Dear Editor,
The proposed Bergamot Transit Village (BTV) is big enough to cause “significant and unavoidable” impacts to much of the Santa Monica/Venice/West LA area. Its impacts, however, are far less than those of other projects which could be developed “by right” without any development agreement (DA) or negotiated community benefits.
As a multi-decade veteran working in creative office space, I know how much office space is allocated for each worker. It’s far from the 286 square feet (sf) used in the BTV Environmental Impact Report (EIR). Based on current research, it’s 75-100 sf. This figure does include kitchens, conference rooms, hallways, and other common and service areas. This difference affects all traffic and other impacts as we need to allow for nearly 4 times the number of workers in commercial office space.
The DA for BTV addresses this issue in the area of traffic and parking. The agreement includes peak-time “trip caps” based on numbers in the EIR. This means that if the project houses 5000 workers, as I believe it would, the number of trips must match the project counts for 1313 workers, as used in the EIR. Parking is addressed by prohibiting workers who drive to work and do not use on-site parking from parking closer to the project than 2 miles away. The fines for violating either of these constraints are very significant. Therefore, we can assume only 6,807 daily trips, and negligible parking impacts from the proposed project.
Because the alternative projects do not require DAs, we have no such caps or parking guarantees.
I analyzed the BTV EIR to determine how the trip counts are calculated. The following formulas determine the number of daily trips:
— Commercial office space – 2.5 trips/worker
— Studio-1 bedroom apartments – 3.19 trips/unit
— 2-3 bedroom apartments – 5.45 trips/unit (27 percent of units are 2-3 bedroom apartments)
The number of workers is the amount of office space divided by the number of sf/worker. In the EIR, it’s 286. (The EIR uses a “Daily Rate” to calculate the number of daily trips from the space allocated for commercial office use. That value incorporates the number of trips/day and the number of sf/worker. The daily trip count is used as the base for all other traffic calculations.) Here, I will include calculations for 75 and 100 sf/worker.
The EIR includes “Alternative 2” as the maximum project which could be built under the existing zoning without requiring a DA. This project is 310,000 sf of commercial office, no residential space, no new streets, and no increase to the 600 existing surface parking spaces. The project would house 3100-4133 workers, increasing the number of daily trips by 7,750-10,332.
The staff report includes financial analysis for a LUCE Tier 1 project which could be built without a DA or administrative review. The EIR does not include this project. The project includes 408,000 sf of commercial office, 179 housing units, and 1,373 parking spaces. The project would house 4080-5440 workers. Daily traffic impacts would be:
— Commercial office space – 10,200-13,600 trips
— 131 studio-1 bedroom units – 418 trips
— 48 2-3 bedroom units – 262 trips
Total: 10,880-14,280 trips
As the analysis shows, the traffic impact caused by projects which can legally be built without community benefits can exceed twice that of the project approved by the City Council.
Neither of these alternatives would require new streets to connect Expo to the area north of Olympic, necessary to activate the Bergamot Area Plan and to achieve the long-term goal of overall trip reduction. If people cannot easily get to the Expo station, they’re not going to use it. Lack of this connection could harm Santa Monica for generations.
I remain concerned about the challenge associated with the trip caps and parking restriction in the approved project. As noted above, the trip caps will force the daily trip count not to exceed 6807. The EIR assumes that 375,585 sf of commercial office space will house 1,313 employees and account for 3,275 trips. That amount of space is expected to house 3,756-5,007 workers and account for 9,390-12,517 trips. It will be very hard to meet the target in the DA. The proposed project reduces commercial office space to 374,434, a negligible difference. It also includes 1,927 parking spaces, causing a significant challenge.
To simplify the challenge and allow for flexibility in the near future, I would like an explicit pause in the construction. First, the parking should be built. Then, the residential component should be built and occupied. This should be followed by the western of the commercial office buildings. It should be occupied long enough to ascertain its true population and impact. After the impacts are understood, the best use of the fifth slot can be determined. The optimal use may be residential, retail, possibly urban big box, commercial office, open space or a combination. Because of the risk associated with the trip cap penalty, the developer should welcome this suggestion.
Valerie Griffin
Santa Monica
