Beverly Hills City Council
February 6, 2024

transmittal, the City is obligated under State law to continue to process the Project’s DPR Application as filed.

I. The Project Enjoys Vested Rights Pursuant to SB 330.

As acknowledged by the Deemed Incomplete Letter, on October 21, 2022, pursuant to Government Code Section 65941.1, the Applicant submitted a preliminary application (“PA”) to the City, which described the proposed Project as a 16-story, 200-unit development project (40 units [20 percent] of which would be deed restricted to lower income households) containing 259,547 square feet (“PA Project”), and on October 24, 2022, the City received the Applicant’s fee payment associated with the PA submittal, thereby establishing vested rights under the ordinances, policies, and standards adopted and in effect as of October 24, 2022.

On April 24, 2023, the Applicant filed the DPR Application with the City for the DPR Project, which is a proposed 19-story mixed use, multifamily residential and hotel building, with 165 rental apartment units (including 33 affordable housing units) and ancillary residential spaces, 73 hotel rooms and ancillary hotel spaces including a restaurant use. The DPR Application was submitted within the 180- day period following the submittal of the PA, as prescribed by Government Code Section 65941.1(d)(1).

Accordingly, the Project’s October 24, 2022 vesting date was maintained.

However, as noted above, the Deemed Incomplete Letter asserts that the Project no longer possesses vested rights due to the Applicant’s modifications to the PA Project, including the introduction of a hotel use. To support this claim, the City cites language from Government Code Section 65941.1(a)(4), which specifies that a PA is required to provide information regarding “the proposed land uses” included in a development project. By the City’s logic, because the DPR Project contains additional land uses (i.e., hotel and restaurant uses) as compared to the PA Project, the PA no longer has any vesting effect. This represents an entirely incorrect reading of SB 330’s statutory provisions by the City.

The City’s claim that the PA and its vesting protections are no longer in effect because new land uses were introduced for the DPR Project is without merit, as the language of Government Code Section 65941.1(a)(4) is not relevant to any determination regarding a loss of vesting. Instead, the solely relevant statutory language regarding changes to a project description contained in a PA that forfeit vested rights is provided by Government Code Section 65941.1(c), which states:
“After submittal of all of the information required by subdivision (a), if the development proponent revises the project such that the number of residential units or square footage of construction changes by 20 percent or more, exclusive of any increase resulting from the receipt of a density bonus, incentive, concession, waiver, or similar provision, the housing development project shall not be deemed to have submitted a preliminary application that satisfies this section until the development proponent resubmits the information required by subdivision (a) so that it reflects the revisions. For purposes of this subdivision, “square footage of construction” means the building area, as defined by the California Building Standards Code (Title 24 of the California Code of Regulations).4
(Emphasis added).
4 Government Code Section 65941.1(c).

Edgar Arroyo
August 9, 2023

The PA Project consisted of a residential project that included 200 dwelling units within a 259,547 square foot, 16-story building. The DPR Project consists of a mixed-use development that includes 165 dwelling units and a 73-room hotel and hotel restaurant within a 311,197 square foot, 19- story building. The number of residential units was reduced from 200 in the PA Project to 165 in the DPR Project (a 17.5 percent decrease), and the square footage of construction was increased from 259,547 square feet in the PA Project to 311,197 square feet in the DPR Project (a 19.9 percent increase). These revisions are within the 20 percent threshold set forth in Government Code Section 65941.1, and do not require the Applicant to resubmit information required by Section 65941.1(a). Therefore, the vesting protections established by the PA continue to apply to the Project.

II. The Builder’s Remedy Provision of the HAA Applies to the Project.

As you know, the City’s Housing Element is currently out of compliance with State Housing Element law requirements.
5 Under the Builder’s Remedy provision of the HAA, if a jurisdiction lacks a substantially compliant Housing Element, it cannot use its objective general plan, specific plan or zoning regulations to deny or render infeasible an affordable housing development project (i.e., a housing development project that provides at least 20 percent of the total units to lower income households, as defined by Health and Safety Code Section 50079.5). The Project is a 165-unit mixed-use development with 20 percent of the units (33 units) affordable to lower income households. Because the residential portion equates to approximately 77 percent of the Project, the Project qualifies as a “housing development project” under the HAA.
6 The DRP Application explicitly states that the Project is proposed pursuant to the Builder’s Remedy provision of the HAA, as the City lacked a substantially compliant Housing Element at the time of the PA. Furthermore, the Project retains vesting rights under the ordinances, policies, and standards adopted and in effect at the time the PA was submitted on October 24, 2022; these vested ordinances, policies and standards include the City’s noncompliant Housing Element status, as confirmed by HCD. 7 Therefore, the City cannot escape its obligation to process the Project pursuant to the mandates of the HAA and the Builder’s Remedy.

Furthermore, since the Applicant’s submittal of the DPR Application, HCD has clarified that a jurisdiction does not have the authority to determine that its adopted Housing Element is in substantial compliance (e.g., a jurisdiction cannot “self-certify”). Specifically, HCD’s March 16, 2023 Memorandum titled “Summary and Clarification of Requirements for Housing Element Compliance” clearly states that:
[A] jurisdiction is “in compliance” as of the date of HCD’s letter finding the adopted element in substantial compliance. Any other letters are not a finding of substantial compliance. 5 In a letter to the City dated May 12, 2023, the State’s Department of Housing and Community Development (“HCD”) found that the City’s 6th Cycle Adopted Housing Element, adopted February 21, 2023, does not substantially comply with State Housing Element law. HCD’s May 12, 2023 letter also stated that “[b]y no means was the City’s prior submittal [adopted October 15, 2021] in substantial compliance with State Housing Law,” and the “City’s findings as part of the adoption are inadequate to demonstrate substantial compliance with statutory requirements; therefore, revisions to the element continue to be necessary to substantially comply with State Housing Element Law.”
6 Government Code Section 65589.5(h)(2)(B). 7 HCD Letter of Technical Assistance Letter to Rand Paster & Nelson LLP, dated October 5, 2022.

Edgar Arroyo
August 9, 2023

However, notwithstanding the City’s indisputably noncompliant status, the City has chosen to ignore its obligations under the Builder’s Remedy. Specifically, the Deemed Incomplete Letter states that the Project requires a General Plan Amendment, Zone Change, and possibly other entitlements because the DPR Project does not “conform to the City’s General Plan and various provisions of the City’s zoning code.” The Deemed Incomplete Letter goes on to identify use limitations, height limitations, and maximum permitted density limitations, and other standards to which the Project would need to adhere. However, as the City knows, under the Builder’s Remedy, a City cannot use its objective general plan, specific plan or zoning regulations to deny or render infeasible an affordable housing development project. The standards the City cites as noncompliant in the Deemed Incomplete Letter are, by definition, the “objective general plan, specific plan or zoning regulations” that cannot be used to deny or render infeasible an affordable housing project such as the Project.

HCD has also provided guidance directly addressing this topic in its June 8, 2023 letter to the City of La Cañada Flintridge, stating:

Government Code section 65589.5, subdivision (d)(5), allows a local agency to disapprove an affordable housing project that ‘is inconsistent with both the jurisdiction’s zoning ordinance and general plan land use designation as specified in any element of the general plan’ if ‘the jurisdiction has adopted a revised housing element … that is in substantial compliance….’ HCD then goes on to explicitly clarify:

If HCD does not find a local jurisdiction’s adopted housing element in substantial compliance by the statutory deadline, the jurisdiction cannot use subdivision (d)(5) of Government Code section 65589.5 (inconsistency with zoning and general plan standards) as a basis to deny a qualifying affordable housing project.

Therefore, based on the provisions of the Builder’s Remedy itself as well as recent HCD guidance the City cannot use inconsistency with zoning and general plan standards to deny or render infeasible the Project as currently proposed.

III. A Second Prong of the Builder’s Remedy Also Applies to the Project.

As detailed above, neither the Applicant nor HCD agree with the City’s claim that its Housing Element somehow substantially complies with State Housing Element law. Nevertheless, and assuming only for the sake of argument that any “self-certification” argument advanced by the City to claim that its Housing Element somehow could be considered in substantial compliance because it has satisfied the bare minimum legal criteria required under State Housing Element law, the City’s required Suitable Sites Inventory (“SSI”) of sites that can accommodate the City’s Regional Housing Needs Allocation (“RHNA”) remains severely deficient. This deficiency alone disqualifies the City from rejecting the Project.

Specifically, Government Code Section 65589.5(d)(5)(B) limits a local agency’s ability to deny General Plan/zoning noncompliant housing projects – even if the local agency arguably has a substantially compliant Housing Element – if the local agency has failed to adequately meet and plan for its 6th Cycle RHNA requirements. Section 65589.5(d)(5)(B) states:

Edgar Arroyo
August 9, 2023

(d) A local agency shall not disapprove a housing development project, including farmworker housing as defined in subdivision (h) of Section 50199.7 of the Health and Safety Code, for very low, low-, or moderate-income households, or an emergency shelter, or condition approval in a manner that renders the housing development project infeasible for development for the use of very low, low-, or moderate-income households, or an emergency shelter, including through the use of design review standards, unless it makes written findings, based upon a preponderance of the evidence in the record, as to one of the following
(5) The housing development project or emergency shelter is inconsistent with both the jurisdiction's zoning ordinance and general plan land use designation as specified in any element of the general plan as it existed on the date the application was deemed complete, and the jurisdiction adopted a revised housing element in accordance with Section 65588 that is in substantial compliance with this article. For purposes of this section, a change to the zoning ordinance or general plan land use designation subsequent to the date the application was deemed complete shall not constitute a valid basis to disapprove or condition approval of the housing development project or emergency shelter.
(B) If the local agency has failed to identify in the inventory of land in its housing element sites that can be developed for housing within the planning period and are sufficient to provide for the jurisdiction's share of the regional housing need for all income levels pursuant to Section 65584, then this paragraph shall not be utilized to disapprove or conditionally approve a housing development project proposed for a site designated in any element of the general plan for residential uses or designated in any element of the general plan for commercial uses if residential uses are permitted or conditionally permitted within commercial designations. In any action in court, the burden of proof shall be on the local agency to show that its housing element does identify adequate sites with appropriate zoning and development standards and with services and facilities to accommodate the local agency's share of the regional housing need for the very low, low-, and moderate-income categories. (Emphasis added.)
The Site is designated for High Density Multi-Family Residential uses under the City’s General Plan Land Use Element, and 20 percent of the Project’s 165 units (i.e., 33 units) would be set aside for Low Income households. It is also abundantly clear that the City cannot meet its burden to demonstrate an adequate SSI. The City’s proposed SSI continues to rely on sites that are widely unrealistic locations for future residential development, including sites that have virtually no potential to be redeveloped for housing in the next eight years.
8 HCD has repeatedly communicated these concerns to the City: for example, HCD’s January 14, 2022 comment letter to the City specifically calls out the City’s SSI, stating “the element does not provide sufficient analysis to demonstrate existing uses will discontinue in the 8 City of Beverly Hills, Adopted Amended Housing Element 2021-2029 (Feb. 21, 2023), Exhibit A: Table C-3 Sites Inventory.

