ITEM 12-B

Council Mtg:  September 26, 1989         Santa Monica, California

TO:       Mayor and City Council

FROM:     City Staff

SUBJECT:  Appeal of Planning Commission Denial  of  CUP  512,  DR
          446,  ZA  5345-Y,  EIA  872,  Located  at 2900 Wilshire
          Boulevard and 1217 Yale Street; Appellant:      Zealund
          Corporation

INTRODUCTION

Before the Council is an appeal of a Planning  Commission  denial
of  a  Conditional  Use  Permit, Site Review Permit, Variance and
Certification of an Environmental Impact  Report  to  permit  the
construction  of  a six-story, 76,483 square-foot office building
with three levels of subterranean parking and  a  two-story,  11-
unit  apartment  building with one level of subterranean parking.
This application is subject to review under the provisions of the
previous  zoning ordinance.  This matter was originally scheduled
for Council review in July 1989, but was continued at the request
of the applicant.  Staff recommendation is to uphold the Planning
Commission and deny the appeal.

SITE LOCATION AND DESCRIPTION

The subject property is a 42,500 sq. ft. parcel  located  on  the
southeast  corner  of Wilshire Boulevard and Yale Street having a
frontage of 170 feet on Wilshire Boulevard and 250 feet  on  Yale
Street.   The site is currently developed with Madame Wong's res-
taurant/club, which would be demolished to  permit  the  proposed
development.   Surrounding  uses consist of a four-story, medical
office building (C6) to  the  north;  a  one  story,  low-density
residential  structure  (R2) to the south; a two-story commercial
building and one and two-story low-density residential  buildings
(C6, R2A and R2) to the east and a single-story commercial center
and low-density residential buildings (C6, R2A  and  R2)  to  the
west.

Zoning Districts:    C4, R2A and R2

Land Use Districts:  Wilshire Corridor Commercial and
                     Low-Density Residential

Parcel Area:         C4:  170' X 150' = 25,500 square feet
             R2A and R2:  170' X 100' = 17,000 square feet
      Total Parcel Area:  170' X 250' = 42,500 square feet

PROPOSED PROJECT

The proposed project entails the  construction  of  a  six-story,
76,483  square-foot  commercial  office  building on the C4 zoned
property and a two-story, 11-unit apartment complex on the  adja-
cent  R2A  and  R2 zoned properties.  A Site Review Permit is re-
quired to permit the commercial development to exceed a height of
4  stories/56'  and a Floor Area Ratio (F.A.R.) of 2.5.  The Site
Review process permits  consideration  of  development  up  to  a
height  of 6 stories/84' and an F.A.R. of 3.0.  The office build-
ing is proposed to be six stories with a height  of  83'  and  an
F.A.R. of 3.0.

A Conditional Use Permit is required to permit the  subterranean,
commercial  parking  garage  to  extend beneath the residentially
zoned property, as provided for by previous Code, Section  9148A.
A Variance is proposed to permit encroachment of the subterranean
garage into the required four-foot unexcavated side yard  of  the
residentially zoned property, to permit 30% compact spaces and to
permit 39 surplus commercial spaces to be tandem.

MUNICIPAL CODE AND GENERAL PLAN CONFORMANCE

The project is subject to the previous zoning  code  due  to  the
date  the  application  was  deemed  complete (prior to April 29,
1988).  The proposed project is  consistent  with  the  Municipal
Code  and conforms with the quantitative standards of the General
Plan as shown in Attachment A, with the following exceptions:   a
variance  is requested to permit the 39 surplus, commercial park-
ing spaces to be tandem spaces; 30%  of  the  commercial  parking
spaces  to  be  compact  spaces; and to allow encroachment of the
subterranean parking garage into the required 4' unexcavated side
yard setbacks on the residentially zoned property.

CEQA STATUS

An Environmental Impact Report (EIR) was been prepared  for  this
project.   A 30-day public review period was conducted.  Comments
were received and the responses to the comments are  incorporated
into the Final EIR.

FEES

The commercial portion of this project is subject to the  Housing
and  Parks  Project  Mitigation Measures of the Land Use and Cir-
culation Elements of the General Plan.   The  project  mitigation
measures  may  be  satisfied  by payment of an in-lieu fee to the
City as established by Ordinance 1367 (CCS).

The residential portion of this project is subject to a Parks and
Recreation Facilities Tax of $200.00 per unit.

ANALYSIS

Project Description

The office building  features  a  recessed,  colonnaded  entrance
along Wilshire Boulevard with recessed, arched window openings at
the second level above the entrance and  recessed  window  walls.
The  third and fourth floors step back ten feet along portions of
the front facade.  The fifth and sixth floors step back  at  ten-
foot increments on all four corners of the structure.  Landscaped
terraces are proposed on each corner of the two uppermost levels.
Arched  windows  are repeated centrally on the sixth floor of the
Wilshire Boulevard elevation.  Proposed  exterior  materials  in-
clude  warm-tone  granite  and  lightly tinted glazing with clear
glazing on the ground level.

The front setback of the proposed office building varies  between
six feet and twenty-eight feet with a predominant setback of fif-
teen feet on the third through sixth floors.  The setback on Yale
Street  varies between six feet and eight feet.  A twenty foot to
twenty-two foot landscaped setback on the  eastern  side  of  the
development is adjacent to an existing, two-story commercial com-
plex.  The predominant setback between  the  proposed  commercial
and  residential structures is approximately 45 feet.  A wall and
landscaping will separate the two uses.

The 11-unit apartment complex is designed as a U-shaped  building
with  an  open courtyard on the south side of the structure.  The
Mediterranean style building features a stucco  exterior,  arched
windows,  balconies with metal railings on three elevations and a
clay tile roof.  Unit plans include ten flats,  ranging  in  size
from  1,050  to 1,300 square feet, and one two-story unit with an
area of 2,150 square feet.  All units have two bedrooms, 2 baths,
kitchen  and  a  living/dining  area.   Proposed setbacks for the
apartment building are 20' on the front, 15' on the rear  and  9'
to 48' on the sides.  Building height is proposed to be 21 feet.

Parking and Circulation Design

Access to the commercial parking garage is provided  via  a  30'-
wide  driveway located on Yale Street approximately 130' south of
Wilshire Boulevard.  A vehicle stacking distance of 115' is  pro-
vided on-site prior to the ramp entrance.  Two tuck-under loading
spaces are provided on the south side  of  the  building,  midway
along  the  drive  aisle.  The trash enclosure will be located on
the first level of the subterranean garage.

The location of the commercial driveway on  Yale  Street,  rather
than  Wilshire  Boulevard,  is supported by the Land Use and Cir-
culation Element, Policy No. 4.3.7, which states that "new drive-
ways  and  mid-block  access  points shall be limited, especially
along major roads."  However, the Circulation Element also  calls
for  minimization  of impacts on residential side streets.  These
policies are weighed on a case-by-case basis, since the  Circula-
tion  Element  does  not provide strict standards for location of
commercial access points.

Required parking for the office structure is 255 spaces, based on
the  code  parking requirement of one parking space for every 300
square feet of floor area.  The three-level, subterranean  garage
provides  a  total  of 295 parking spaces, which exceeds the code
requirement by 40 spaces.  Thirty-nine of the  total  spaces  are
proposed to be tandem parking spaces and 89 spaces (30% of total)
are proposed to be compact parking stalls.  Current code permits,
by  right, a maximum of 40% of the total number of parking spaces
to be compact.  The proposed  tandem  spaces  represent  surplus,
rather than code-required, parking spaces.

The residential parking is separated from the commercial  parking
within  the  first  level of the subterranean garage.  A separate
driveway for use of the apartment residents is provided  on  Yale
Street  approximately  80' south of the commercial driveway.  The
code requires two parking spaces per unit for a total requirement
of  22  spaces.   The  previous code did not have a guest parking
requirement for residential units.  For purposes  of  comparison,
current  code  would  require  two guest spaces for a total of 24
spaces.  Twenty-seven standard parking spaces are provided within
the  residential  parking garage, which exceeds the code require-
ment by 5 spaces.  This equates to the provision of approximately
2.5 spaces for every unit.

ENVIRONMENTAL IMPACT REPORT

The Environmental Impact Report (EIR) analyzed various  areas  of
potential  project-related impacts, including:  traffic, circula-
tion and parking; aesthetics, shadows, light and glare; water and
sewer  service;  business  displacement and neighborhood effects.
The EIR concluded that the project would not generate significant
environmental  impacts which could not be mitigated.  Some of the
major areas addressed in the EIR are discussed below.

