ITEM 7-A

Council Mtg:  November 10, 1992

TO:       Mayor and City Council

FROM:     City Staff

SUBJECT:  Appeal of Conditional Use Permit 92-007  to  Allow  the
          Issuance of Six Type-41 (On-Sale Beer and Wine) Alcohol
          Licenses for an Eight-Tenant Food  Court  at  1315  3rd
          Street Promenade.
          Applicant:  Christian Title
          Appellant:  Trisha Roth

INTRODUCTION

This report recommends that the City Council deny the appeal  and
uphold  the  Planning  Commission approval of the Conditional Use
Permit.

BACKGROUND

In  November  1989,   the   Zoning   Administrator   granted   an
Administrative   Approval   to  allow  the  construction  of  the
Criterion Theatre Plaza, a five-story, 23,600 square  foot  mixed
use  building  with approximately 9,600 square feet of restaurant
space on the first and second floors,  and  approximately  14,000
square  feet  of office and studio space on the third, fourth and
fifth floors.  The layout of the restaurant space is designed  in
a  food court configuration with eight separate tenant spaces and
a common seating area.  The Administrative Approval was to  allow
the  construction of the project and the restaurant uses, but did
not permit the issuance of alcohol licenses for the restaurants.

In July 1992 the Planning Commission approved a  Conditional  Use
Permit  to  allow the sale and consumption of alcohol in the food
court.  The Commission granted a total of seven  Conditional  Use
Permits;  one  to  allow the consumption of alcohol in the common
seating area and six to allow the sale of alcohol in six  of  the
eight  food  court  spaces.   All  seven  of  the Conditional Use
Permits  were  issued  to  the  building  owner,  who   will   be
responsible  for  the common seating area, as well as the leasing
of the food court spaces.  This arrangement  was  recommended  by
the  City  Attorney's  office.   The Planning Commission approved
the project by a vote of five to two.  The two Commissioners  who
voted   against   the  project  expressed  a  concern  about  the
over-concentration of alcohol outlets in the downtown  area.   On
July 29, 1992 the approval was appealed by Trisha Roth.

Project Design

The food court will consist of eight tenant spaces and 400  seats
in  a  first  and second floor common seating area.  As proposed,
six of the eight tenant spaces would  obtain  a  Type-41  alcohol
license.  The mix of tenants would be as follows:

First Level

       Space "A" - Mesquite Bar-B-Que Grillery (Alcohol License)
       Space "B" - Baja Bud's Mexican Food (Alcohol License)
       Space "C" - Lisa's Cookies & Yogurt (No Alcohol)
       Space "D" - Mon-kee's Chinese Food (Alcohol License)
       Space "E" - La Mocha Gourmet Coffees & Teas (No Alcohol)

Second Level

       Space "F" - Daily Grill (Alcohol License)
       Space "G" - Un-leased (Alcohol License)
       Space "H" - Un-leased (Alcohol License)

While spaces "G" and "H" are not yet  leased,  the  applicant  is
requesting  that  the tenants of the two un-leased spaces be able
to obtain an alcohol license.

In previous meetings with the applicant, staff expressed  concern
about  the  food  court concept of the project in relation to the
ability of the alcohol servers to monitor  customers  after  they
purchase  alcohol  from  an individual restaurant tenant and then
take a seat in the common seating area.  In response, the  appli-
cant has stated in the attached letter (Attachment A), that there
will be bus people and  floor  managers  located  throughout  the
seating  area  who  will monitor customers in relation to alcohol
consumption.

Staff also informed the applicant  that  alcohol  consumption  at
tables  located  along the public passageway could pose a problem
in relation to people passing through the  area.   The  applicant
has  proposed the installation of 42" high barrier rails adjacent
to each passageway table  in  order  to  address  this  potential
problem.    The   Planning  Commission  approval  allows  alcohol
consumption along the public passageway, as long as  the  barrier
rails as proposed by the applicant are installed.