Edgar Arroyo
August 9, 2023

planning period, analyze existing leases or contracts that would prevent redevelopment of sites, or provide evidence of the City’s past experience with converting existing uses to higher density residential development.” Similarly, HCD’s November 28, 2022 comment letter again highlights the City’s inadequate analysis of the suitability of nonvacant sites, stating that the City “must still support the potential for additional residential development on the sites remaining in the inventory. This is especially significant given that the sites inventory includes parcels that seem to have viable businesses including medical uses, Class A and B office buildings, and stores including a Starbucks, Neiman Marcus, and CVS with little to no analysis on the likelihood of these uses discontinuing during the planning period.” However, the City has ignored HCD’s comments by continuing to rely on sites occupied by viable commercial businesses and medical uses without the required evidence to support the inclusion of these sites on the SSI.

If these deficient sites were removed from the SSI, the City’s income category totals would be reduced by hundreds of units and would not come close to satisfying the City’s RHNA allocation of 1,688 lower income units. As a result, instead of the current SSI’s claimed 10-unit surplus of lower income units, the City would in fact have a significant deficit for this income category. Thus, the City cannot meet its legal burden under Government Code Section 65589.5(d)(5)(B) to demonstrate an adequate SSI as a basis to deny the Project.

HCD has confirmed the applicability of this second Builder’s Remedy prong to the Project. On June 20, 2023, HCD issued technical guidance in response to a request from our firm confirming that:

The requirement for an adequate sites inventory under subdivision (d)(5)(B) is an additional limitation on the utilization of Government Code section 65589.5, subdivision (d)(5), to support a denial under the Housing Accountability Act. Specifically, if the City has failed to identify adequate sites to provide for the RHNA for all income levels, then Government Code section 65589.5, subdivision (d)(5) cannot be used to disapprove or conditionally approve a housing development project proposed for a site designated in any element of the general plan for residential uses or designated in any element of the general plan for commercial uses if residential uses are permitted or conditionally permitted within commercial designations.

Please note that HCD’s May 12, 2023, review of the housing element found that the City did not demonstrate an adequate sites inventory to meet its RHNA obligation because of its incomplete analysis demonstrating the adequacy of its realistic capacity methodology, the unsuitability of nonvacant sites, and its calculations of accessory dwelling units. (Emphasis added).

With this guidance, HCD has confirmed that even if a court of law could somehow determine, over HCD’s repeated non-compliance determinations and a large body of evidence to the contrary, that the City somehow has adopted a substantially compliant Housing Element, Government Code Section 65589.5 (d)(5)(B) would still compel approval of the Project based on the City’s inability to meet its burden to demonstrate an adequate SSI.

IV. The Deemed Incomplete Letter Constitutes a Violation of the PSA.

As described above, the Deemed Incomplete Letter claims that the DPR Application is incomplete because the Project was inconsistent with General Plan and zoning standards. However, as HCD explained in its June 8, 2023 guidance letter to the City of La Cañada Flintridge, inconsistency with Edgar Arroyo
August 9, 2023

local zoning standards is a reason to deny an application in some circumstances (absent application of the Builder’s Remedy), but it is not a basis for deeming an application incomplete. Therefore, in addition to the clear SB 330 and HAA violations cited above, the Deemed Incomplete Letter also conflicts with Section 65943 (a) of the PSA.

V. The City’s Actions Are Placing It at Legal Risk.

California courts are enforcing the applicability of the Builder’s Remedy in noncompliant jurisdictions. Recently, the Los Angeles County Superior Court in Californians for Homeownership v. City of La Cañada Flintridge (July 10, 2023, Case No. 23STCP00699) held that the Builder’s Remedy is a legitimate remedial penalty for cities that lack a legally compliant Housing Element. The court further noted that declaratory relief to determine the applicability of the Builder’s Remedy is a proper remedy for affordable housing development proponents in jurisdictions lacking a compliant Housing Element.

The cities of La Cañada Flintridge and Beverly Hills have taken a strikingly similar approach to Housing Element compliance. Both jurisdictions have failed to adopt substantially compliant Housing Elements and obtain HCD’s certification prior to the statutory deadline. Both cities have consistently refused to take meaningful action to meet their State mandated housing requirements and have instead embraced a policy of wishful thinking by self-declaring – without proper legal support or backup – that their Housing Elements are somehow compliant notwithstanding HCD’s refusal to certify. And both cities have chosen to completely ignore the HAA’s clear penalties for noncompliance by refusing to properly process timely filed Builder’s Remedy project applications. The Superior Court’s message to La Cañada Flintridge in Californians for Homeownership is directly applicable to the City and its failure to process the Project pursuant to the Builder’s Remedy:

The HAA contains builder’s remedy that limits a city’s ability to deny a development for low-cost housing unless it has a substantially compliant housing element. §65589.5(d)(1), (d)(5). These penalties make all the difference in interpreting section 65583’s [Housing Element law] deadlines, which are now mandatory and not directory. (Tentative Ruling, 7-10-23, p.24).

V. Conclusion.

The Project’s DPR application is the appropriate mechanism for the City to review the Project pursuant to the Builder’s Remedy provisions of the HAA. General Plan Amendments and/or Zone Changes may not be legally required.

However, notwithstanding the above we emphasize that the Project materials have been modified in response to other comments noted in the City’s Deemed Incomplete Letter. Specifically, the Applicant revised the Project plans to provide additional information, dimensions, and/or illustrations in response to the City’s requests. The attachments provided with this submittal clearly indicate which objective general plan, specific plan or zoning regulations are not applicable to the Project. Additional application materials and studies have also been provided in response to the Deemed Incomplete Letter. As noted in the Deemed Incomplete Letter, we would expect the City to continue with its review and as a next step determine what type of environmental review should be required pursuant to the California Environmental Quality Act. The Applicant will provide additional materials and studies as determined to be appropriate at that time.

Edgar Arroyo
August 9, 2023

Please contact us with any questions about this transmittal. Thank you.

Sincerely,
Dave Rand
Dave Rand
Partner
of RAND PASTER & NELSON, LLP
Attachments
A – HCD Letters and Memorandums
B – Written Responses to Deemed Incomplete Letter Comments C – Revised Project Plans including Survey and Landscape D – Title Report
E – Transportation Assessment
F – Geotechnical Report
G – Construction Management Plan Draft
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM., Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov

MEMORANDUM
DATE: March 16, 2023
TO: Planning Directors and Interested Parties
FROM: Megan Kirkeby, Deputy Director
Division of Housing Policy Development
SUBJECT: Summary and Clarification of Requirements for Housing Element Compliance
HCD is committed to diligently reviewing all 539 local jurisdictions’ housing elements for substantial compliance with State Housing Element Law. To comply with State Housing Element Law and avoid the consequences of noncompliance, a local jurisdiction must, among other things:

1. Submit a draft housing element to HCD at least 90 days before adoption1 and receive findings from HCD determining whether the draft element is substantially compliant,2 and consider HCD’s findings before adopting the draft element.3 In other words, where a jurisdiction submits an “adopted” housing element before submitting an initial draft or before considering HCD’s findings on an initial draft, HCD will consider the “adopted” to be an initial draft for purposes of both HCD’s review and the jurisdiction’s statutory compliance.

2. If HCD finds the draft element is not substantially compliant, revise the draft to address any findings by HCD4 or adopt without changes and include written findings explaining why the jurisdiction believes that the draft substantially complies.5 Promptly following adoption, submit the adopted housing element to HCD6 and receive findings on the adopted element from HCD.7
1 Gov. Code, § 65585, subd. (b)(1)
2 Gov. Code, § 65585, subds. (b)(3), (d)
3 Gov. Code, § 65585, subd. (e)
4 Gov. Code, § 65585, subd. (f)(1)
5 Gov. Code, § 65585, subd. (f)(2)
6 Gov. Code, § 65585, subd. (g)
7 Gov. Code, § 65585, subd. (h)
Summary and Clarification of Requirements for Housing Element Compliance

In other words, a jurisdiction does not have the authority to determine that its adopted element is in substantial compliance but may provide reasoning why HCD should make a finding of substantial compliance.

In addition, a jurisdiction is “in compliance” as of the date of HCD’s letter finding the adopted element in substantial compliance. Any other letters are not a finding of substantial compliance.

HCD recommends that a jurisdiction adopt only after receiving a letter from HCD finding the draft meets statutory requirements.

For more detailed information about this process, please visit HCD’s Housing Elements webpage and Housing Elements Building Blocks.

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
June 8, 2023
Mark R. Alexander, City Manager
City of La Cañada Flintridge
One Civic Center Drive
La Cañada Flintridge, CA 91011
Dear Mark R. Alexander:

RE: City of La Cañada Flintridge Denial of 600 Foothill Boulevard Housing Project – Notice of Violation
The California Department of Housing and Community Development (HCD) writes to notify the City of La Cañada Flintridge (City), and its City Council, that it is in violation of State Housing Element Law and the Housing Accountability Act (HAA) (Gov. Code, § 65589.5). This violation occurred when the City, despite technical assistance from HCD, denied an appeal related to the application of the housing project at 600 Foothill Boulevard (Project). The City did so by adopting Resolution 23-14, which purports to uphold the Planning Division’s incompleteness determination for the Project application, issued on March 1, 2023.

The basis for the City’s denial includes, among other findings:

1. that Government Code section 65589.5, subdivision (d)(5), colloquially referred to as the Builder’s Remedy, does not apply and is not available for the Project; and

2. that the Project did not “vest” as a Builder’s Remedy project as alleged in the Project’s preliminary application because the City’s housing element, adopted on October 4, 2022 (October 4, 2022, Adopted Housing Element), was in compliance with State Housing Element Law (Gov. Code, § 65580 et seq.).

Based on HCD’s review of pertinent information in the City’s own staff report, these findings are flawed. The City cannot “backdate” its housing element compliance date to an earlier date so as to avoid approving a Builder’s Remedy application. In short, the October 4, 2022 Adopted Housing Element did not substantially comply with State Housing Element Law, regardless of any declaration by the City. Therefore, the Builder’s Remedy applies, and the City’s denial of the Project application based on inconsistency with zoning and land use designation is a violation of the HAA.

Mark R. Alexander, City Manager

HCD further reminds the City that, as of the date of this letter, the City remains out of compliance with Housing Element Law unless and until it completes statutorily required rezoning.

Background
The Project is proposed as an 80-unit mixed-use project where 20 percent of the units (16 units) will be affordable to lower-income households. The residential portion equates to approximately 89 percent of the Project; therefore, the Project qualifies as a “housing development project” under the HAA (Gov. Code, § 65589.5, subd. (h)(2)(B)). The base density proposed for this Project is approximately 40.5 units per acre before the application of density bonus under State Density Bonus Law (Gov. Code, §§ 65915- 65918). HCD understands the timeline for the Project as follows:
• On November 11, 2022, pursuant to Government Code section 65941.1, the Project applicant submitted a preliminary application that was vested on November 14, 2023, after payment of application fees.
• A full application was submitted to the City for the Project on January 13, 2023, and fees were paid on the invoice on January 31, 2023. By submitting this full application within the 180-day period prescribed by Government Code section 65941.1, subdivision (d)(1), the applicant established November 14, 2023 (the date it submitted the preliminary application) as the vesting date of the application.
• On February 10, 2023, the City’s planning division issued the first incompleteness letter on this application, which cited information required for the site plan, floor plan, elevation, landscape plans, grading plans, and the density bonus application, among other things. The letter did not comment on density or development standards relating to the Mixed-Use 2 designation. • On March 1, 2023, the City’s planning division issued a second incompleteness letter that further found that the Builder’s Remedy would not apply to the Project, that the Project was therefore inconsistent with the Mixed-Use 2 designation, and that the applicant must submit revised plans and materials based on a density of 12-15 units per acre.
• On March 9, 2023, the applicant appealed this incompleteness letter to the City Council.
• On March 22, 2023, HCD provided a Letter of Technical Assistance to the City to help with decision-making related to this appeal.
• On May 1, 2023, the City Council heard and denied the appeal by adopting Resolution 23-14. The Resolution found the following:
o the Builder’s Remedy under the HAA did not apply and is not available for the Project; and
o the Project did not “vest” as a Builder’s Remedy project as alleged in the Project’s SB 330 Preliminary Application (submitted November 14, 2022) because the City’s October 4, 2022 Adopted Housing Element was in substantial compliance with State Housing Element Law, regardless of HCD’s finding to the contrary.