Traffic and Circulation Analysis

Six critical, signalized intersections were analyzed in  the  EIR
to  determine  volume/capacity ratios (V/C) and levels of service
(LOS) during the morning  and  evening  peak  hours.   These  six
intersections are:

       -  Wilshire Boulevard and Yale Street;
       -  Santa Monica Boulevard and Yale Street;
       -  Wilshire Boulevard and Berkeley Street;
       -  Wilshire Boulevard and 26th Street;
       -  Colorado Avenue and Stewart Street; and
       -  Olympic Boulevard and Stewart Street.

The traffic impact analysis determined that prior to  mitigation,
the  project  would create significant traffic impacts during the
evening peak hour at the following three critical intersections:

       -  Wilshire Boulevard and Yale Street;
       -  Santa Monica Boulevard and Yale Street; and
       -  Wilshire Boulevard and 26th Street.

The EIR proposed mitigation measures not only reduce the project-
related,  significant  traffic  impacts,  but also reduce the V/C
ratios below the projected cumulative base conditions by  amounts
ranging between 2% and 18% (Please refer to Table 6 in Appendix B
of the EIR.  [A correction should be noted that the similar Table
4, on page 4-14 of the EIR, contains typographical errors.  Table
6 is  the  correct  source.]).   These  mitigation  measures  are
detailed in section 4.1.3.1 of the EIR and outlined below:

       Wilshire Boulevard and Yale Street

       Restripe both approaches of Yale Street to  accommodate  a
       10' exclusive left-turn lane and a 15' through lane.  This
       would require prohibition  of  parking  during  p.m.  peak
       hours  on  both sides of Yale Street for a distance of ap-
       proximately 120' north and south  of  Wilshire  Boulevard.
       This  would  require  a no-parking restriction on approxi-
       mately 14  on-street,  parking  spaces  during  p.m.  peak
       hours.

       Santa Monica Boulevard and Yale Street

       Restripe both approaches of Yale Street to  accommodate  a
       10' exclusive left-turn lane and a 15' through lane.  This
       would require prohibition  of  parking  during  p.m.  peak
       hours  on  both sides of Yale Street for a distance of ap-
       proximately  110'  north  and  south   of   Santa   Monica
       Boulevard.  This would require a no-parking restriction on
       ten, on-street parking spaces during p.m. peak hours.

       Wilshire Boulevard and 26th Street

       Restripe Wilshire Boulevard to accommodate a 12' exclusive
       right-turn  lane  in  the westbound direction.  No loss of
       parking will occur, as parking is prohibited on the  north
       side  of  Wilshire  Boulevard, east of 26th Street, due to
       the existing bus stop.

The EIR states that the above mitigation  measures  would  create
the  unavoidable  significant  impact of eliminating 14 on-street
parking spaces on Yale Street near Wilshire Boulevard and ten on-
street parking spaces on Yale Street near Santa Monica Boulevard.
However, staff does not believe this poses a  significant  impact
for  several  reasons.   The 24 on-street parking spaces are pro-
posed to be prohibited only  during  the  p.m.  peak  hours.   By
limiting  parking, the overall cumulative traffic conditions with
the proposed project would be improved over what is projected  to
be  the  cumulative  base traffic conditions without the proposed
project.  This improvement goes beyond  mitigating  the  project-
related  impacts  and  would improve the actual operation of area
traffic, thus providing a beneficial tradeoff.  Furthermore,  the
project  provides  40  surplus parking spaces above code require-
ment.  Therefore, the loss of 14 on-street parking spaces  during
the  p.m. peak hours on Yale Street near Wilshire Boulevard could
potentially be regained within the  subterranean  garage  of  the
proposed  project.   Due to these factors, staff did not consider
the restriction of a limited number of on-street  parking  spaces
during certain hours to be a significant impact and, therefore, a
Statement of Overriding  Considerations  would  not  be  required
should the Council wish to approve the project.

Wastewater Generation

The EIR estimates that the office project and  11-unit  apartment
complex would generate 6,019 gallons per day (gpd) of wastewater.
Current  wastewater  generation  for  this  site  is  1,343  gpd,
resulting  in  a  net  increase  of  4,676 gpd.  The net increase
represents approximately seven percent of  the  City's  six-month
wastewater  allocation.   The  applicant  could  be  required  to
attempt to  achieve  a  zero-net  flow  through  a  City-approved
program should the Council wish to approve the project.

SITE REVIEW CONSIDERATION

The Site Review Permit is required to permit the project  to  ex-
ceed  a  height  of  4 stories/56' and an F.A.R. of 2.5 and to be
considered for a maximum height of 6 stories/84' and an F.A.R. of
3.0.  The proposed project is at the maximum requested F.A.R. and
is one foot less than the  maximum  permitted  height.   The  EIR
determined  that,  with appropriate mitigation measures, the sig-
nificant project-related impacts could be eliminated.

One of these mitigation measures is that the height and  bulk  of
the  project  be  considered  in detail to ensure that the office
building  steps  down  or  otherwise  relates  to  the   adjacent
residential  zone.  Compliance with this mitigation could require
reduction in number of stories of the  development,  redesign  to
provide  additional architectural stepbacks or reduction in floor
area.

A reduction imposed solely on the floor area or floor area  ratio
of  the project would not directly affect the pertinent issues of
height and bulk of the project, as  a  reduction  in  floor  area
could  potentially  be  accommodated  by  decreasing the building
footprint without reducing the  building's  height  or  perceived
bulk.   Therefore, a more direct control of height and bulk could
be accomplished by restricting the  number  of  stories  and  es-
tablishing setback requirements for the project.

A redesign of the project would be required to satisfy the design
related  EIR  mitigation measures, as well as to comply with Land
Use Element, Policy 3.2.1, which states  that  "allowable  height
limits  for  commercial  and  industrial uses should step down or
otherwise relate to the height limit of the adjacent  residential
zone, to reduce visual intrusion, shading and scale incongruity."
Staff recommended to the Planning Commission that the project  be
redesigned  to  a maximum of five stories, not to exceed a height
of 70 feet, with the building footprint and setbacks to be  main-
tained  as  proposed.   Any additional refinement to the building
facade which may be necessitated by the loss of the  sixth  floor
to  ensure  the  proportion  and  rhythm  of the structure may be
presented  to  the  Architectural  Review  Board.   Assuming   no
additional  stepbacks  are  required  on  the  upper  levels, the
reduction  of  the  building  to  five  stories  per  the   staff
recommendation  to the Planning Commission would have resulted in
a total floor area of 64,178 (a reduction of 12,305 sq. ft.)  and
an F.A.R. of 2.52 (a reduction of 0.48).

PLANNING COMMISSION ACTION

On April 5, 1989  the  Planning  Commission  conducted  a  public
hearing  regarding the proposed project.  The Planning Commission
had been presented with a staff recommendation  for  approval  of
the  project  subject  to  a  reduction  of  one story in height,
accompanied by the reduction in square footage  discussed  above,
as  well  as a variety of other conditions (see attached Planning
Commission  staff  report).   The  applicant  indicated  to   the
Commission a preference to develop the project at the originally-
proposed six stories.

Concerns raised by the  Planning  Commission  included  the  com-
patibility  of  the  proposed six-story development with the sur-
rounding neighborhood, lack of project  elements  justifying  the
provision  of a site review bonus, the use of Yale Street instead
of Wilshire for access to the commercial development, the removal
of  on-street parking as a traffic mitigation measure, inadequate
provision of open space, the lack of study of the intersection of
Arizona and Yale and Colorado and Yale, and several other issues.

A motion was made for project approval at an FAR of  2.0  with  a
four-story height limit and three stories on the residential side
of the project, that the design be modified  to  reflect  greater
pedestrian  orientation  on  the  ground level, that the building
incorporate an upper level setback as called for by the Land  Use
Element  and Zoning Ordinance, that the ground floor retail space
be limited to low-intensity retail, that vehicle access  be  from
Wilshire  instead  of  Yale,  and  that the traffic study for the
project be revised.  There was general discussion and expressions
of  support for this motion among the Commissioners present.  The
Planning Commission Chairperson asked the developer if  he  would
be  willing to grant a Permit Streamlining Act extension to allow
time for redesign.  The developer indicated he would not be will-
ing to grant such an extension.

Since the Permit Streamlining Act  deadline  for  action  on  the
project  was  April  12, 1989, and the developer was unwilling to
grant an extension allowing the Commission to  review  a  revised
design,  a motion for denial was made based on lack of compliance
with site review criteria including a lack  of  provisions  which
would  justify  a  site review bonus, lack of pedestrian orienta-
tion, inadequate open space, and  significant  environmental  im-
pacts.   This  motion was approved unanimously by the six Commis-
sioners present.