Neither of the two existing food courts located in  the  downtown
area (Eatz at Santa Monica Place and Galleria Gourmet at 1437 3rd
Street Promenade) have alcohol licenses.  However, beer and  wine
is served at other food courts in the Los Angeles area.  As noted
in the applicant's letter, beer and wine is available in the food
court at Westside Pavilion and at Farmer's Market at Third Street
and Fairfax in Los Angeles.  The applicant has  stated  that  the
serving  of  beer and wine at these locations has not resulted in
any problems.  Staff  contacted  the  management  office  of  the
Westside  Pavilion  was told that the management was not aware of
any problems that have resulted from the sale of beer and wine in
the food court area.

The applicant has stated that alcohol typically  accounts  for  a
small  percentage  of  the  gross revenue for food court tenants.
The Planning Commission approved the project  with  a   condition
that  no more than 35% of gross revenues from each tenant be from
alcohol sales.  The applicant has agreed  to  this  condition  of
approval.

In response to a request for comments from the Police  Department
about  the  outlet,  a  representative  stated  that the data the
Police Department has  gathered  does  not  lead  to  a  negative
recommendation and the department does not have specific comments
about  this  particular  application.   Further,   although   the
department  has  concerns  about the number of alcohol outlets in
the Promenade area, it recognizes that the Council has  addressed
this  issue by adopting a moratorium on additional outlets in the
Bayside District.

Parking

The Zoning Ordinance parking requirements for the restaurant uses
would  normally  be  128  spaces, based on a ratio of one parking
space for every 75 square  feet  of  floor  area.   However,  the
project  is  located  in the Downtown Parking Assessment District
and is not required to provide parking.  According to the Parking
Demand  Analysis  for the Third Street Promenade/Bayside District
prepared by Kaku Associates in May 1991, at that  time,  the  six
City  parking  structures were operating at a weekday peak of 60%
occupancy, resulting in a surplus of 1252 parking spaces,  and  a
weekend  peak  occupancy  of  61%, resulting in a surplus of 1228
parking spaces.  Based on the surplus of available parking in the
structures,  the facility is not expected to result in a shortage
of parking.  Furthermore, the types of establishments planned for
the food court are not intended to be destination points, but are
more likely to be utilized by office  workers,  theatre  patrons,
and other people who are already in the area.

Alcohol License

Within a 500' radius of the site, there are six Type-41  (on-sale
beer  and  wine  for  public  eating place) alcohol licenses, ten
Type-47 (on-sale general for public eating place) alcohol  licen-
ses,  and  one  Type-48 (on-sale general for public premises) al-
cohol license.  These include the following:

Type-41 (On-Sale Beer and Wine for Public Eating Place)

Pizza Contorni   (176 seats) 1333 2nd Street
Taka Sushi        (58 seats) 1345 2nd Street
Cibo              (50 seats) 1246 3rd Street
Gaucho Grill      (82 seats) 1251 3rd Street
Bravo Cucina      (80 seats) 1319 3rd Street
Papa George's     (50 seats) 1321 3rd Street
Vic's Restaurant  (99 seats) 1333 3rd Street
Early World       (75 seats) 401 Santa Monica Blvd.

Type-47 (On-Sale General for Public Eating Place)

3rd Street Pub   (105 seats) 1240 3rd Street
Legend's         (300 seats) 1311 3rd Street
Teaser's         (150 seats) 1351 3rd Street
Trilussa         (360 seats) 1360 3rd Street
King George      (117 seats) 301 Santa Monica Blvd.
Amazon Grill      (49 seats) 307 Santa Monica Blvd.
Jazz Club        (393 seats) 309 Santa Monica Blvd. (Not Open)
Tony Roma's      (105 seats) 319 Santa Monica Blvd.

Type-48 (On-Sale General for Public Premises)

The Improv       (875 seats) 321 Santa Monica Blvd.

According to the 1990 Census, there is a  residential  population
of 185 people within a 500' radius of the site.