Mark R. Alexander, City Manager

Housing Element Compliance
The City’s determination that the October 4, 2022 Adopted Housing Element was in substantial compliance with State Housing Element Law is incorrect and unsupported by law. Pursuant to Government Code section 65585, a local jurisdiction must first submit a draft housing element to HCD and receive HCD’s findings before formally adopting a revised housing element. If HCD finds the draft element is not substantially compliant, the local jurisdiction must revise the draft to address any findings by HCD (Gov. Code, § 65585, subd. (f)(1)) or adopt the housing element without changes and include written findings explaining why the local jurisdiction believes that the draft substantially complies (Gov. Code, § 65585, subd. (f)(2)). Promptly following adoption, the local jurisdiction must submit the adopted housing element to HCD (Gov. Code, § 65585, subd. (g)) and receive findings on the adopted element from HCD (Gov. Code, § 65585, subd. (h)). The following represents the record of housing element submittals to HCD and HCD’s formal responses.
• October 6, 2021 – The City submitted the initial draft housing element to HCD. • October 15, 2021 – Due date of 6th cycle housing element per State Housing Element Law.
• December 3, 2021 – Pursuant to Government Code section 65585, subdivision (b), HCD found the draft housing element required significant revisions to substantially comply with State Housing Element Law.
• October 4, 2022 – The City adopted a housing element that failed to address adequately the findings in HCD’s letter of December 3, 2021. The resolution adopting the housing element made none of the findings required by Government Code section 65585, subdivision (f)(2).
• October 7, 2022 – The City submitted the October 4, 2022 Adopted Housing Element for HCD’s review.
• December 6, 2022 – HCD found the October 4, 2022 Adopted Housing Element required critical revisions to comply with state law, including additional analysis to demonstrate the adequacy of the sites included in its site inventory and policy and programmatic changes pursuant to Government Code section 65585, subdivision (h).
• February 21, 2023 – The City adopted a housing element which addressed adequately the findings in HCD’s December 6, 2022 letter. As part of this adoption, the City further stated that the City’s housing element was in substantial compliance with State Housing Element law as of the October 4, 2022 Adopted Housing Element.
• February 23, 2023 – The City submitted the revised, adopted housing element for HCD’s review.
• April 24, 2023 – HCD found the revised adopted housing element was not in substantial compliance pursuant to Government Code section 65585, subdivision (b). HCD made this finding because the City adopted the element on February 21, 2023, more than one year past the statutory due date of October 15, 2021. As a result, and pursuant to Government Code section Mark R. Alexander, City Manager

65588, subdivision (e)(4)(C)(iii), the City must complete required rezones in Program 1 (Adequate Residential Sites to Accommodate the Regional Housing Needs Allocation (RHNA), Program 4 (Downtown Village Specific Plan), Program 5 (Religious Institution Housing Overlay), and Program 6 (By Right Approval for Projects with 20 percent Affordable Units) prior to being found in substantial compliance.

A local jurisdiction has no authority to determine that its adopted element is in substantial compliance with State Housing Element Law.
1 It may, however, provide
reasoning why HCD should make a finding of substantial compliance (Gov. Code, § 65585, subd. (f)(2)). As stated in HCD’s letter dated March 22, 2023, a local jurisdiction is “in compliance” as of the date of HCD’s letter finding the adopted element in substantial compliance. A local jurisdiction cannot “backdate” compliance to the date of its adoption of a housing element.
2 Moreover, by revising its October 4, 2022 Adopted
Housing Element (in response to HCD’s findings made on December 6, 2022), the City directly contradicted its declaration that that Adopted Housing Element substantially complied with State Housing Element Law. In short, the October 4, 2022 Adopted Housing Element did not substantially comply with State Housing Element Law, regardless of any declaration by the City.

Housing Accountability Act (HAA)
Resolution 23-14 improperly blocks the Project applicant from utilizing protections provided in the HAA. Pursuant to Government Code section 65589.5, subdivision (d), a jurisdiction shall not disapprove a housing development project for very low-, low-, or moderate-income households3 or condition approval in a manner that renders the housing development project infeasible unless it makes written findings, based upon a preponderance of the evidence in the record, as to one of five findings in subdivision (d).

If HCD does not find a local jurisdiction’s adopted housing element in substantial compliance by the statutory deadline, the jurisdiction cannot use subdivision (d)(5) of Government Code section 65589.5 (inconsistency with zoning and general plan standards) as a basis to deny a qualifying affordable housing project. 1 See “Housing Compliance Memo,” State Department of Housing and Community Development, March 16, 2023. https://www.hcd.ca.gov/sites/default/files/docs/planning-andcommunity/memos/HousingElementComplianceMemo03162023.pdf. 2 Ibid. 3 “Housing for very low-, low-, or moderate-income households” means that either (A) at least 20 percent of the total units shall be sold or rented to lower-income households, as defined in Section 50079.5 of the Health and Safety Code, or (B) 100 percent of the units shall be sold or rented to persons and families of moderate income as defined in Section 50093 of the Health and Safety Code, or persons and families of middle income, as defined in Section 65008 of this code (Gov. Code, § 65589.5, subd. (h)(3)).

Mark R. Alexander, City Manager

Government Code section 65589.5, subdivision (d)(5), allows a local agency to disapprove an affordable housing project that “is inconsistent with both the jurisdiction’s zoning ordinance and general plan land use designation as specified in any element of the general plan” if “the jurisdiction has adopted a revised housing element … that is in substantial compliance….” Here, because the City does not have a substantially compliant housing element, it may not disapprove an affordable housing project for inconsistency with the zoning and land use designation.

Pursuant to Government Code section 65941.1, subdivision (a), the submittal of a complete preliminary application vests the right to develop a housing development project in accordance with the ordinances, policies, and standards in effect when a preliminary application is submitted (Gov. Code, § 65589.5, subd. (o)(1)). Therefore, if the preliminary application submittal occurs at a time when the jurisdiction does not have a compliant housing element, and the development submittal occurs within the 180-day required period thereafter (Gov. Code, § 65941.1, subd. (d)(1)), the jurisdiction cannot rely upon zoning and land use standards to deny an affordable housing project because the jurisdiction’s noncompliant status was vested, and shall remain, throughout the entitlement process. This rule applies even if the jurisdiction subsequently achieves compliance.

As the adopted housing element was not in substantial compliance as of November 14, 2022 (the date of preliminary application submittal), the City cannot use Government Code section 65589.5, subdivision (d)(5), to deny the project.

Yet on March 1, 2023, the City issued an incompleteness letter that found that the Builder’s Remedy would not apply to the Project, that the Project was therefore inconsistent with the land use designation, and that as a result, the applicant must submit revised plans.4 On May 1, 2023, the City Council denied the applicant’s appeal by adopting Resolution 23-14, which found that the Builder’s Remedy did not apply. Although the City Council did not directly vote on or deny a proposed housing development on the site, Resolution 23-14 upheld the planning division’s March 1, 2023 letter, which denied the 80-unit Project as submitted and directed the applicant to submit new site plans and a new project consistent with the Mixed-Use 2 zone density of 12-15 units per acre.

The City’s adoption of Resolution 23-14 therefore effectively denied the Project as proposed in violation of the HAA (Gov. Code, § 65589.5, subds. (d) and (h)(6)(A)). 4 The City’s March 1, 2023, letter appears to incorrectly determine the Project application was incomplete because the Project was inconsistent with zoning standards. Inconsistency with local zoning standards is a reason to deny an application in some circumstances, but it is not a basis for deeming an application incomplete. The City’s finding therefore conflicts with the Permit Streamlining Act (Gov. Code, § 65943, subd. (a)) and the HAA (Gov. Code, § 65941.1, subd. (d)(1)).

Mark R. Alexander, City Manager

Conclusion
The City violated state law by claiming, without any factual or legal justification, that the Builder’s Remedy did not apply to the Project application (Gov. Code, § 65589.5, subd. (d)(5)). In addition, pursuant to HCD’s housing element findings letter dated April 24, 2023, the City remains out of compliance with State Housing Element Law. Please note HCD’s review of the May 1, 2023, action to deny the appeal of the March 1, 2023 letter was made in furtherance of, and limited to, a determination of the City’s compliance with State Housing Element Law and the HAA. Accordingly, HCD expresses no opinion as to whether the City has complied with, or is excused from, any other provisions of the Government Code governing review and approval of development applications.

Under Government Code section 65585, HCD must review any action or failure to act that it determines to be inconsistent with either an adopted housing element or Government Code section 65583. HCD must then issue written findings to the local government (Gov. Code, § 65585, subd. (i)). Additionally, HCD must notify a local government when that local government takes actions that violate Government Code sections 65589.5 and 65583 and may notify the California Office of the Attorney General (Gov. Code, § 65585, subds. (i)(1) and (j)). By this letter, HCD has done so.

The City has until June 22, 2023, to provide a written response to this Notice. HCD will consider any written response before taking further action authorized by Government Code section 65585, subdivision (j), including, but not limited to, referral to the California Office of the Attorney General. If you have any questions or need additional information, please contact [email protected].

Sincerely,
David Zisser
Assistant Deputy Director
Local Government Relations and Accountability
Melinda Coy
Proactive Housing Accountability Chief
cc: David Pai, Supervising Deputy Attorney General, California Department of Justice (via email)
Susan Koleda, AICP, Community Development Director (via email) STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
May 12, 2023
Nancy Hunt-Coffey, City Manager
City of Beverly Hills
455 N. Rexford Drive
Beverly Hills, CA 90210
Dear Nancy Hunt-Coffey:

RE: City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Thank you for submitting the City of Beverly Hills’ (City) adopted housing element received for review on April 3, 2023. Pursuant to Government Code section 65585, subdivision (h), the California Department of Housing and Community Development (HCD) is reporting the results of its review:

The City, in adopting the element, also made findings pursuant to Government Code section 65585. These findings appear intended to explain the City’s reasoning for why the element substantially complies with State Housing Element Law (Gov. Code, § 65580 et seq.), despite HCD’s findings in the prior review Notably, the findings cite prior HCD correspondence that explained additional revisions are necessary to “fully” comply with State Housing Element Law. In this context, “fully” means addressing HCD’s findings from the prior review and should be considered synonymous with “substantial.” By no means was the City’s prior submittal in substantial compliance with State Housing Element Law. This should be well illustrated by the five pages of findings in the Appendix, including several findings that explain the adopted element simply was not revised to address HCD’s findings.