APPEAL

On April 19, 1989 Tamar C. Stein, on behalf of  Zealund  Corpora-
tion,  appealed  the  Planning  Commission's  action.  The appeal
letter cited three grounds for appeal:  1) That the  Commission's
action  was  not  supported  by adequate findings or facts in the
record; 2) that the Commission denied the project  based  on  the
developer's  refusal  to  comply  with  conditions  for which the
developer maintains compliance was not required, thereby  violat-
ing substantive and due process and constituting a taking; and 3)
that the project has met all requirements of the  Municipal  Code
and therefore approval is warranted.

Under the Zoning Ordinance and General Plan, the Planning Commis-
sion  has  broad  discretion  to  act  on projects, including the
ability to impose conditions to protect the public health, safety
and  welfare.   The Commission's concerns about the height of the
project were originally identified in  the  Environmental  Impact
Report  for  the  project.   Other  concerns,  such as pedestrian
orientation and a desire to change the commercial  vehicular  ac-
cess  point from Yale to Wilshire, are clearly within the Commis-
sion's authority.

The Commission's role in reviewing  Development  Review  applica-
tions  and  other  discretionary  projects clearly extends beyond
measuring simple compliance with maximum General Plan height  and
FAR  standards.   Under  Ordinance Number 1321 (CCS), this review
extends to an examination of whether the size  and  placement  of
structures is appropriate and relates harmoniously to surrounding
neighborhoods, review of the adequacy of  circulation  facilities
to  serve  the  project,  and inclusion of mitigation measures to
address impacts identified in the environmental  review  process.
The Commission's actions on this project are within its authority
and consistent with its mission of assuring that development  en-
hances the quality of life in the community.

BUDGET/FINANCIAL IMPACT

The recommendations of this staff report have no budget/financial
impact.

RECOMMENDATION

It is recommended that the City Council uphold the Planning  Com-
mission's  denial of  Conditional Use Permit 512, Development Re-
view 446 and Variance 5345-Y subject to the following findings.

FINDINGS

1.     The physical location, size, massing, and placement of the
       proposed commercial structure on the site and the location
       of proposed uses within the  project  are  not  compatible
       with  and  do not relate harmoniously to surrounding sites
       and neighborhoods, in that the proposed six-story  commer-
       cial  building  is  of a larger scale than and will appear
       incongruous with  existing,  surrounding  residential  and
       commercial uses.

2.     The granting of a Site Review bonus to  permit  additional
       height  and density bonuses above the zone's base develop-
       ment standards is not warranted in that the project  fails
       to  provide  associated  amenities  such  as neighborhood-
       serving  commercial  uses;  usable  open  space  which  is
       accessible to the public; public art; substantial tiering,
       stepping back and lowering of the structure to blend  with
       surrounding  lower-scale  development;  adequate articula-
       tion of the building  design  and  an  interactive  design
       promoting pedestrian orientation to the street.

3.     That the Planning Commission's actions were appropriate to
       protect  the  health, safety and welfare of the community,
       and within its powers under the laws of the City  and  the
       State  of California in that the Commission's desire for a
       revised traffic study was appropriate under  the  require-
       ments  of  the California Environmental Quality Act, which
       requires that decisionmakers  be  provided  with  adequate
       information  on  potential  environmental impacts of proj-
       ects, and that the Commission felt that several  intersec-
       tions  should be studied in relation to traffic impacts of
       the project; that Ordinance 1321, to  which  this  project
       was  subject,  clearly contemplates a discretionary review
       process for Development Review projects, including  condi-
       tional  approvals;  that Ordinance 1321 also requires com-
       pliance with the General Plan and the  developer  was  un-
       willing  to grant a processing extension to allow redesign
       so as to comply with reasonable design changes desired  by
       the  Planning  Commission  to  ensure  compliance with the
       General Plan, which changes included revised height, step-
       backs, FAR, ground floor orientation and vehicle access to
       the project.      That  under  the  Zoning  Ordinance  and
       General Plan, the Planning Commission has broad discretion
       to act on projects, including the ability to impose condi-
       tions  to  protect  the public health, safety and welfare.
       The Commission's concerns about the  height,  relation  to
       surrounding  properties, and pedestrian orientation of the
       project were originally identified  in  the  Environmental
       Impact  Report  for  the  project as potential adverse im-
       pacts.  Other concerns, such as pedestrian orientation and
       a  desire  to change the commercial access point from Yale
       to Wilshire, are clearly within the  Commission's  purview
       in  its  exercise  of  good planning principles and inter-
       pretation of General Plan policy and  Municipal  Code  re-
       quirements  and  form  the  basis for the Planning Commis-
       sion's denial of the project.

4.     Under Ordinance 1321 and site review criteria of the  Land
       Use  and  Circulation  Elements,  the  Planning Commission
       properly found that the size and placement  of  structures
       in  the  proposed project is not appropriate and would not
       relate harmoniously to surrounding neighborhoods, and that
       circulation  facilities  to serve the project would be in-
       adequate.  The Commission's actions on  this  project  are
       within  its  authority  and consistent with its mission of
       assuring that development enhances the quality of life  in
       the community.

Prepared by:  Shari Laham, Associate Planner
              D. Kenyon Webster, Principal Planner

Attachments:  A. Municipal Code and General Plan Conformance
              B. Radius and Location Map
              C. Project Description, Submitted by Applicant
              D. Summary of Project
              E. Letter from Applicant, dated 2/16/89
              F. Protest Letter, dated 3/9/89
              G. Final EIR
              H. Plot Plan, Floor Plans, Elevations and Section
              I. Planning Commission Staff Report
              I. Planning Commission Statement of Official
                  Action
              J. Letter of Appeal

NOTE:   Attachments  B  through  H,  and  attachment  J  are  not
available  on  PEN,  but  may  be  obtained from the City Clerk's
office.


ATTACHMENT A

MUNICIPAL CODE AND GENERAL PLAN CONFORMANCE

                               Land Use
Category       Municipal Code  Element             Project

Permitted Use  C4:  General    General             General
               Commercial      Commercial          Office

               R2 & R2A:
               Low-Density     Low-Density         Low-Density
               Residential     Residential         Residential

Commercial     6 stories/90'   4 stories/56;
Height
                               With Site Review:   Site Review:
                               6 stories/84'       6 stories/83'

Residential    2 stories/30'   Same as             2 stories/21'
Height                         Municipal Code

Commercial
Setbacks

  Frontyard    0'              Same as Code        6' - 28'

  Sideyard     0'              Same as Code        20'- 22'(east)
                                                   6' - 8' (west)

  Rearyard     23'             Same as Code        35'-6"

Residential
Setbacks

  Frontyard    20'             Same as Code        20'

  Sideyard      9'             Same as Code        9' - 50'

  Rearyard     15'             Same as Code        15'

Commercial     3.3             2.5;
F.A.R.                         With Site           With Site
                               Review:  3.0        Review:  3.0

Parking        255 commercial                      295 commercial
               spaces;         Same as Code        spaces;

               22 residential                      27 residential
               spaces                              spaces


                          ATTACHMENT I

                     CITY PLANNING DIVISION
          Community and Economic Development Department

                       M E M O R A N D U M

DATE:     April 5, 1989

TO:       The Honorable Planning Commission

FROM:     Planning Staff

SUBJECT:  CUP 512, DR 446, ZA 5345-Y, EIA 872

          Address:    2900 Wilshire Boulevard and 1217 Yale
                      Street
          Applicant:  Zealund Corporation

SUMMARY

Action:  Approval of a Conditional Use Permit, Site  Review  Per-
mit, Variance and Certification of an Environmental Impact Report
to permit the construction of  a  six-story,  76,483  square-foot
office  building  with three levels of subterranean parking and a
two-story, 11-unit apartment building with one level  of  subter-
ranean  parking.  This application is subject to review under the
provisions of the previous zoning ordinance.

Recommendation:  Approval with conditions

Permit Streamlining Expiration Date:  April 12, 1989


SITE LOCATION AND DESCRIPTION

The subject property is a 42,500 sq. ft. parcel  located  on  the
southeast  corner  of Wilshire Boulevard and Yale Street having a
frontage of 170 feet on Wilshire Boulevard and 250 feet  on  Yale
Street.   The site is currently developed with Madame Wong's res-
taurant which would be demolished to permit the proposed develop-
ment.   Surrounding  uses consist of a four-story, medical office
building (C6) to the north; a one story, low-density  residential
structure  (R2) to the south; a two-story commercial building and
one and two-story low-density residential buildings (C6, B2A  a**
R2)  to  the  east  and a single-story commercial center and low-
density residential buildings (C6, R2A and R2) to the west.

