: Zoning Analysis Spreadsheet. Please call me at your convenience at (310) 204-3500 if you would like any further information about the information contained in this Memorandum. Sincerely, three6ixty Dana A. Sayles, AICP ATTACHMENTS Attachment A: Parcel Profile Reports Attachment B: ORD 165,167 - Zone Change Attachment C: Building Permit Records Attachment D: Vermont / Western Station Area Neighborhood Plan Attachment E: CM Zone Use List Attachment F: Zoning Information No. 2427 Attachment G: Pinnacle 360 Project Description Attachment H: Zoning Analysis Spreadsheet