Further, HCD finds that the adopted element received for review on April 3, 2023, does not substantially comply with State Housing Element Law, and the City’s findings as part of the adoption are inadequate to demonstrate substantial compliance with statutory requirements; therefore, revisions to the element continue to be necessary to substantially comply with State Housing Element Law. In addition:
• Local Findings of Substantial Compliance: In its transmittal letter to HCD, the City asserted that its initial draft, adopted October 15, 2021, substantially complied with State Housing Element Law. However, the City’s findings provide minimal content, reasoning, or response to HCD’s findings that the prior submittal substantially complies with State Housing Element Law. For example, HCD’s prior reviews found that the City’s definition of “family” and its development standards for group homes serving Nancy Hunt-Coffey, City Manager

seven or more persons are constraints on housing for persons with disabilities. As another example, HCD’s prior reviews contained several findings related to appropriate policies and programs to affirmatively further fair housing (AFFH). The City’s findings do not address this essential statutory requirement. Similar issues persist throughout the City’s findings where statutory requirements are not addressed in a meaningful way or where broad statements of statutory requirements are made but little to no content, reasoning, or response is provided regarding these statutory requirements or HCD’s prior findings.

The City’s findings only appear to make an attempt at meeting statutory requirements related to calculations of realistic residential capacity, suitability of sites, and potential for redevelopment on nonvacant sites – narrow issues among many statutory requirements. However, these findings do not address the extent of statutory requirements and HCD’s prior findings.

Regarding the calculation of realistic residential capacity, suitability of sites, and redevelopment potential on nonvacant sites in the planning period, the City’s findings essentially reaffirm the City’s Mixed-Use Overlay Zone as its core strategy for addressing the Regional Housing Needs Allocation (RHNA) and reiterates that the overlay will significantly contribute to the intensification of residential uses along the City’s major commercial corridors. Given the emphasis placed on the overlay as an integral component of the City’s strategy to accommodate its RHNA, HCD’s prior reviews noted that the City should implement significant program actions and policies that incentivize the use of the overlay and adopt secondary measures, including rezoning of additional sites, should an evaluation of the overlay reveal ineffectiveness.

In addition, during its review, HCD received public comments from local stakeholder groups that highlighted the present limitations of the overlay’s effectiveness (e.g., three story height constraints in select areas, incentives limited to developer outreach and consultation, and the presence of many existing and viable non-residential uses along these corridors).

For these and several other reasons, the City’s findings do not adequately explain the reasoning as to how the element substantially complies with State Housing Element Law despite HCD’s findings in the prior review.
• Adopted Housing Element and HCD’s Findings: The City’s adopted element contains some revisions to address HCD’s prior findings. For example, the adopted element contains some revisions to its sites analysis, in addition to minor revisions to its programs, but otherwise provides minimal content to address HCD’s November 28, 2022 review. As an example, many of the City’s AFFH programs are still largely limited to conducting outreach and continue to include vague program commitments such as “study,” “consider,” and “continue” that do not facilitate meaningful outcomes to AFFH and are insufficient to overcome patterns of segregation and foster inclusive communities free from barriers that restrict access Nancy Hunt-Coffey, City Manager

to opportunity. Please see HCD’s prior review and the enclosed Appendix for revisions needed to substantially comply with State Housing Element Law.

As a reminder, the City’s 6th cycle housing element was due October 15, 2021. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described, adopt, and submit to HCD to regain housing element compliance.

Pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), a jurisdiction that failed to adopt a compliant housing element within one year from the statutory deadline cannot be found in compliance until rezones to make prior identified sites available or accommodate a shortfall of sites pursuant to Government Code section 65583, subdivision (c)(1)(A) and Government Code section 65583.2, subdivision (c) are completed. As this year has passed, if rezoning is necessary, the housing element will remain out of compliance until rezonings have been completed.

Please be aware that AB 2339, codified in Government Code section 65583 adds specificity on how cities and counties plan for emergency shelters and ensure sufficient and suitable capacity. Future submittals of the housing element may need to address these statutory requirements. For additional information and timing requirements, please see HCD’s memo at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/ab2339-notice.pdf.

Public participation in the development, adoption, and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lowerincome and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website, and a link to the revisions must be emailed to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant, the Strategic Growth Council, and HCD’s Affordable Housing and Sustainable Communities programs, and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Nancy Hunt-Coffey, City Manager

Governor’s Office of Planning and Research at: https://www.opr.ca.gov/planning/generalplan/guidelines.html.

We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Chelsea Lee, of our staff, at [email protected].

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Page 5 May 12, 2023

APPENDIX

CITY OF BEVERLY HILLS
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks and includes the Government Code addressing State Housing Element Law and other resources.

A. Housing Needs, Resources, and Constraints

1. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Realistic Capacity: In response to HCD’s prior review, the element now includes minor revisions on pages C-12-14, but these revisions are limited only to a general discussion of the factors utilized for determining sites in the inventory. The element must still include an estimate of the number of units that can be accommodated on each site in the inventory based on land use controls, site improvements, typical densities of existing/approved residential developments at a similar affordability level, and the current/planned availability of utilities. Please see HCD’s prior review for additional information.

Suitability of Nonvacant Sites: In response to HCD’s prior review, the element now includes additional information that highlights active developer interest and several proposed projects in the Mixed-Use Overlay Zone. However, additional information is required to fully address this finding. Specifically, HCD received public comment that indicates there are limitations in the application of the overlay that would hinder or preclude residential development in these areas. Additional public comment received by HCD emphasized the need to examine additional and more viable opportunities for sites inclusion, including vacant sites in the T-1 zone. The element must be revised to address public comments received on the sites inventory and modify policies and programs as necessary.

Accessory Dwelling Units (ADUs): The element was not revised to address this finding.

Please see HCD’s prior review for additional information.

City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Page 6 May 12, 2023

2. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures. (Gov. Code, § 65583, subd. (a)(5).)
Constraints on Housing for Persons with Disabilities:
• Family Definition: The element continues to not address this finding. Please see HCD’s prior review for additional information.
• Group Homes: The element continues to not address this finding. Please see HCD’s prior review for additional information.

B. Housing Programs

1. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning... (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A1, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.

2. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities... (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding A2, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to add programs and address and remove or mitigate any identified constraints.

3. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Page 7 May 12, 2023
sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
In response to HCD’s prior review, the element now includes minor revisions to its affirmatively furthering fair housing (AFFH) programs (pp. A47-51). However, these revisions do not otherwise address HCD’s findings. As noted in HCD’s cover letter, many of the City’s AFFH programs are still largely limited to conducting outreach and continue to include vague program commitments such as “study,” “consider,” and “continue” that do not facilitate meaningful outcomes to affirmatively furthering fair housing. Moreover, such actions alone are insufficient to overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity and the element must be revised to include robust program actions and commitments. Please see HCD’s prior review for additional information.

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
November 28, 2022
Timothea Tway, Director
Community Development Department
City of Beverly Hills
455 North Rexford Drive, First Floor
Beverly Hills, CA 90210
Dear Timothea Tway:

RE: City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Thank you for submitting the City of Beverly Hills’ (City) housing element which was adopted October 12, 2021 and received for review on September 29, 2022. The September 29, 2022, revisions are allowed pursuant to Resolution 21-R-13370. Pursuant to Government Code section 65585, subdivision (h), the California Department of Housing and Community Development (HCD) is reporting the results of its review. In addition, HCD considered comments from Californians for Homeownership pursuant to Government Code section 65585, subdivision (c).

The adopted housing element with draft revisions addresses many statutory requirements described in HCD’s January 14, 2022 letter; however, additional revisions are necessary to fully comply with State Housing Element Law (Article 10.6 of the Gov.

Code). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. During the housing element revision process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill Timothea Tway, Director

(SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City meets housing element requirements for these and other funding sources.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.

HCD appreciates the hard work and dedication you and your team during the review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Chelsea Lee, of our staff, at [email protected].

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Page 1 November 28, 2022

APPENDIX

CITY OF BEVERLY HILLS
The following changes are necessary to bring the County’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/building-blocks and includes the Government Code addressing State Housing Element Law and other resources.

A. Housing Needs, Resources, and Constraints

1. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Realistic Capacity: The element did not address HCD’s previous finding. The element must include an estimate of the number of units that can be accommodated on each site in the inventory based on the land use controls and site improvements, typical densities of existing or approved residential developments at a similar affordability level, and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities. As an example, the element could identify sites in the inventory by zones and relate the characteristics of individual parcels in the inventory to its past track record of recently approved projects by zone to establish its realistic capacity methodology. For sites zoned for nonresidential uses, e.g., commercial and mixed-use zones, the element must describe how the estimated number of residential units for each site was determined. In addition, the estimate must also account for land use controls such as allowing 100 percent nonresidential uses.

Suitability of Nonvacant Sites: While the element now includes additional discussion in Appendix C of the criteria that the City utilized to remove additional parcels in the sites inventory that were unlikely to be redeveloped, it must still support the potential for additional residential development on the sites remaining in the inventory. This is especially significant given that the sites inventory includes parcels that seem to have viable businesses including medical uses, Class A and B office buildings, and stores including a Starbucks, Neiman Marcus, and CVS with little to no analysis on the likelihood of these uses discontinuing during the planning period. Please see HCD’s prior review for additional information. The element should include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. While the element includes past experiences City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Page 2 November 28, 2022
converting existing uses to higher density residential development, it must relate those trends to the sites identified in the inventory. The element could also consider indicators such as age and condition of the existing structure expressed developer interest, low improvement to land value ratio, and other factors.

Accessory Dwelling Units (ADUs): In response to HCD’s prior review, the element now includes additional information that states 19 ADUs have been permitted in 2021 (pgs.

C-13-14). Even with this additional data, it is not clear if the City’s assumed production level of 150 ADUs will be achievable during the planning period. To further supplement its assumptions, the City may consider adding trends for 2022, in addition to its programs. The City may consider including trends for 2022 to further supplement its ADU assumptions in addition to including actions in Program 10.4 (Accessory Dwelling Units) that aggressively promote and incentivize ADU construction. Further, the City must still reconcile ADU figures with HCD records.

2. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures. (Gov. Code, § 65583, subd. (a)(5).)
Constraints on Persons with Disabilities:

Family Definition: The element continues to not address this finding. Please see HCD’s prior review for additional information.

Group Homes: The element continues to not address this finding. Please see HCD’s prior review for additional information.

3. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. (Gov. Code, § 65583, subd. (a)(6).)
Developed Densities and Permit Times: In response to HCD’s prior review, the element now includes revisions in Program 12.3 (Efficient Development Permit Review) to acknowledge that some projects have been approved with lower densities. However, the element must be revised to include the analysis as described in the City’s comment matrix to HCD.

City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Page 3 November 28, 2022
B. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov. Code, § 65583, subd. (c).) In response to HCD’s prior review, the element now includes satisfactory revisions to Programs 10.3 (Housing Trust Fund) and 10.4 (Accessory Dwelling Units). However, additional revisions are required to address HCD’s finding for Program 9.3 (Home Repair and Improvement). Specifically, the element cites that The Handyworker Program was discontinued, but should be revised to clarify what actions the City will initiate to “encourage” the reestablishment of the program given that it is intended to provide funding for scheduled accessibility improvements by 2025, and include other actions if funding from this program is not actualized in the planning period.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A1, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.