Zoning Districts:    C4, R2A and R2

Land Use Districts:  Wilshire Corridor Commercial and
                     Low-Density Residential

Parcel Area:         C4:  170' X 150' = 25,500 square feet
             R2A and R2:  170' X 100' = 17,000 square feet
      Total Parcel Area:  170' X 250' = 42,500 square feet

PROPOSED PROJECT

The proposed project entails the  construction  of  a  six-story,
76,483  square-foot  commercial  office  building on the C4 zoned
property and a two-story, 11-unit apartment complex on the  adja-
cent  R2A  and  R2 zoned properties.  A Site Review Permit is re-
quired to permit the commercial development to exceed a height of
4  stories/56'  and a Floor Area Ratio (F.A.R.) of 2.5.  The Site
Review process permits  consideration  of  development  up  to  a
height  of 6 stories/84' and an F.A.R. of 3.0.  The office build-
ing is proposed to be six stories with a height  of  83'  and  an
F.A.R. of 3.0.

A Conditional Use Permit is proposed to permit the  subterranean,
commercial  parking  garage  to  extend beneath the residentially
zoned property, as established by previous Code,  Section  9148A.
A Variance is proposed to permit encroachment of the subterranean
garage into the required four-foot unexcavated side yards of  the
residentially zoned property, to permit 30% compact spaces and to
permit 39 surplus commercial spaces to be tandem.

MUNICIPAL CODE AND GENERAL PLAN CONFORMANCE

The project is being considered under the  previous  zoning  code
due  to  the  date  the application was deemed complete (prior to
April 29, 1988).  The proposed project  is  consistent  with  the
Municipal  Code  and in conformity with the General Plan as shown
in Attachment A, with the following exceptions:   a  variance  is
requested  to  permit 39 surplus, commercial parking spaces to be
tandem spaces and 30% of the  commercial  parking  spaces  to  be
compact  spaces  and  to  allow  encroachment of the subterranean
parking  garage  into  the  required  4'  unexcavated  side  yard
setbacks on both sides of the residentially zoned property.

CEQA STATUS

An Environmental Impact Report (EIR) has been prepared  for  this
project  and  approval of a resolution certifying the adequacy of
the EIR is recommended.  Copies of the Draft EIR were distributed
to  the Planning Commission at the beginning of the 30-day public
review period.  Comments were received and the responses  to  the
comments are incorporated into the Final EIR.

FEES

The commercial portion of this project is subject to the  Housing
and  Parks  Project  Mitigation Measures of the Land Use and Cir-
culation Elements of the General Plan.   The  project  mitigation
measures  may  be  satisfied  by payment of an in-lieu fee to the
City as established by Ordinance 1367 (CCS) and outlined  in  the
conditions of approval for this project.

                  STATEMENT OF OFFICIAL ACTION

PROJECT

    NUMBER:     CUP 512, DR 446, ZA 5345-Y, EIA 870

    LOCATION:   2900 Wilshire Boulevard and 1217 Yale Street

    APPLICANT:  Zealund Corporation

    REQUEST:    Approval of a Conditional Use Permit, Site Review
                Permit,   Variance   and   Certification   of  an
                Environmental  Impact  Report   to   permit   the
                construction  of  a six-story, 76,483 square-foot
                office   building   with    three    levels    of
                subterranean  parking  and  a  two-story, 11-unit
                apartment building with one level of subterranean
                parking.

PLANNING COMMISSION ACTION

      4/5/89    Date.

                Approved project based on the following  findings
                and subject to the conditions below.

        X       Denied.

                Other.

FINDINGS

1.  The physical location, size, massing, and  placement  of  the
    proposed commercial structure on the site and the location of
    proposed uses within the project are not compatible with  and
    do   not   relate   harmoniously  to  surrounding  sites  and
    neighborhoods, in  that  the  proposed  six-story  commercial
    building   is   of  a  larger  scale  than  and  will  appear
    incongruous  with  existing,  surrounding   residential   and
    commercial uses.

2.  The proposed development of a six-story,  76,483  square-foot
    office  building  with  three  levels of subterranean parking
    will create potentially significant traffic  impacts  in  the
    surrounding  area,  as documented in the Environmental Impact
    Report, EIA 872.  The proposed traffic mitigation measures of
    imposing  on-street parking restrictions during peak hours on
    portions of nearby residential streets is not  determined  to
    be  acceptable  in that the burden of traffic mitigation mea-
    sures should be borne solely by the project and  not  by  the
    surrounding community.

3.  The granting of a Site Review to permit additional height and
    density  bonuses  above the zone's base development standards
    is not  warranted  in  that  the  project  fails  to  provide
    associated  amenities such as neighborhood-serving commercial
    uses; usable open space which is accessible  to  the  public;
    public  art;  substantial tiering, stepping back and lowering
    of  the  structure  to  blend  with  surrounding  lower-scale
    development;   adequate  articulation  of the building design
    and an interactive design  promoting  pedestrian  orientation
    to the street.

VOTE

Ayes:     Hecht, Kaufman, Lambert, Mechur, Pyne and Nelson
Nays:
Abstain:
Absent:   Farivar

NOTICE

If this is a final decision not subject to further  appeal  under
the  City  of  Santa Monica Comprehensive Land Use and Zoning Or-
dinance, the time within which judicial review of  this  decision
must  be  sought  is  governed by Code of Civil Procedure Section
1094.6, which provision has been adopted by the City pursuant  to
Municipal Code Section 1400.

I hereby certify that this Statement of Official Action accurate-
ly reflects the final determination of the Planning Commission of
the City of Santa Monica.

            signature                              date

            print name and title

The residential portion of this project is subject to a Parks and
Recreation Facilities Tax of $200.00 per unit.

ANALYSIS

Project Description

The office building  features  a  recessed,  colonnaded  entrance
along Wilshire Boulevard with recessed, arched window openings at
the second level above the entrance and  recessed  window  walls.
The  third and fourth floors step back ten feet along portions of
the front facade.  The fifth and sixth floors step back  at  ten-
foot increments on all four corners of the structure.  Landscaped
terraces are proposed on each corner of the two uppermost levels.
Arched  windows  are repeated centrally on the sixth floor of the
Wilshire Boulevard elevation.  Proposed  exterior  materials  in-
clude  warm-tone  granite  and  lightly tinted glazing with clear
glazing on the ground level.

The front setback of the proposed office building varies  between
6' and 28' with a predominant setback of 15' on the third through
sixth floors.  The setback on Yale Street varies between  6'  and
8'.   A  20' to 22' landscaped setback on the eastern side of the
development which is adjacent to an existing,  two-story  commer-
cial  complex.  The predominant setback between the proposed com-
mercial and residential structures is approximately 45  feet.   A
wall and landscaping will separate the two uses.

The 11-unit, apartment complex is designed as a U-shaped building
with  an  open courtyard on the south side of the structure.  The
Mediterranean style building features a stucco  exterior,  arched
windows,  balconies with metal railings on three elevations and a
clay tile roof.  Unit plans include ten flats,  ranging  in  size
from  1,050  to 1,300 square feet, and one two-story unit with an
area of 2,150 square feet.  All units have two bedrooms, 2 baths,
kitchen  and  a  living/dining  area.   Proposed setbacks for the
apartment building are 20' on the front, 15' on the rear  and  9'
to 48' on the sides.  Building height is proposed to be 21 feet.

Parking and Circulation Design

Access to the commercial parking garage is provided  via  a  30'-
wide  driveway located on Yale Street approximately 130' south of
Wilshire Boulevard.  A vehicle stacking distance of 115' is  pro-
vided  on-site prior to the ramp entrance.  Two, tuck-under load-
ing spaces are provided on the south side of the building, midway
along  the  drive  aisle.  The trash enclosure will be located on
the first level of the subterranean garage.

The location of the commercial driveway on  Yale  Street,  rather
than  Wilshire  Boulevard,  is supported by the Land Use and Cir-
culation Element,  Policy  No.  4.3.7,  which  states  that  "new
driveways   and   mid-block   access  points  shall  be  limited,
especially along major roads."

Required parking for the office structure is 255 spaces, based on
the  code  parking requirement of one parking space for every 300
square feet of floor area.  The three-level, subterranean  garage
provides  a  total  of 295 parking spaces, which exceeds the code
requirement by 40 spaces.  Thirty-nine of the  total  spaces  are
proposed to be tandem parking spaces and 89 spaces (30% of total)
are proposed to be compact parking stalls.  Current code permits,
by  right, a maximum of 40% of the total number of parking spaces
to be compact.  The proposed  tandem  spaces  represent  surplus,
rather  than  code-required,  parking spaces.  For these reasons,
staff recommends approval of the variance to  allow  compact  and
tandem parking spaces.