Bayside District Specific Plan Update

In June 1992, the Planning Commission made recommendations to the
City Council on the update to the Bayside District Specific Plan.
The Commission's comments included a  recommendation  that,  with
the  exception of four pending applications, there be no more al-
cohol outlets approved in  the  Bayside  District  Specific  Plan
area.  The Conditional Use Permit for the Criterion Theater Plaza
food court was one of the pending applications that the  Planning
Commission  exempted  from  their recommendation.  As stated pre-
viously, in July 1992 the Planning Commission approved  a  Condi-
tional Use Permit for the food court alcohol licenses.

On September 15, 1992, the City Council adopted an emergency  or-
dinance (Ordinance 1644 (CCS)) establishing a limit on the number
of alcohol and food serving establishments in  the  Bayside  Dis-
trict.  The Council's limit allowed for two additional outlets in
the 1300 block of the  Promenade.   On  September  29,  1992  the
Council approved a Conditional Use Permit for Vic's Restaurant at
1333 3rd Street  Promenade.   The  approval  of  Vic's  left  one
available  outlet  in  the  1300  block  of  the  Promenade.  The
remaining available outlet has  been  intended  for  the  subject
application.   In  terms  of  the  Planning  Commission  and City
Council discussion, even though the proposed project includes six
alcohol  licenses  and  seven  Conditional  Use  Permits,  it  is
considered one alcohol "outlet".

Appeal

The  appellant  filed  the  appeal  of  the  Planning  Commission
approval  based  on  several  concerns  relating  to the sale and
consumption of alcohol.  As stated in the  attached  appeal  form
dated  07/29/92 (Attachment B), the appellant has raised concerns
about what she feels is an over-concentration of alcohol  outlets
in  the  area,  the  lack  of  local  police  and ABC enforcement
personnel, a failure to enforce health code  warnings,  the  high
cost  of  alcohol  versus the financial benefit to the community,
sales of alcohol to minors and potential increased gang activity.

The City Council has addressed the  over-concentration  issue  in
the  downtown area by establishing a limit on the total number of
alcohol outlets.  The appellant has raised several issues  relat-
ing  to  enforcement  and health issues, but it is not clear from
the information submitted  by  the  appellant  how  the  proposed
licenses  will result in increased enforcement problems or health
risks.  The proposed alcohol licenses will be for  a  food  court
where the service of alcohol will be ancillary to the primary use
of the  premises  as  a  food  serving  facility.   The  Planning
Commission  approved  the  project  with several conditions which
will  ensure  that  the  project  will  be  compatible  with  the
existing uses in the surrounding area.

Conclusion

The issuance of type-41 alcohol licenses for the food court  ten-
ants  complies  with  the provisions of the Zoning Ordinance, the
existing Third Street Mall Specific Plan,  the  proposed  Bayside
District  Specific  Plan and Ordinance 1644.  Adequate parking is
available in the City parking structures.  With  the  recommended
conditions  of approval, the use will be compatible and will com-
pliment existing uses in the Bayside District.

PUBLIC NOTIFICATION

Pursuant to Municipal Code Section 9130.8, within 30  days  after
the subject application was deemed complete, the applicant posted
a sign on the property as required.   In  addition,  pursuant  to
Municipal  Code  Section 9131.5, notice of the public hearing was
mailed to all owners and residential and  commercial  tenants  of
property located within a 500 foot radius of the project at least
ten consecutive calendar days prior to the hearing.   A  copy  of
the notice is contained in Attachment C.

BUDGET/FINANCIAL IMPACT

The recommendation presented in this report  does  not  have  any
budget or fiscal impact.

RECOMMENDATION

It is respectfully recommended that the Council deny  the  appeal
and  uphold  the  Planning Commission approval of Conditional Use
Permit 92-007 with the findings and conditions contained  in  the
Planning  Commission Statements of Official Action (Attachments D
and E).

Prepared by:  D. Kenyon Webster, Planning Manager
              David Martin, Associate Planner
              Planning Division
              Land Use and Transportation Management Department

Attachments:  A.  Letter from applicant
              B.  Appeal form dated 07/29/92
              C.  Notice of Public Hearing
              D.  Statement of Official Action for CUP 92-007
              E.  Statement of Official Action for CUP 92-007a