3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) As noted in Findings A2 and A3, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Page 4 November 28, 2022
analysis, the City may need to add programs and address and remove or mitigate any identified constraints. In addition, while the element included program commitments to Program 12.1 (Development Standards), additional revisions are required to fully address HCD’s finding. Specifically, Program 12.1 indicates that the City will “consider an ordinance to streamline the approval process to allow Director-level approvals for Architectural Review of multi-family housing projects with affordable housing…” but this does not demonstrate a specific commitment to address constraints related to permit processing procedures. The program should be amended to include specific and measurable actions to demonstrate a beneficial impact during the planning period.

Moreover, the action to “review the mixed-use overlay zone regulations by 2026 to assess how these regulations have been utilized by projects…” should be revised to an earlier timeframe for implementation so as to result in beneficial impacts during the planning period.

4. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).) In response to HCD’s prior review, the element now includes several revisions to Appendix A related to public outreach, contributing factors, other relevant factors, local data and knowledge, and housing mobility and new housing choice strategies.

However, additional information is required to fully address this finding. As an example, many of the program actions listed on pages A-46-50 and in Program 11.1 (Affirmatively Further Fair Housing (AFFH)) are limited to conducting outreach, does not include geographic targeting for program metrics and milestones, and includes language such as “study,” “continue,” or “maintain” that does not result in tangible outcomes that will overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity. Additionally, the element, among other things, must still include an analysis at the local and regional level that assesses data, trends, and patterns for each of the fair housing areas (outreach and enforcement, R/ECAPs and RCAAs, access to opportunity, segregation and integration, and disproportionate housing needs and displacement risk). In addition, the element must also include an analysis demonstrating whether sites identified to meet the Regional Housing Needs Allocation (RHNA) are distributed throughout the community in a manner that affirmatively furthers fair housing. For more information, please visit https://www.hcd.ca.gov/affirmatively-furthering-fair-housing. To assist with the analysis, HCD will also send a sample under separate cover.

5. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Page 5 November 28, 2022
all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).) In response to HCD’s prior review, the element now includes additional information in Appendix A on the expiring affordability covenant for the Beverly Hills Senior Housing project (pgs. A-23-24). However, these revisions do not otherwise address HCD’s finding. Program 9.7 (Monitoring Affordable Housing and Residential Displacement) should be revised to clarify that the City intends to maintain the affordability of the project regardless of the expiration of the covenant.

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
June 20, 2023
Dave Rand
Rand Paster & Nelson, LLP
633 West Fifth Street
64th Floor
Los Angeles, CA 90071
Dear Dave Rand:

RE: City of Beverly Hills 6th Cycle Housing Element Submittal Compliance and Suitable Sites Inventory – Letter of Technical Assistance On March 14, 2023, the California Department of Housing and Community Development (HCD) received your firm’s letter requesting technical assistance in relationship to the application of Government Code section 65586.5, the Housing Accountability Act. The purpose of this letter is to provide technical assistance regarding your request.

Summary of Request for Clarification
On March 14, 2023, your firm submitted a letter to HCD on behalf of 9300 Wilshire, LLC (Applicant), who is proposing development of a 16-story, 200-unit multifamily housing development project containing 40 deed-restricted, lower-income units. As HCD understands, the Applicant submitted a preliminary application to the City pursuant to Government Code section 65941.1, and the Applicant is in the process of preparing the formal entitlement application for submittal and eventual approval pursuant to Government Code section 65589.5.

Your letter requests confirmation of the City’s housing element status, clarification of the City’s compliance pursuant to Government Code section 65585(f)(2), and clarification as to how Government Code section 65589.5, subdivision (d)(5)(B) relates to the utilization of Government Code Section 65589.5, Subdivision (d)(5) as a basis for denying a project.

Confirmation of the City’s Housing Element Status and Clarification of the City’s Noncompliance
HCD confirms that as of the date of this letter, Beverly Hills’ housing element remains out of substantial compliance with State Housing Element Law. On May 12, 2023, HCD Dave Rand, Rand Paster & Nelson, LLP

reported its findings to the City pursuant to Government Code section 65585, subdivision (h). Among other things, HCD found the City’s housing element lacked (1) adequate sites to accommodate its share of the regional housing needs allocation (RHNA), (2) analysis related to constraints on housing for persons with disabilities, and (3) program commitments to affirmatively further fair housing.

Pursuant to Government Code section 65585, a local jurisdiction must submit a draft housing element to HCD and receive HCD’s findings. If HCD finds the draft element is not substantially compliant, the local jurisdiction must revise the draft to address any findings by HCD (Gov. Code, § 65585, subd. (f)(1)) or adopt without changes and include written findings explaining why the local jurisdiction believes that the draft substantially complies (Gov. Code, § 65585, subd. (f)(2)). Promptly following adoption, the local jurisdiction must submit the adopted housing element to HCD (Gov. Code, § 65585, subd. (g)) and receive findings on the adopted element from HCD (Gov. Code, § 65585, subd. (h)). A local jurisdiction is “in compliance” as of the date of HCD’s letter finding the adopted element in substantial compliance.

While the City did provide findings pursuant to Government Code section 65585, subdivision (f)(2), it does not have the authority to determine that its adopted element is in substantial compliance. HCD considered the City’s findings in its review of the adopted housing element and provided a response to those findings in its May 12, 2023, letter finding the City’s housing element out of compliance.

Clarification Regarding if a City with a Deficient Sites Inventory Can Utilize Government Code Section 65589.5, Subdivision (d)(5) as a Basis for Denying a Project
The requirement for an adequate sites inventory under subdivision (d)(5)(B) is an additional limitation on the utilization of Government Code section 65589.5, subdivision (d)(5), to support a denial under the Housing Accountability Act. Specifically, if the City has failed to identify adequate sites to provide for the RHNA for all income levels, then Government Code section 65589.5, subdivision (d)(5) cannot be used to disapprove or conditionally approve a housing development project proposed for a site designated in any element of the general plan for residential uses or designated in any element of the general plan for commercial uses if residential uses are permitted or conditionally permitted within commercial designations1. Please note that HCD’s May 12, 2023, review of the housing element found that the City did not demonstrate an adequate sites inventory to meet its RHNA obligation because of its incomplete analysis demonstrating the adequacy of its realistic capacity methodology, the unsuitability of nonvacant sites, and its calculations of accessory dwelling units.
1 Gov. Code § 65589.5, subd. (d)(5)(B)
Dave Rand, Rand Paster & Nelson, LLP

HCD appreciates the opportunity to provide technical assistance regarding all State Housing Element Laws. If you have any questions regarding the content of this letter or would like additional technical assistance, please contact John Buettner, of our staff, at [email protected].

Sincerely,
Melinda Coy
Proactive Accountability Unit Chief
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
October 5, 2022
Dave Rand
Rand Paster & Nelson LLP
633 W. Fifth Street, 64th floor
Los Angeles, CA 90071
Dear Dave Rand:

RE: 3030 Nebraska Avenue, Santa Monica – Letter of Technical Assistance This letter is in response to your September 16, 2022, request for technical assistance regarding the implementation of the Housing Accountability Act (HAA), particularly those provisions that require housing element compliance, in the context of the proposed multi-family residential development in Santa Monica at the address noted above. The inquiry pertains to the relationship of preliminary applications to projects that invoke the provisions of subdivision (d)(5) of Government Code section 65589.5 once a housing element has been found in substantial compliance with State Housing Element Law.

Background
A housing development project with housing for very low-, low-, or moderate-income households1 cannot be denied (or approved in a way such that conditions render the inclusion of affordable housing infeasible) unless one of five potential written findings, based upon a preponderance of the evidence in the record, can be made. (Gov. Code, § 65589.5, subd. (d).) Under subdivision (d)(5), a jurisdiction can only deny a qualifying project if both of the following criteria are satisfied: (1) The project is inconsistent with both the jurisdiction’s zoning ordinance and general plan land use designation and (2) the jurisdiction has a housing element in substantial compliance with State Housing Element Law. Therefore, the status of a jurisdiction’s housing element is of critical importance when determining the applicability of the provisions of subdivision (d)(5). 1 “Housing for very low, low-, or moderate-income households” means that either (A) at least 20 percent of the total units shall be sold or rented to lower income households, as defined in Section 50079.5 of the Health and Safety Code, or (B) 100 percent of the units shall be sold or rented to persons and families of moderate income as defined in Section 50093 of the Health and Safety Code, or persons and families of middle income, as defined in Section 65008 of this code. (Gov. Code, § 65589.5, subd. (h)(3).)
Dave Rand, Rand Paster & Nelson LLP

Analysis
The question posed in your September 16, 2022; request is as follows:

If a preliminary application is submitted to a jurisdiction without a compliant Housing Element, and the jurisdiction subsequently achieves Housing Element compliance during the project’s entitlement process, do the rights vested by the preliminary application continue to apply?
The answer is “yes.” The submittal of a complete preliminary application pursuant to Government Code section 65941.1 vests the right to develop a housing development project in accordance with the ordinances, policies, and standards in effect when a preliminary application is submitted. (Gov. Code § 65589.5, subd. (o)(1).) Therefore, if the submittal occurs at a time when the jurisdiction does not have a compliant housing element, any potential benefits afforded to the applicant as a result of the jurisdiction’s noncompliant status would remain throughout the entitlement process even if the jurisdiction subsequently achieves compliance during the entitlement process.

If you have questions or need additional information, please contact Brian Heaton at [email protected].

Sincerely,
Melinda Coy
Proactive Housing Accountability Unit Chief
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Edgar Arroyo, Senior Planner
Community Development Department
SENT VIA EMAIL May 12, 2023
Dave Rand
Rand Paster & Nelson LLP
633 W. Fifth Street, 64th Floor
Los Angeles, CA 90071
[email protected]
RE: 125 – 129 South Linden Drive – Development Plan Review for Mixed Use Development (PL2300126) Dear Mr. Rand:

Staff has reviewed your application and materials for the Development Plan Review submittal on April 14, 2023, for the proposed construction of a new mixed-use development at 125-129 South Linden Drive. The subject properties are located in the City’s R-4, Multiple Residential Zone, and High Density Multi-family residential General Plan land use designation. At this time, the application has been deemed incomplete for the reasons set forth below, and the previously filed Preliminary Application relating to the project site is deemed to be of no further effect due to changes in the project. Further, additional applications for amendments to the City’s General Plan and zoning ordinances are required to enable processing of the proposed project.

1. Preliminary Application
On October 24, 2022,1 the property owner (9300 Wilshire LLC) submitted a Preliminary Application pursuant to Government Code Section 65941.1 (the PA) for a housing development to vest the rights of a project under the ordinances, policies, and standards adopted and in effect at the time that the preliminary application was submitted. Thereafter, on April 14, 2023, the property owner submitted a formal Development Plan Review (DRP) application for a housing development project, which was within 180 days of the PA submittal date noted above as required to maintain the validity of the PA.

The project that was submitted as part of the PA (the PA project) consisted of a residential-only project that included 200 dwelling units within a 259,547 SF, 16-story building. The building was proposed with a height of 170’ and included 124 parking spaces within a four-level subterranean parking structure.
1 Although the Preliminary Application was submitted on Friday, October 21, 2022, the fees for the application were paid after hours, thus the submittal date is considered to be Monday, October 24, 2022. 2 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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The project for which the DPR application was submitted (the DA project) is substantially different from the project for which the PA was submitted. The DPR plans submitted entail a mixed-use development that includes 165 dwelling units and a 73-room hotel and hotel restaurant within a 311,197 SF, 19-story building. The building contemplated in the DPR application is now proposed with a height of 200’ and includes 126 parking spaces within a four-level subterranean parking structure.