As established by the Land Use and  Circulation  Element,  Policy
No. 4.7.10, staff is recommending as a condition of approval that
parking be provided free of charge to employees of  and  visitors
to  the commercial complex in order to mitigate potential parking
impacts on the surrounding neighborhood, unless  and  until  such
time as a preferential parking zone is established in the immedi-
ate area.

The residential parking is separated from the commercial  parking
within  the  first  level of the subterranean garage.  A separate
driveway for use of the apartment residents is provided  on  Yale
Street  approximately 80' south of the commercial driveway.  Code
requires two parking spaces per unit for a total  requirement  of
22  spaces.   The  previous code did not have a guest parking re-
quirement for residential units.   For  purposes  of  comparison,
current  code  would  require  two guest spaces for a total of 24
spaces.  Twenty-seven standard parking spaces are provided within
the  residential  parking garage, which exceeds the code require-
ment by 5 spaces.  This equates to the provision of approximately
2.5 spaces for every unit.

ENVIRONMENTAL IMPACT REPORT

The Environmental Impact Report (EIR) analyzed various  areas  of
potential  project-related impacts, including:  traffic, circula-
tion and parking; aesthetics, shadows, light and glare; water and
sewer  service;  business  displacement and neighborhood effects.
The EIR  concluded  that  the  project  would  not  generate  any
significant  environmental  impacts which could not be mitigated.
Some of the major areas addressed in the EIR are discussed below.

Traffic and Circulation Analysis

Six critical, signalized intersections were analyzed in  the  EIR
to  determine  volume/capacity ratios (V/C) and levels of service
(LOS) during the morning  and  evening  peak  hours.   These  six
intersections are:

       -  Wilshire Boulevard and Yale Street;
       -  Santa Monica Boulevard and Yale Street;
       -  Wilshire Boulevard and Berkeley Street;
       -  Wilshire Boulevard and 26th Street;
       -  Colorado Avenue and Stewart Street; and
       -  Olympic Boulevard and Stewart Street.

The traffic impact analysis determined that prior to  mitigation,
the  project  would create significant traffic impacts during the
evening peak hour at the following three, critical intersections:

       -  Wilshire Boulevard and Yale Street;
       -  Santa Monica Boulevard and Yale Street; and
       -  Wilshire Boulevard and 26th Street.

The EIR proposes mitigation measures which not  only  reduce  the
project-related, significant traffic impacts, but also reduce the
V/C ratios below the  projected  cumulative  base  conditions  by
amounts  ranging  between  2% and 18% (Please refer to Table 6 in
Appendix B of the EIR.  [A correction should be  noted  that  the
similar  Table 4, on page 4-14 of the EIR, contains typographical
errors.  Table 6 is the correct source.]).  These mitigation mea-
sures  are  detailed  in  section 4.1.3.1 of the EIR and outlined
below.

       Wilshire Boulevard and Yale Street

       Restripe both approaches of Yale Street to  accommodate  a
       10' exclusive left-turn lane and a 15' through lane.  This
       would require prohibition  of  parking  during  p.m.  peak
       hours  on  both sides of Yale Street for a distance of ap-
       proximately 120' north and south  of  Wilshire  Boulevard.
       This  would  require  a no-parking restriction on approxi-
       mately 14  on-street,  parking  spaces  during  p.m.  peak
       hours.

       Santa Monica Boulevard and Yale Street

       Restripe both approaches of Yale Street to  accommodate  a
       10' exclusive left-turn lane and a 15' through lane.  This
       would require prohibition  of  parking  during  p.m.  peak
       hours  on  both sides of Yale Street for a distance of ap-
       proximately  110'  north  and  south   of   Santa   Monica
       Boulevard.  This would require a no-parking restriction on
       ten, on-street parking spaces during p.m. peak hours.

       Wilshire Boulevard and 26th Street

       Restripe Wilshire Boulevard to accommodate a 12' exclusive
       right-turn  lane  in  the westbound direction.  No loss of
       parking will occur, as parking is prohibited on the  north
       side  of  Wilshire  Boulevard, east of 26th Street, due to
       the existing bus stop.

The EIR states that the above mitigation  measures  would  create
the  unavoidable  significant  impact of eliminating 14 on-street
parking spaces on Yale Street near Wilshire Boulevard and ten on-
street parking spaces on Yale Street near Santa Monica Boulevard.
However, staff does not believe this poses a  significant  impact
for  the  following reasons.  The 24 on-street parking spaces are
proposed to be prohibited only during the p.m. peak hours.  In so
doing,  the  overall  cumulative traffic conditions with the pro-
posed project would be improved over what is projected to be  the
cumulative  base traffic conditions without the proposed project.
This improvement goes beyond mitigating the  project-related  im-
pacts  and  would  improve  the actual operation of area traffic,
thus providing a beneficial tradeoff.  Furthermore,  the  project
provides  40  surplus  parking  spaces  above  code  requirement.
Therefore, the loss of 14 on-street  parking  spaces  during  the
p.m.  peak  hours  on  Yale  Street near Wilshire Boulevard could
potentially be regained within the  subterranean  garage  of  the
proposed  project.  Due to these factors, staff does not consider
the restriction of a limited number of on-street  parking  spaces
during certain hours to be a significant impact and, therefore, a
Statement of Overriding Considerations is not required.

Wastewater Generation

The EIR estimates that the office project and  11-unit  apartment
complex would generate 6,019 gallons per day (gpd) of wastewater.
Current  wastewater  generation  for  this  site  is  1,343  gpd,
resulting  in  a  net  increase  of  4,676 gpd.  The net increase
represents approximately seven percent of  the  City's  six-month
wastewater allocation.  The applicant will be required to attempt
to achieve a zero-net flow through a City-approved program.

SITE REVIEW CONSIDERATION

The Site Review Permit is required to permit the project  to  ex-
ceed  a  height  of  4 stories/56' and an F.A.R. of 2.5 and to be
considered for a maximum height of 6 stories/84' and an F.A.R. of
3.0.  The proposed project is at the maximum requested F.A.R. and
is one foot shorter than the maximum permitted height.   The  EIR
determined  that,  with appropriate mitigation measures, the sig-
nificant, project-related impacts could be eliminated.

One of these mitigation measures is that the height and  bulk  of
the  project  will be considered in detail to ensure that the of-
fice building steps down or otherwise  relates  to  the  adjacent
residential  zone.  Compliance with this mitigation could require
the following in part  or  in  whole:   reduction  in  number  of
stories  of  the  development, redesign to provide additional ar-
chitectural stepbacks and/or reduction in floor area.

A reduction imposed solely on the floor area or floor area  ratio
of  the  project will not directly affect the pertinent issues of
height and bulk of the project, as  a  reduction  in  floor  area
could  potentially  be  accommodated  by  decreasing the building
footprint without reducing the  building's  height  or  perceived
bulk.   Therefore, it appears a more direct control of height and
bulk may be accomplished by restricting the number of stories and
establishing setback requirements for the project.

A redesign of the project will be required to satisfy the  design
related  EIR  mitigation measures, as well as to comply with Land
Use Element, Policy 3.2.1, which states  that  "allowable  height
limits  for  commercial  and  industrial uses should step down or
otherwise relate to the height limit of the adjacent  residential
zone, to reduce visual intrusion, shading and scale incongruity."
Staff recommends that the project be redesigned to a  maximum  of
five  stories, not to exceed a height of 70 feet, with the build-
ing footprint and setbacks to be  maintained  as  proposed.   Any
additional  refinement to the building facade which may be neces-
sitated by the loss of the sixth floor to ensure  the  proportion
and rhythm of the structure may be presented to the Architectural
Review Board.  Assuming no additional stepbacks are  provided  on
the  upper  levels, the reduction of the building to five stories
would result in a total floor area of 64,178  and  an  F.A.R.  of
2.52.

RECOMMENDATION

It is  recommended  that  the  Planning  Commission  approve  the
resolution  certifying  Environmental Impact Report, EIA 872, and
approve  Conditional Use Permit 512, Development Review  446  and
Variance 5345-Y subject to the following findings and conditions.

VARIANCE FINDINGS

1.     There are special  circumstances  or  exceptional  charac-
       teristics  applicable  to the property involved, including
       size, shape, topography, location, or surroundings, or  to
       the  intended  use  or development of the property that do
       not apply to other properties in  the  vicinity  under  an
       identical zoning classification, in that the number of on-
       site parking spaces exceeds the code requirement  and  the
       inclusion  of  compact  and tandem parking spaces will not
       detrimentally affect the circulation and parking  patterns
       of the project.  The extension of the subterranean parking
       into the unexcavated side yard areas  of  the  residential
       property permits the provision of extra parking spaces.

2.     The granting of such variance will not be  detrimental  or
       injurious  to  the property or improvements in the general
       vicinity and district in which the property is located, in
       that  similar  projects in the past have utiliaed compact,
       tandem and extended subterranean parking with no  signifi-
       cant   impact   on  circulation  patterns  or  neighboring
       properties and that provided parking is in excess of  that
       required.

3.     The strict application of the provisions of  this  Chapter
       would  result  in  practical  difficulties  or unnecessary
       hardships, not including economic difficulties or economic
       hardships, in that past projects have incorporated compact
       and tandem parking spaces with no significant impacts  and
       the  total  number  of parking spaces provided exceeds the
       required number.

4.     The granting of a variance will not be contrary to  or  in
       conflict  with  the  general  purposes  and intent of this
       Chapter, or to the goals, objectives, and policies of  the
       General  Plan,  in that the project is consistent with the
       General Plan.

5.     The variance would not impair the integrity and  character
       of the district in which it is to be located, in that more
       parking than is required will be provided and the variance
       will not affect the appearance of the project.

6.     The subject site is physically suitable for  the  proposed
       variance,  in  that  it  is a recycling of commercial land
       with the provision of adequate access and circulation.

7.     There are adequate provisions for water,  sanitation,  and
       public  utilities and services to ensure that the proposed
       variance would not be detrimental  to  public  health  and
       safety,  in  that the project is an in-fill in a developed
       area with all necessary improvements.

8.     There will be adequate provisions  for  public  access  to
       serve  the  subject  variance  proposal,  in that adequate
       driveways will be provided on Yale Street  and  pedestrian
       sidewalks are in existence.

9.     The strict application of the provisions of Chapter 10  of
       the City of Santa Monica Comprehensive Land Use and Zoning
       Ordinance would result in unreasonable deprivation of  the
       use  or enjoyment of the property, in that similar varian-
       ces have been granted in the past which have  not  created
       any  deleterious  effects  and parking is provided for the
       project in excess of that required.

DEVELOPMENT REVIEW FINDINGS

1.     The physical location, size,  massing,  and  placement  of
       proposed  structures  on the site and the location of pro-
       posed uses within the project are compatible with and  re-
       late  harmoniously to surrounding sites and neighborhoods,
       in that the apartment building is of similar scale to  ex-
       isting residential uses and the office building is located
       on a busy, commercial  corridor,  will  be  reduced  to  a
       maximum  of  five  stories  and  is  setback 135' from the
       nearest developed residential property.

2.     The rights-of-way can accommodate autos  and  pedestrians,
       including  parking  and  access,  in  that the site design
       provides adequate driveway and parking facilities and  the
       site   is  adjacent  to  two  improved  streets,  Wilshire
       Boulevard and Yale Street.

3.     The health and safety services and  public  infrastructure
       are sufficient to accommodate the new development, in that
       the project is proposed to be an  in-fill  of  an  already
       developed area with all necessary services and infrastruc-
       ture preestablished.

4.     Any on-site provision of housing or parks and public  open
       space,  which  are part of the required project mitigation
       measures required in Subchapter 5G of the  City  of  Santa
       Monica   Comprehensive  Land  Use  and  Zoning  Ordinance,
       satisfactorily meet the goals of the  mitigation  program,
       in  that  11  apartment  units will be provided which will
       comply with Program 12, the required parks and  recreation
       fee  per  residential  unit  will  be  paid and the office
       project will be required to pay all necessary housing  and
       parks mitigation fees.

5.     The project is generally  consistent  with  the  Municipal
       Code  and General Plan, in that the project is designed to
       meet all code requirements and the General Plan, with  the
       exception of those parking issues for which a variance has
       been applied.

6.     Reasonable mitigation measures have been included for  all
       adverse  impacts  identified  in  the Environmental Impact
       Report,  in  that  all  reasonable   mitigation   measures
       espoused  by  the  EIR have been included as conditions of
       approval for the project,  as  well  as  additional  staff
       conditions.

CONDITIONAL USE PERMIT FINDINGS

1.     The proposed use is one conditionally permitted within the
       subject  district  and complies with all of the applicable
       provisions of the "City of Santa Monica Comprehensive Land
       Use  and  Zoning  Ordinance", in that the extension of the
       subterranean,  commercial  parking  garage   beneath   the
       residentially  zoned  property  will  not be a visible en-
       croachment into the residential neighborhood  and  is  ex-
       pressly  permitted  by Code with approval of a Conditional
       Use Permit.

2.     The proposed  use  would  not  impair  the  integrity  and
       character of the district in which it is to be established
       or located, in that the  subterranean,  commercial  garage
       will  be  accessed solely from the commercial lot and will
       not be a visible encroachment into the residential zone.

3.     The subject parcel is physically suitable for the type  of
       land  use  being  proposed,  in  that  it  is  of adequate
       size,dimension and topography to support the proposed use.

4.     The proposed use is compatible with any of the  land  uses
       presently  on  the subject parcel if the present land uses
       are to remain, in that none of the existing land uses will
       remain  and  the  project will essentially be built upon a
       vacant parcel.

5.     The proposed use would be  compatible  with  existing  and
       permissible  land uses within the district and the general
       area in which the proposed use is to be located,  in  that
       the  office  development is compatible with those existing
       uses along the Wilshire Corridor and the apartment  build-
       ing    is    compatible   with   surrounding   residential
       developments.

6.     There are adequate provisions for water,  sanitation,  and
       public  utilities and services to ensure that the proposed
       use would not be detrimental to public health and  safety,
       in  that  these  services are already existing and the EIR
       determined that no significant impacts  would  be  created
       which would overburden any of these established services.

7.     Public access to the proposed use shall  be  adequate,  in
       that  vehicular  access  may  be acquired through the sur-
       rounding, improved street system and pedestrian access may
       be served along the existing sidewalk network.

8.     The physical location or placement of the use on the  site
       is  compatible  with  and relates harmoniously to the sur-
       rounding neighborhood, in that the apartment  building  is
       of  a similar scale to surrounding residential development
       and the office  building  will  be  stepped  back  at  the
       corners,  will  receive review of the Architectural Review
       Board and is separated by 135' from the nearest  developed
       residential property.

9.     The proposed use is consistent with the goals, objectives,
       and policies of the General Plan, in that it complies with
       the various Elements of the General Plan.

10.    The proposed use would not be detrimental  to  the  public
       interest, health, safety, convenience, or general welfare,
       in that the subterranean garage will  provide  parking  in
       excess  of  the code requirement with no visible encroach-
       ment into the residential area.

11.    The proposed use will not result in  an  overconcentration
       of  such  uses  in  the  immediate  vicinity,  in that the
       General Plan has established the densities for  commercial
       and  residential  development  in the area and the project
       complies with both.

CONDITIONS

Plans

1.     This approval is for those plans dated April  6,  1988,  a
       copy of which shall be maintained in the files of the City
       Planning Division.  Project development shall  be  consis-
       tent  with  such  plans,  except as otherwise specified in
       these conditions of approval.

2.     The Plans shall comply with all other provisions of  Chap-
       ter  1,  Article  IX  of  the  Municipal Code, (Zoning Or-
       dinance) and all other pertinent  ordinances  and  General
       Plan policies of the City of Santa Monica.

3.     Final parking lot layout and specifications shall be  sub-
       ject to the review and approval of the Parking and Traffic
       Engineer.

4.     Minor amendments to the plans shall be subject to approval
       by  the Director of Planning.  A significant change in the
       approved concept shall be subject to  Planning  Commission
       Review.   Construction  shall  be  in conformance with the
       plans submitted or as modified by the Planning Commission,
       Architectural Review Board or Director of Planning.

5.     Plans for final design, landscaping, screening, trash  en-
       closures,  and  signage shall be subject to review and ap-
       proval by the Architectural Review Board.

6.     The Architectural Review Board, in its review,  shall  pay
       particular  attention to the project's pedestrian orienta-
       tion and amenities; scale and articulation of design  ele-
       ments;  exterior  colors,  textures  and materials; window
       treatment; glazing; and landscaping.

Fees

7.     The City is contemplating the adoption of a Transportation
       Management  Plan which is intended to mitigate traffic and
       air quality impacts resulting from both new  and  existing
       development.   The  Plan  will likely include an ordinance
       establishing mitigation requirements,  including  one-time
       payment  of  fees on certain types of new development, and
       annual fees to be paid by certain types  of  employers  in
       the  City.   This  ordinance may require that the owner of
       the proposed project pay such new  development  fees,  and
       that  employers within the project pay such new annual em-
       ployer fees related to the City's  Transportation  Manage-
       ment Plan.

8.     A Park  and  Recreation  Facilities  Tax  of  $200.00  per
       residential  unit  shall be due and payable at the time of
       issuance of a building permit for the construction of  the
       residential  units  on the subject lot, per and subject to
       the provisions of Section 6670 et seq. of the Santa Monica
       Municipal Code.