Pursuant to Govt. Code Section 65941.1 (a):
“An applicant for a housing development project … shall be deemed to have submitted a preliminary application upon providing all of the following information about the proposed project to the city … from which approval for the project is being sought and upon payment of the permit processing fee: ….” (Emphasis added.)
The information required in a preliminary application includes “[t]he proposed land uses by number of units and square feet of residential and nonresidential development using the categories in the applicable zoning ordinance.” (Govt. Code Sec. 65941.1(a)(4). (Emphasis added.)) The description of the proposed land uses included in the PA’s proposed project made no mention of any hotel or restaurant use or, for that matter, any other commercial or non-residential uses, and did not contemplate a mixed use project. The PA described the proposed land uses only as follows: “The proposed project will include 200 residential dwelling units in 259,547 (gross) sq. ft .” The DPR application, however, describes a very different project:
“The project consists of the construction of a new 19-story mixed use, multifamily residential and hotel building, with 165 rental apartment units (including 33 affordable housing units) and ancillary residential spaces, 73 hotel rooms and ancillary hotel spaces, and 126 parking spaces.”
Based on the introduction of the new hotel use in the DPR project, which was not contemplated in the PA project, the Department concludes that the DPR project submittal is for a project different from the PA project. Because the DPR project is substantially different from the project described in the PA, the Department concludes that the DPR application, although filed within 180 days of the filing of the PA, is not sufficient to meet the filing requirement of Govt. Code Section 65941.1(d)(1). Therefore, the Department finds that the PA has expired and is of no furtherforce or effect.

Per the explanation provided in the cover letter, the responses to the remaining comments reject the need to apply for additional entitlements or to comply with any provisions of the General Plan or zoning code (BHMC Title 10).

2. General Plan Amendment and Zoning Amendment Applications Required The proposed DPR project does not conform to the City’s General Plan and various provisions of the City’s zoning code. These deviations include, but are not limited to that:
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• Neither a hotel nor a mixed residential/commercial use project is a permissible use in either the High Density Multifamily Residential General Plan land use designation orthe R-4 zoning applicable to the project site.
• The proposed height exceeds the maximum permissible heights allowed in the General Plan and R-4 zoning
• The proposed residential density exceeds the maximum allowed density on the site.

The substantial deviations from the General Plan and applicable R-4 zoning and related ordinance contemplated by the DPR project must be analyzed and processed pursuant to the City’s procedures, and nothing in the Housing Accountability Act (Govt. Code Sec. 65589.5.) divests the City of its authority to require an applicant to follow the City’s procedural and administrative requirements.

Thus, in order to process the DPR project application, the applicant must also submit applications for amendments to the City’s General Plan, and zoning ordinances and/or map for concurrent processing.

The applications for the respective amendments must clearly describe each of the amendments that are necessary to enable the proposed DPR project, including the land use designation and zoning so as to accommodate the mixed use and hotel uses, which are prohibited in the General Plan land use designation and R-4 zone in which the property is located. Further, the amendment applications must address any other necessary changes to related development standards with which the proposed DPR project does not comply, including but not limited to height, density, setbacks, and other standards as described in more detail below.

Following the proper amendment process, in addition to the DPR process, is critical to, among other considerations, ensuring that the due process rights of surrounding property owners are respected, and that those property owners may participate in the proceedings, including required public hearings, should they so choose.

Refer to the response to item #1 and the cover letter. Applications for a General Plan Amendment or Zone Change are not necessary, as the project retains its vesting rights to proceed with a Development Review Permit in conjunction with the Builder’s Remedy.

3. Land Use – Sheets A01, A06, A07, A14, A15, A16, A28, and A29 The project site is located within the City’s R-4 Zone, and the High Density Multi-family Residential General Plan land use designation. BHMC Sections 10-3-1202 and 10-3-1203 detail the types of permitted and conditionally permitted uses within the R-4 Zone. As proposed, the DPR project2 consists of a mixed-use development that includes 165 dwelling units and a 73-room hotel and hotel restaurant. While residential development is permissible within the R-4 Zone and the High Density Multi-family Residential General Plan land use designation, subject to the applicable development standards, as noted above, mixed-use developments, including hotel and hotel restaurant uses, are not permissible in the R-4 Zone orthe High Density Multi-family Residential General Plan land use 2 Hereafter, the word “project” refers to the DPR project, unless otherwise noted. 4 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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designation.

Revise the project to remove commercial uses in the project or, as noted above, submit Zone Change and General Plan Amendment applications to seek consideration of the project, as well as the regulations within the R-4 Zone that do not facilitate the type of proposed mixed-use development.

Refer to the response to item #1 and the cover letter. Applications for a General Plan Amendment or Zone Change are not necessary, as the project retains its vesting rights to proceed with a Development Review Permit in conjunction with the Builder’s Remedy.

4. Density – Sheet A01
The proposed project includes the development of 165 dwelling units on a 21,676.05 square-foot (SF) project site. The application materials submitted for this project note that the proposed project is not a density bonus project and is not seeking incentives, concessions, and/or waivers, or any subdivision which may be contemplated to separate the hotel uses from the residential uses. Specifically, as to density bonus, the PA specifically says “The project does not include a density bonus request under State Density Bonus Law”.

The City’s General Plan details the applicable density requirements for multi-family properties in the city. The applicable density for properties located in Multi-family Residential High Density Area is 50 dwelling units per acre (or 1 unit for every 871.2 SF of lot area). As such, the applicable density requirements would facilitate 25 dwelling units on the project site (21,676.05 / 871.2 = 24.88 units).

Fractional figures are rounded up to the nearest whole number.

As designed, the project exceeds the maximum number of allowable units by over 140 dwelling units.

Revise the project with a reduction in proposed units to comply with applicable density requirements.

Alternatively, the project may seek additional dwelling units above the otherwise applicable requirements by applying for a Density Bonus Permit. A density bonus project would be reviewed in compliance with applicable state density bonus law requirements.

Should the density of the project not be revised to comply with code requirements or pursuant to a density bonus proposal, the project as designed would require a zone change and general plan amendment, as noted above, because the project currently exceeds all applicable development standards for multi-family development in the City’s R-4 Zone and does not conform with the City’s General Plan.

Refer to the response to item #1 and the cover letter. Applications for a General Plan Amendment or Zone Change are not necessary, as the project retains its vesting rights to proceed with a Development Review Permit in conjunction with the Builder’s Remedy.

5. Minimum Floor Area for Dwelling Units – Sheet A01 and Sheets A16 through A23 BHMC Section 10-3-2802 details the applicable minimum dwelling unit requirements for new 5 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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development on properties located within the City’s R-4 Zone. The applicable minimum dwelling unit size are as follows:
• Studio/Efficiency Unit: Minimum floor area of 600 SF
• One Bedroom Unit: Minimum floor area of 1,000 SF
• Two Bedroom Unit: Minimum floor area of 1,300 SF
• Three Or More Bedroom Unit: Minimum floor area of 1,500 SF In review of the set of plans, the residential portion of the project consists of 165 dwelling units with a mix of 13 studio, 59 one-bedroom, and 93 two-bedroom units. As noted on Sheet A01, the average size of a studio unit is between 450 SF and 486 SF, the average size of a one-bedroom unit is between 652 SF and 658 SF, and the average size of a two-bedroom unit not located on the penthouse level (19th floor) is between 892 SF to 970 SF. As such, these units do not appear to provide the applicable minimum floor area for an efficiency, one-bedroom, or two-bedroom unit. Revise the project and design of each unit to provide the minimum floor area required.

Refer to the response to item #1 and the cover letter.

Adherence to this zoning standard is not required.

6. Outdoor Living Space – Sheets A01, A08, and A09
a. Required Outdoor Living Space – BHMC Section 10-3-2803 details the applicable open space requirements for new development on properties located within the City’s R-4 Zone. Pursuant to this section, 200 SF of outdoorliving space is required per dwelling unit. The required outdoor living space can be provided as private outdoor living space with a minimum dimension of 6’-0” on all sides, or as common outdoor living space with a minimum dimension of 15’ on all sides.

While the proposed development of 165 dwelling units exceeds the density allowed for the project site, should the applicant seek a zone change/general plan amendment to facilitate the project, the project would need to provide 33,000 SF of open space. As provided on the Open Space tables on Sheets A01, A08, and A09, the proposed project is proposing 18,228 SF of open space, which is approximately 14,772 SF less than what is otherwise required. Revise the project to provide the applicable area of outdoorliving space per unit.
b. Outdoor Living Space Dimensions – Pursuant to BHMC Section 10-3-2803, outdoor living space can be provided as private outdoor living space with a minimum dimension of 6’-0” on all sides, or as common outdoor living space with a minimum dimension of 15’ on all sides. Based on the Open Space tables provided on Sheets A08 and A09, it appears that the project is providing open space in both common and private outdoor living areas. While the 18,228 SF of proposed outdoor living area is not sufficient to meet the required outdoor living space required per unit (33,000 SF of outdoor living space is required for 165 dwelling units), the open space diagrams provided do not include any dimensions to show that the minimum outdoor living space dimensions are being provided. Revise the open space diagrams to include the dimensions of each proposed common and 6 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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private outdoor living space areas. Each area shall provide the minimum dimensions required to count toward the required outdoor living space.
c. Number of Dwelling Units – The number of dwelling units noted on the Open Space tables provided on Sheets A01, A08, and A09 do not match the number of units proposed for the project.

The Open Space tables show that 171 dwelling units are proposed, while the plans for the project show a total of 165 dwelling units proposed. Revise the tables according to reflect the correct number of proposed units. Revise the amount of required open space to reflect the correct unit count.

Refer to the response to item #1 and the cover letter.

Adherence to this zoning standard is not required.

For informational purposes, the plans have been updated to include dimensions on the open space areas that are provided and to revise the data discrepancy in the tables to reflect the correct number of units. Refer to sheets A08 and A09.

7. Building Height – Sheets A01, A11, A24, A25, A26, A27, A28, and A29 a. Maximum Allowable Height – The project site is comprised of two properties located within the City’s R-4 Zone. BHMC Section 10-3-2804 details the applicable height requirements for properties located in the R-4 Zone. The first property at 125 S. Linden Drive is located within Height District C, which allows for development up to five (5) stories with a maximum height of 55’. The second property at 129 S. Linden Drive is located within Height District B, which allows for development up to four (4) stories with a maximum height of 45’.

In review of the project plans, the new development is designed with 19 stories and at a height of approximately 200’ tall. As designed, the portion of the project located in Height District B exceeds the maximum allowable height by 155’. Similarly, the portion of the project located in Height District C exceeds the maximum allowable height by 145’. Reduce the height of the proposed project to conform to the maximum allowable height for each applicable height district. b. Height of Rooftop Elements – Call out the height of all proposed rooftop elements on all sections and elevations, including the height of the proposed rooftop elevators, rooftop stairs, mechanical equipment screening, and any unoccupied architectural features (e.g., rooftop trellises and similar).

The rooftop elements shall comply with the maximum heights detailed under the definition of "Height of Building" for Multiple-Family Residential Zones in BHMC Section 10-3-100, as provided below, otherwise these features shall not be exempt from height and shall be counted toward the overall height of building:
• Structures enclosing elevator equipment and/or elevatorlobbies if such structures are not higher than fifteen feet (15') above the adjacent roof deck and are not larger than the shaft of the elevator or elevators and their respective lobby areas. 7 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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• Structures enclosing stairs required by law to be carried to the roof if such enclosing structure is used for no other purpose than enclosing the stairs and is no larger than the stair shaft below and if such enclosure is not more than twelve feet (12') in height as measured from the adjacent roof deck.
• Penthouse structures used exclusively for mechanical equipment for the building or structure if such penthouse structure is not more than ten feet (10') in height as measured from the adjacent roof deck.
• Parapets or handrails not more than forty-five inches (45") in height as measured from the roof orfloor which they surround.
c. Mechanical Equipment Screening – Show the proposed rooftop mechanical equipment screening on all sections and elevations, as the proposed screening is not shown on the sections and elevations provided. Pursuant to BHMC Section 10-3-100 (Height), the max height is 15'-0" for mechanical equipment penthouses and enclosures.

Refer to the response to item #1 and the cover letter.

Adherence to this zoning standard is not required.

For informational purposes, the plans have been revised to include additional data on the height and screening of the roof structures. Refer to sheets A23-A31.

8. Alley Dedication – Sheets A11 through A29
As required by the City’s Street Master Plan, a 2’-6” dedication is required along the north side and rear of the project site for widening of the existing 15’ alley to improve vehicular circulation. (See also BHMC Section 10-6-2, regarding street dedication and improvement requirements.) This dedication area needs to be shown on all details of the set of plans. Additionally, any required property setback shall be measured from the adjusted property line, post-alley dedication.

Show the required 2’-6” alley dedication area on all details of the set of plans, including on site plan, floor plans, and all sections and elevations provided. Adjust the location of the property lines adjacent to the required dedication areas accordingly.

The plans have been revised to show the dedication in all requested locations. While adherence to the setback standards is not required, the proposed setbacks are shown from the new property line.

Refer to sheets A11-A23.

9. Setbacks – Sheets A01 and A11 through A29
a. Front Setback – The applicable front yard setback for the project site is 15’-0”. As designed, portions of the proposed building located above ground level would encroach into the required setback.

As proposed, complete sections of the building on almost every floor level appear to encroach into the required front yard setback, with a seven-inch (7”) setback shown on the site plan provided on 8 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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Sheet A11 of the set of plans. Such building encroachment is not permissible within the front yard setback area.

Revise the project to provide the applicable 15’-0” front setback for the project. b. Side Yard Setbacks – BHMC Section 10-3-2807 details the applicable side yard setbacks for properties located within the City’s R-4 Zone. Pursuant to this section, the development of a project with more than four (4) stories or greater than 45’ in height shall be subject to a cumulative setback of 23’-0’, with a minimum setback of at least 9’ required on one side. When a project is subject to a dedication of land required for improving and widening existing alleys adjacent to the project site, the required setback shall be measured from the adjusted property line post-alley dedication.

As proposed, complete sections of the building on most floor levels appear to encroach into the required side setback, with a 7’-0” side setback provided to the north and an 11’-0” side setback provided to the south. The 18’-0” cumulative setback does not appear to meet the applicable cumulative setback of 23’-0’ required for a project that exceeds four stories and 45’ in height.

Similarly, the 7’-0” setback shown on the north side does not appear to meet the minimum side setback required for properties in the R-4 zone. Revise the project to provide the required minimum and cumulative side yard setback.
c. Rear Setback – BHMC Section 10-3-2808 details the applicable rear yard setback for properties located within the City’s R-4 Zone. Pursuant to this section, a setback of 15’ is required for all new development in the R-4 zone. When a project is subject to a dedication of land required for improving and widening existing alleys adjacent to the project site, the required setback shall be measured from the adjusted property line post-alley dedication.

As proposed, sections of the building on several floor levels appear to encroach into the required rear setback, with a portion of the building designed with a 2’-6” rear from existing property lines.

Revise the project to provide the applicable 15’-0” rear yard setback to the project. d. Setbacks Throughout Plan Set - Show all applicable front, side, and rear setback lines on the site plan, floor plans, sections, and elevation on the set of plans. These details are missing from several sheets of the plan set.

Garage Encroachment in Front Setback – Pursuant to BHMC Section 10-3-2811, basement garages are allowed to encroach into the front yard setback area. However, as designed, the portion of the basement garage built into these setback areas needs to be 2'-0” lower than the grade of the adjacent sidewalk. Additionally, that 2'-0” depression shall be used to provide planting areas within the front yard setback area.

As shown on Section 2 on Sheet A29, the portion of the basement garage within the front yard setback is currently designed to be at the same level as the adjacent sidewalk along South Linden Drive, which is not permissible. Revise the design of the basement garage that encroaches into the 9 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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front yard setback area so that it is 2'-0” lower than the adjacent sidewalk along South Linden Drive. e. Modulation – BHMC Section 10-3-2806 details the applicable front modulation standards for properties located within the City’s R-4 Zone. In review of the set of plans provided, no details were included as to the amount of front building modulation provided for the project. As a separate exhibit to the set of plans, provide front modulation diagrams showing the required amount of modulation required and the modulation proposed for the project. Additionally, the diagrams shall show the depth of the modulation provided per floor and calculations for the aggregate principal building area.

Adjust the project design accordingly to provide the applicable front modulation for the project pursuant to BHMC Section 10-3-2806.

Refer to the response to item #1 and the cover letter.

Adherence to this zoning standard is not required.

For informational purposes, the plans have been revised to include additional data on the proposed setbacks, relative to the new property line location after the dedication. Refer to sheets A11-A23.

10. “NO BUILD ZONE” Area – Sheets A12 and A13
In reviewing the Fault Rupture Hazard Investigation dated October 7, 2020, previously prepared for the project site, several active earthquake faults were discovered on the properties at 125 and 129 S. Linden Drive. The “Structural Setback Plan” on Page 60 of the document establishes a “NO BUILD ZONE” where no portion of a habitable structure could be built.

Please show this no build zone area on the site plans and floor plans provided for the first floor and every subterranean level of the project to ensure that the proposed building does not encroach into the NO BUILD ZONE.

The plans have been revised to show additional notations on the No Build Zone as requested. Refer to sheets A12-A23.

11. Front Yard Paving – Sheet A14
BHMC Section 10-3-2813 details the applicable front yard paving standards for properties located within the City’s R-4 Zone. Pursuant to this section, no portion of any front yard within the R-4 Zone shall be paved, except for not more than one walkway not exceeding five feet (5') in width and one driveway not exceeding the width of its curb cut. Based on the design provided on Sheet A14, the project includes a paved courtyard and walkway to the north side of the property. No driveway paving is proposed within the front yard setback area. Together, these walkways exceed the maximum allowable width for walkways located in the front yard setback area.

Revise the design of the paving proposed in the front yard setback area to include one (1) walkway that 10 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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does not exceed 5’ in width. Additional walkways not exceeding 5’ in width may be permissible as detailed in BHMC Section 10-3-2813.

Refer to the response to item #1 and the cover letter.

Adherence to this zoning standard is not required.

12. Site Walls and Fences – Sheet A11
Show all proposed site fences and walls on the site plan for the project. Provide additional details and sections on the set of plans showing the design and height of any proposed fences and walls. All site fences and walls shall be designed in conformance with the applicable fence/wall standards provided in BHMC Section 10-3-2814.

Refer to the response to item #1 and the cover letter.

Adherence to this zoning standard is not required.

For informational purposes, the plans have been revised to show details on the site walls and fences.

Refer to sheets A11 and A14.

13. Parking – Sheets A01, A12 and A13
a. Residential Parking – BHMC Section 10-3-2816 details the applicable parking standards for properties located within the City’s R-4 Zone. Pursuant to this section, the project shall provide the following number of parking spaces per dwelling unit type:
• One (1) parking space shall be provided for each multiple-family dwelling unit that is an efficiency unit of less than one thousand (1,000) square feet. • Two (2) spaces shall be provided for each multiple-family dwelling unit that contains one bedroom.
• Two and one-half (2 ½) parking spaces shall be provided for each multiple-family dwelling unit that contains two (2) bedrooms.

In review of the set of plans, the residential portion of the project consists of 165 dwelling units with a mix of 13 studio, 59 one-bedroom, and 93 two-bedroom units. Based on the unit mix proposed, 364 parking spaces would be required for the 165 dwelling units proposed. The total number of required parking spaces will be confirmed once floor plans of the residential portion of the project are provided to confirm an accurate bedroom count. As the project is only designed with 127 parking spaces, the project does not conform to the applicable parking standards. As provided on the set of plans and application materials, this project is not a density bonus project and thus is not eligible for the reduced parking standards under state density bonus provisions.

Revise the project to provide the required number of parking spaces. 11 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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b. Guest Parking – BHMC Section 10-3-2817 details the applicable parking standards for properties located within the City’s R-4 Zone. Pursuant to this section, guest parking shall be provided for the project at a ratio of 0.25 spaces/unit. As proposed, a project with 165 dwelling units would be subject to 42 guest parking spaces (41.25 rounded up to the nearest whole number).

Revise the project to provide the required number of guest parking spaces. Clearly call out which parking spaces for the project are being allocated for only guest parking. c. Hotel and Hotel Restaurant Parking – While previously noted that the hotel and hotel restaurant uses proposed for this project are not permissible within the R-4 Zone, should the applicant seek a Zone Change/General Plan Amendment to facilitate the proposed commercial uses, such uses shall be designed in compliance with the applicable parking requirements detailed in BHMC Section 10- 3-2730. Such parking shall be provided on-site.

Based on the plans provided, a 73-room hotel would require 73 parking spaces (1 space/room).

Additionally, the proposed 3,497 SF hotel restaurant would require 14 parking spaces (1 space/350 SF for first 3,000 SF – 1 space/100 SF for portion over 3,000 SF). However, 25% of the spaces required to be provided for the hotel may also be applied toward the hotel restaurant, which can provide a credit of approximately 19 parking spaces for hotel restaurant use.

As designed, the parking garage for the development does not currently provide any parking for the commercial uses of the project. Each space is labeled as “RES”, implying that the parking spaces are reserved for the residential uses of the project and not available to service the proposed hotel and hotel restaurant uses. Should the applicant seek a Zone Change/General Plan Amendment for consideration of this project, parking for the proposed hotel and hotel restaurant uses shall be provided on-site.
d. Parking Stall Dimensions – The City’s parking standards require all parking spaces provided for a project to be provided in standard configuration, with a minimum parking stall width of 9’-0” and a length of 19’-0”. Compact parking stall dimensions are not allowable for any required parking stall associated with the residential use of the property. However, pursuant to BHMC Section 10-3- 2727, the proposed hotel use may provide up to 25% of the required parking as compact parking stalls and through tandem spaces as part of a Conditional Use Permit.

In review of the set of plans, the subterranean parking structure includes compact parking stalls on each of the four levels for the residential uses, which is not permissible. No parking appears to be specifically provided for the commercial hotel and hotel restaurant uses proposed for the project.