Demolition

9.     Until such time as the demolition is undertaken,  and  un-
       less  the  structure  is  currently  in  use, the existing
       structure shall be maintained and secured by  boarding  up
       all  openings, erecting a security fence, and removing all
       debris, bushes and planting that inhibit the easy surveil-
       lance  of the property to the satisfaction of the Building
       and Safety Officer and the Fire Department.  Any landscap-
       ing  material  remaining  shall  be watered and maintained
       until demolition occurs.

10.    Unless otherwise approved by the Recreation and Parks  De-
       partment  and  the  Planning  Division,  at  the  time  of
       demolition, any  street  trees  shall  be  protected  from
       damage,   death,   or  removal  per  the  requirements  of
       Ordinance 1242 (CCS).

11.    Immediately after demolition and  during  construction,  a
       security  fence,  the height of which shall be the maximum
       permitted by the Zoning  Ordinance,  shall  be  maintained
       around  the  perimeter  of the lot.  The lot shall be kept
       clear of all trash, weeds, etc.

Construction

12.    Unless otherwise approved by  the  Department  of  General
       Services,  all  sidewalks shall be kept clear and passable
       during the grading and construction phase of the project.

13.    Sidewalks, curbs, gutters, paving and driveways which need
       replacing  or removal as a result of the project as deter-
       mined by the Department of General Services shall  be  re-
       constructed  to  the  satisfaction  of  the  Department of
       General Services.  Approval for this  work  shall  be  ob-
       tained  from  the  Department of General Services prior to
       issuance of the building permits.

14.    Vehicles hauling dirt or other  construction  debris  from
       the  site  shall  cover  any open load with a tarpaulin or
       other secure covering to minimize dust emissions.

15.    Street trees shall be maintained, relocated or provided as
       required  in a manner consistent with the City's Tree Code
       (Ord. 1242 CCS), per the specifications of the  Department
       of  Recreation  and  Parks  and  the Department of General
       Services.  No street tree shall be removed without the ap-
       proval of the Department of Recreation and Parks.

16.    A construction period mitigation plan shall be prepared by
       the  applicant  for  approval by the Department of General
       Services prior to issuance of a building permit.   As  ap-
       plicable, this plan shall 1) Specify the names, addresses,
       telephone numbers and business license numbers of all con-
       tractors  and  subcontractors as well as the developer and
       architect;  2) Describe how  demolition  of  any  existing
       structures  is  to be accomplished;  3) Indicate where any
       cranes are to be located  for  erection/construction;   4)
       Describe how much of the public street, alleyway, or side-
       walk is proposed to be used in conjunction with  construc-
       tion;   5)  Set  forth  the extent and nature of any pile-
       driving operations;  6) Describe the length and number  of
       any tiebacks which must extend under the property of other
       persons;  7) Specify the nature and extent of any dewater-
       ing and its effect on any adjacent buildings;  8) Describe
       anticipated contruction-related truck  routes,  number  of
       truck  trips,  hours  of hauling and parking location;  9)
       Specify the nature and extent of any  helicopter  hauling;
       10) State whether any construction activity beyond normal-
       ly permitted hours is proposed;  11) Describe any proposed
       contruction  noise mitigation measures;  12) Describe con-
       struction-period security measures including any  fencing,
       lighting, and security personnel;  13) Provide  a drainage
       plan;  14)  Provide  a  construction-period  parking  plan
       which  shall  minimize  use of public streets for parking;
       15) List a designated on-site construction manager.

17.    A sign shall be posted on the property in a manner consis-
       tent with the public hearing sign requirements which shall
       identify the address and phone number of the owner  and/or
       applicant  for the purposes of responding to questions and
       complaints during  the  construction  period.   Said  sign
       shall  also indicate the hours of permissible construction
       work.

18.    A copy of these conditions shall be posted  in  an  easily
       visible  and  accessible location at all times during con-
       struction at the project site.  The pages shall  be  lami-
       nated  or  otherwise protected to ensure durability of the
       copy.

Environmental Mitigation

19.    Ultra-low flow plumbing fixtures are required on  all  new
       development  and remodeling where plumbing is to be added.
       (Maximum 1.6 gallon toilets and 1.0 gallon urinals and low
       flow shower head.)

20.    Prior to issuance of a Certificate of  Occupancy,  project
       owner  shall present documentation to the General Services
       Department   certifying   that   existing   Santa   Monica
       occupancies with toilets installed prior to 1978 have been
       retrofitted with ultra low-flow toilets (1.6  gallons  per
       flush  or  less)  such that development of the new project
       will not result in a net  increase  in  wastewater  flows.
       Flow  from  existing  occupancies which will be removed as
       part of the new development  may  be  deducted  from  flow
       attributable  to  the  new development if such occupancies
       have been occupied within one year prior to issuance of  a
       Building   Permit   for   the   proposed   project.   Flow
       calculations for new development  and existing occupancies
       shall be consistent with  guidelines   developed   by  the
       General Services Department.

21.    To mitigate solid waste impacts, prior to  issuance  of  a
       Certificate  of  Occupancy,  project  owner shall submit a
       recycling plan to the Department of General  Services  for
       its approval.  The recycling plan shall include 1) list of
       materials such as white paper, computer paper, metal cans,
       and glass to be recycled; 2) location of recyling bins; 3)
       designated recycling coordinator; 4) nature and extent  of
       internal   and   external   pick-up  service;  5)  pick-up
       schedule; 6) plan to inform tenants/occupants of service.

22.    To mitigate circulation impacts, prior to  issuance  of  a
       Certificate  of  Occupancy,  project  owner shall submit a
       transportation demand managment plan to the Department  of
       General  Services  for  its approval.  This plan shall in-
       clude:  1) Name, address and telephone  number  of  desig-
       nated  person(s)  responsible for coordinating transporta-
       tion demand managment measures  at  the  development.   2)
       Demand  management  measures to be employed at the site to
       reduce circulation impacts which  would  otherwise  occur.
       Such measures may include, but are not limited to programs
       addressing:  A. Education and Marketing to alert employees
       and  visitors to the site to demand reduction programs and
       incentives; B. Parking Management such as parking  charges
       for  single-occupant  vehicles,  reduced rates for car and
       vanpools; C. Ridesharing  programs  such  as  a  rideshare
       matching  program,  incentives,  and  car and vanpool sub-
       sidies; D. Transit  programs  such  as  provision  of  bus
       schedules to employees and visitors, subsidized bus tokens
       and passes to employees and visitors;  E.  Bicycling  pro-
       grams  such as provision of secure bicycle storage facili-
       ties, provision of showers  and  lockers;  F.  Alternative
       Work Schedules for building employees to avoid peak AM and
       PM traffic hours and reduce overall trips; G. Trip  Length
       Reduction  by programs to increase proportion of employees
       residing within three miles of  the  project  site.    The
       goal of the Transportation Demand Management Plan shall be
       to reduce vehicle trips which  would  otherwise  occur  by
       twenty percent.

23.    On-site commercial parking shall be made available without
       cost  to  building customers and employees until such time
       as a preferential parking district is established  in  the
       vicinity of the site.

24.    Landscaping  plans  shall  comply   with   Subchapter   5B
       (Landscaping  Standards) of the zoning ordinance including
       use of water-conserving landscaping  materials,  landscape
       maintenance   and   other   standards   contained  in  the
       Subchapter.

25.    The project owner shall restripe both approaches  of  Yale
       Street to accommodate a 10' exclusive left-turn lane and a
       15' through lane per the  specifications  of  the  General
       Services  Department.   This would require the prohibition
       of on-street parking during p.m. peak hours on both  sides
       of  Yale  Street, from Wilshire Boulevard to approximately
       120' north and south of the intersection.  This  will  re-
       quire  no-parking  restrictions  for  approximately 14 on-
       street parking spaces during p.m. peak hours.

26.    The project owner shall restripe both approaches  of  Yale
       Street to accommodate a 10' exclusive left-turn lane and a
       15' through lane per the  specifications  of  the  General
       Services  Department.   This would require the prohibition
       of on-street parking during p.m. peak hours on both  sides
       of  Yale  Street,  from Santa Monica Boulevard to approxi-
       mately 110' north and south  of  the  intersection.   This
       will  require  no-parking  restrictions  for approximately
       ten, on-street parking spaces.

27.    The project owner  shall  restripe  the  existing  roadway
       width  to  provide a 12' exclusive, right-turn lane in the
       westbound direction of Wilshire  Boulevard  east  of  26th
       Street  per the specifications of the General Services De-
       partment.  No on-street parking will be  restricted  as  a
       result of the restriping.

28.    The project shall be reduced to a maximum of five stories,
       not to exceed a height of 70 feet, with the building foot-
       print and setbacks to be maintained as proposed, in  order
       to conform to the character of surrounding development, in
       accordance with Policy 3.2.1  of  the  Land  Use  Element,
       which  states that "allowable height limits for commercial
       and industrial uses should step down or  otherwise  relate
       to  the  height limit of the adjacent residential zone, to
       reduce visual intrusion, shading and scale incongruity."

29.    A detailed plan of  pedestrian  improvements  illustrating
       features intended to enhance the street orientation of the
       project shall be submitted  to  the  Architectural  Review
       Board for approval.

30.    An 8', decorative, masonry wall shall be provided  between
       the  proposed residential and office structures; such wall
       shall step down to a height of 42" in the  required  front
       setback of the residential development.

31.    The subterranean parking  structure  shall  not  exceed  a
       height  of  3 feet above adjacent, average grade on either
       the commercial or residential portions of the development.

Miscellaneous Conditions

32.    The building address shall be painted on the roof  of  the
       commercial  building  and shall measure four feet by eight
       feet (32 square feet).

33.    The operation shall at all times be conducted in a  manner
       not  detrimental to surrounding properties or residents by
       reason of lights,  noise,  activities,  parking  or  other
       actions.

34.    No medical office use shall be permitted at the site.

35.    If  any  archaeological  remains  are   uncovered   during
       excavation  or  construction,  work  in  the affected area
       shall be suspended and a recognized  specialist  shall  be
       contacted  to  conduct  a  survey  of the affected area at
       project's owner's expense.  A determination shall then  be
       made  by  the  Director  of Planning to determine the sig-
       nificance of the survey findings and  appropriate  actions
       and requirements, if any, to address such findings.

Validity of Permits

36.    In the event permittee violates or fails  to  comply  with
       any  conditions  of  approval  of  this permit, no further
       permits, licenses, approvals or certificates of  occupancy
       shall  be  issued  until  such  violation  has  been fully
       remedied.

37.    Within ten days of Planning Division  transmittal  of  the
       Statement of Official Action, project  applicant     shall
       sign and return a copy of the Statement of Official Action
       prepared  by the Planning Division, agreeing to the Condi-
       tions of approval and acknowledging that failure to comply
       with  such  conditions shall constitute grounds for poten-
       tial revocation of the permit approval.  By signing  same,
       applicant  shall not thereby waive any legal rights appli-
       cant may possess regarding said  conditions.   The  signed
       Statment  shall  be  returned  to  the  Planning Division.
       Failure to comply with  this  condition  shall  constitute
       grounds for potential permit revocation.

38.    This determination shall not become effective for a period
       of  fourteen  days  from  the date of determination or, if
       appealed, until a final determination is made on  the  ap-
       peal.  Any appeal must be made in the form required by the
       Zoning Administrator.

Monitoring of Conditions

39.    Pursuant to the requirements of Public Resources Code Sec-
       tion 21081.6, the  City  Planning Division will coordinate
       a monitoring and reporting program regarding any  required
       changes  to  the  project made in conjunction with project
       approval and any conditions of approval,  including  those
       conditions  intended  to mitigate or avoid significant ef-
       fects on the environment.  This program shall include, but
       is  not  limited  to,  ensuring that the Planning Division
       itself and other City divisions and  departments  such  as
       the  Building  Division,  the General Services Department,
       the Fire Department, the Police Department, the  Community
       and  Economic  Development  Department and the Finance De-
       partment are aware of project requirements which  must  be
       satisfied prior to issuance of a Building Permit, Certifi-
       cate of Occupancy, or other permit, and that other respon-
       sible agencies are also informed of conditions relating to
       their    responsibilities.     Project     owner     shall
       demonsdrate*compliance  with  conditions  of approval in a
       written report submitted  to  the  Planning  Director  and
       Building Officer prior to issuance of a Building Permit or
       Certificate of  Occupancy,  and,  as  applicable,  provide
       periodic    reports   regarding   compliance   with   such
       conditions.

PROJECT MITIGATION FEE CONDITION

1.     In accordance with Sections 9046.1 - 9046.4 of  the  Santa
       Monica  Municipal  Code,  prior  to issuance of a building
       permit the developer shall execute an  irrevocable  letter
       of credit or other form of security acceptable to the City
       for the payment of an in-lieu fee for  housing  and  parks
       equal  to  $2.25/sq.ft. for the first 15,000 sq.ft. of net
       rentable  office  floor  area  and  $5.00/sq.ft.  for  the
       remaining  net rentable office floor area.  This fee shall
       be adjusted for inflation by the percentage change in  the
       Consumer  Price Index ("CPI") between October 1984 through
       the month in which  the  payment  is  made.   Upon  mutual
       agreement of the developer and the City, the developer may
       satisfy the Project Mitigation measures by  providing  low
       and  moderate  income housing or developing new park space
       on or off the project site.  To fulfill this obligation an
       agreement shall be secured in writing by the developer and
       approved by the City Attorney and City staff prior to  is-
       suance  of  a building permit.  This fee, prior to adjust-
       ment, will be $341,165, based on  a  net  rentable  office
       floor area of 76,483 square feet.

INCLUSIONARY UNIT CONDITIONS

1.     The developer shall covenant and agree with  the  City  of
       Santa   Monica  to  the  specific  terms,  conditions  and
       restrictions upon the possession, use and enjoyment of the
       subject property, which terms, conditions and restrictions
       shall be recorded with the Los Angeles  County  Recorder's
       Office  as  a  part  of the deed of the property to ensure
       that two affordable units are provided and maintained over
       time  and  through  subsequent  sales of the property.  An
       affordable unit shall be defined as  being  affordable  to
       households  with  incomes  not exceeding 100% of the (HUD)
       Los Angeles County median income, expending not  over  30%
       of  monthly  income  on housing costs, as specified by the
       Housing  Division  of  the  Department  of  Community  and
       Economic Development.

       This agreement shall be executed  and  recorded  prior  to
       approval  of  the Final Map.  Such agreement shall specify
       1)  responsibilities  of  the  developer  for  making  the
       unit(s) available to eligible tenants and 2) responsibili-
       ties of the City of Santa Monica  to  prepare  application
       forms   for  potential  tenants,  establish  criteria  for
       qualifications,   and   monitor   compliance   with    the
       provicions*of the agreement.

       Owner shall provide the  City  Planning  Division  with  a
       conformed copy of the recorded agreement prior to approval
       of the Final Map.

       This provision is intended  to  satisfy  the  inclusionary
       housing  requirements of Program 12 of the Housing Element
       of the General Plan of the City of Santa Monica  ("Program
       12").   Developer  may  satisfy the obligations created by
       this Agreement by demonstrating to the Director  of  Plan-
       ning  compliance with Ordinance 1448 (CCS), which provides
       implementation standards for Program 12.

Prepared by:  Shari Laham, Associate Planner

Attachments:  A.  Municipal Code and General Plan Conformance
              B.  Radius and Location Map
              C.  Resolution of Certification of EIR
              D.  Statement of Certification of EIR
              E.  Project Description, Submitted by Applicant
              F.  Summary of Project
              G.  Letter from Applicant, dated 2/16/89
              H.  Protest Letter, dated 3/9/89
              I.  Final EIR
              J.  Plot Plan, Floor Plans, Elevations and Section


SL
PC/CUP512
$N-date

ATTACHMENT A

MUNICIPAL CODE AND GENERAL PLAN CONFORMANCE

                               Land Use
Category       Municipal Code  Element             Project

Permitted Use  C4:  General    General             General
               Commercial      Commercial          Office

               R2 & R2A:
               Low-Density     Low-Density         Low-Density
               Residential     Residential         Residential

Commercial     6 stories/90'   4 stories/56;
Height
                               With Site Review:   Site Review:
                               6 stories/84'       6 stories/83'

Residential    2 stories/30'   Same as             2 stories/21'
Height                         Municipal Code

Commercial
Setbacks

  Frontyard    0'              Same as Code        6' - 28'

  Sideyard     0'              Same as Code        20'- 22'(east)
                                                   6' - 8' (west)

  Rearyard     23'             Same as Code        35'-6"

Residential
Setbacks

  Frontyard    20'             Same as Code        20'

  Sideyard      9'             Same as Code        9' - 50'

  Rearyard     15'             Same as Code        15'

Commercial     3.3             2.5;
F.A.R.                         With Site           With Site
                               Review:  3.0        Review:  3.0

Parking        255 commercial                      295 commercial
               spaces;         Same as Code        spaces;

               22 residential                      27 residential
               spaces                              spaces