Revise the design of the parking garage to include standard parking stalls with the minimum required stall width and length and remove compact stalls forthe residential uses. Provide the required parking for the hotel and hotel restaurant uses. 12 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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e. Parking Aisle Depth – The minimum aisle width required for parking spaces provided at a 90 degree angle is 26’-0” per the City’s parking standards. The drawings prepared for parking levels P1 - P4 show that a 24’-0” parking aisle is proposed where parking spaces are provided with a 90 degree turning angle.

Revise the design of the parking aisle width to provide the 26’-0” wide minimum aisle width. f. Garage Encroachment into Alley Dedication Area – As designed, the basement garage would encroach into the 2’-6” alley dedication area required along the north side and rear of the property.

The garage cannot encroach into the required alley dedication area. Revise the design of the parking garage so that no portions of the building encroach into the required alley dedication areas.

Refer to the response to item #1 and the cover letter.

Adherence to this zoning standard is not required.
g. Replacement Parking for 9740 Wilshire Blvd - The project site at 129 S. Linden Drive is currently improved with a surface parking lot that provides required parking forthe commercial office building located at 9740 Wilshire Blvd. The original building plans for the commercial building at 9740 Wilshire Boulevard show that the surface parking lot at 129 S. Linden Drive was designed with diagonal parking for 50 vehicles. To facilitate this, a parking covenant was filed with the city and recorded on August 12, 1957, against the properties at 9740 Wilshire Blvd and 129 S. Linden Drive to provide a portion of the required parking off-site. The use of the 129 South Linden Drive site for commercial parking purposes was approved through Variances issued by the City Council in 1941 and 1958 (City Council Resolution Nos. 1061 and 2841).

In review of the project, 126 parking spaces would be provided for the residential portion of the project. No parking is specifically provided for on the set of plans for the proposed the hotel and hotel restaurant uses. Additionally, the plans for the project and the application materials do not address how the required covenanted parking for 9740 Wilshire Blvd would be replaced.

However, Pursuant to BHMC Section 10-3-2737, it is not permissible to locate parking required for a commercial use or commercial property on a site that is zoned for residential land uses. As it pertains to the replacement parking for 9740 Wilshire, the replacement parking would either need to be provided on an alternative site zoned for commercial uses, or the applicant would need to seek a code amendment to allow for replacement of the required parking within this new development. As previously noted, in addition to the parking required for the proposed project, a total of 50 parking spaces will need to be provided as replacement parking for the 9740 Wilshire site because the new development is proposing the removal of the existing covenanted parking required forthe development on that property.

The Project provides parking which can be shared between multiple uses. Additionally, the Project and 13 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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the existing office building are eligible for a total reduction of parking requirements per recent updates to state law (Assembly Bill 2097), so in providing 126 spaces it provides more parking than is required.

14. Loading – Sheets A06 and A14
a. Number of Loading Spaces Required – BHMC Sections 10-3-2740 thought 10-3-2743 detail the applicable loading space requirements. Based on the area schedule provided on Sheet A06, approximately 48,034 SF of floor area is proposed for use as hotel and hotel restaurant on the first and second floors. Pursuant to BHMC Section 10-3-2741, the number of loading spaces required for the proposed commercial floor area is three (3) truck spaces. Each truck loading space shall have a minimum length of 35’, width of 12’, and overhead clearance of 10’.

As proposed on Sheet A14, the project is designed with what appears to be one (1) loading space accessed from the alley that is 12’ wide by 30’ long. This single loading space provided does not appear to comply with the number of loading spaces required for the project or the minimum dimensions required for a truck loading space.

Revise the project to provide the applicable number of loading spaces at the required minimum dimensions.
b. Loading Study – Provide a loading study that evaluates the loading demands of the proposed project and determines the adequacy of the loading areas proposed. The loading study shall also study vehicle maneuverability into the proposed loading areas, particularly truck maneuverability for accessing the loading space located adjacent to the alley at the rear, as it appears difficult to maneuver a truck in the alley due the existing width. The existing alley measures 15’ in width, but would be widened to 17’-6” feet once the project dedicates land along the alleys. c. Location of Loading Spaces – Pursuant to BHMC Section 10-3-2742, when a project site or structure abuts an alley, access to loading spaces shall be provided from the alley. Alley accessed loading spaces shall be parallel to the alley unless the project applicant establishes one of the following:
• Site constraints preclude construction of a parallel loading space or spaces; or, • The alternative loading space configuration proposed by the project applicant meets the functionalrequirements of the code.

As currently designed, the loading space provided on Sheet A14, is perpendicularto the alley instead of parallel to it. Revise the project to include the required loading spaces in compliance with BHMC Section 10-3-2742. If this cannot be achieved and the applicant is seeking an alternative configuration, provide findings as noted above detailing site constraints and how the alternative loading space will meet the functional requirements of the code. d. Maneuvering – Pursuant to BHMC Section 10-3-2740, loading spaces shall be directly accessible for thedistribution of goods within the structure oruse. For multi-story structures, such access shall 14 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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be direct to an elevator or stairway serving all stories, and in this case, all stories of the hotel and hotel restaurant. In order to meet the functional requirements, loading spaces shall have a minimum maneuvering area as specified in the MINIMUM STANDARDS FOR LOADING SPACES table in BHMC Section 10-3-2740. Said maneuvering area shall be contiguous to the end of the loading space and may include the width of the alley or street.

Provide maneuvering diagrams showing truck ingress and egress to the loading spaces provided for the project.

Refer to the response to item #1 and the cover letter.

Adherence to this zoning standard is not required.

15. Survey – Sheet A10
a. Scale of Plan – In review of the survey provided on Sheet A10, the drawing does not appear to match the scale noted on the plan sheet. When several site features with dimensions are measured at the noted scale (1” = 10’), the dimensions scale out to less than what are noted on the survey. Provide a survey that is drawn to the scale noted on the plan sheet.
b. Survey Legibility – The survey provided appears to be scanned from an original of that document and placed on the set of plans. As such, the details and dimensions provided are pixelated and not very legible. Provide a survey that is clear, legible, and not pixelated. c. Surveyor’s License Expiration – The survey provided notes that the surveyor’s license expired on 12/31/2020. Provide an updated survey with an updated expiration date of the surveyor of record.

An updated survey is enclosed with the resubmittal materials. Refer to sheet A10.

16. Title Report – Sheet A10
Provide a Title Report of the project site to verify whether any easements exist on the properties at 125 and 129 S. Linden Drive. The survey provided on Sheet A10 notes that there are no easements on the project site, “per referenced preliminary title report.” However, a copy of this title property was not provided. Provide a title report of the project site with project resubmittal.

A title report is enclosed with the resubmittal materials (Attachment D).

17. Elevations and Renderings – Sheets A00, A02, A03, A04, A24, A25, A26, and A27 Revise the elevations and renderings provided for the project, as required, to address the corrections and comments provided in this review letter and the redlined set of plans.

Refer to the response to item #1 and the cover letter.
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Adherence to this zoning standard is not required.

18. Floor Plan Layouts for Dwelling Units – Sheets A16 through A23 Provide floor plans layouts for each of the proposed dwelling units in the project. The floor plans provided only have a call out to the number of bedrooms in each unit, but the layout of each unit is not provided. The floor plans shall show the proposed kitchen, bathroom, bedroom, and living area of each of the proposed dwelling units.

The plans have been revised to include the interior unit layouts of each unit on the floor plans. Refer to sheets A14-A23.

19. Rubbish Storage – Sheet A14
BHMC Section 9-3-1 details the applicable rubbish storage standards for residential and commercial development. As proposed, the project would include a 592 SF trash room located in the first floor of the building, adjacent to the alley at the rear. However, calculations were not provided on the set of plans or in the application materials to demonstrate that the proposed trash room is of sufficient size to accommodate the anticipated demand for waste generated by the project site.

Provide calculations pursuant to BHMC Section 9-3-1 showing the anticipated amount of rubbish that would be generated by the project and the size of the rubbish/trash room needed to accommodate the projected waste quantities that would be generated by the project.

This requirement will be satisfied once Construction Documents are drafted as this requirement is derived from the Building Code. The project will incorporate these requirements as required during the construction document phase.

20. Landscape Plans – Not Provided
Provide landscape plans of the proposed project with resubmittal. The landscape plans shall show all proposed landscaping improvements on the project site and in the public right-of-way.

The plans have been revised to include landscape plans. Refer to sheets L1.00-L.1.15.

21. Environmental Review
Once all major corrections have been addressed and complete applications have been submitted, the City will review the proposal to determine what review may be required pursuant to the California Environmental Quality Act (CEQA). The applicant will be responsible for paying the the costs for the preparation of any required environmental document, including but not limited to the costs of any consultants as may need to be retained by the City.

Pursuant to this item, the level of environmental review will be determined by the City after the aforementioned items have been addressed. At this time, there is nothing for the applicant to produce. The applicant will compensate the costs required for environmental review. 16 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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22. Low Impact Development (LID)
Pursuant to BHMC Section 9-4-508, the City’s Low Impact Development (LID) requirements are applicable to new developments projects.

As you progress with the design of the project, review the applicable LID requirements and incorporate them into your project and set of plans. This will ensure that the project, as designed, can accommodate the required LID provisions early on and will reduce or eliminate any changes needed once the project is submitted for building plan check.

A copy of the Low Impact Development (LID) Fact Sheet is available for download from the City’s website using the following link:
http://www.beverlyhills.org/cbhfiles/storage/files/1266023136723167408/ChecklistforLIDRequiremen tsFINAL(6).pdf
For question related to LID requirements, please contact Trevor Alsop at 310-288-2837 or by email at [email protected].

Pursuant to this item, the LID requirements will be incorporated and considered for the final plans. At this time, there is nothing for the applicant to produce.

23. Shade and Shadow Study
Provide a shade and shadow study for the proposed project. Diagram the shadows from the proposed structure during the winter and summer equinoxes, from 6:00 A.M. to 9:00 P.M., at three-hour intervals. The study shall show adjacent properties and the projected shadow on those properties during the noted intervals.

The plans have been revised to include a Shade and Shadow study. Refer to sheet A32.

24. Rooftop Operations Plan
Provide the following information for all enclosed and unenclosed rooftop areas proposed:
• Indicate the types of uses proposed for all enclosed and unenclosed rooftop areas. • Indicate the proposed hours of operation of all enclosed and unenclosed rooftop areas. • Indicate whether the rooftop area will be used exclusively by the residential portion of the project orif hotelrooftop access will be provided.
• If the hotel will have access to the rooftop, indicate the type, frequency (yearly, monthly, daily, etc.) ofrooftop events, appointments, etc.
• If the hotel will have access to the rooftop, indicate maximum occupancy anticipated for each type of event.
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The 18th and 19th floor rooftop areas include passive seating areas and landscaping. The rooftop areas will be used for residential users only. The maximum occupancy will be confirmed by the City during the plan check phase once construction documents are prepared.

25. Arborist Report
Provide an Arborist Report detailing all existing trees located within adjacent public right-of-way along South Linden Drive. The arborist report shall also detail all proposed removal and/or installation of new trees in the public right-of-way.

The DPR checklist states an arborist report is required “only if requesting to move, replant, replace, etc. a tree located within the City’s public right-of-way.” The Project is proposing to retain the four trees in the right of way along Linden Drive.

An arborist report is not required.

26. Transportation/Traffic Studies
Pursuant to the City’s Local Transportation Assessment Guidelines adopted by Planning Commission Resolution No. 1901, the following transportation/traffic studies are required:
a. Transportation Impact Analysis – Based on the City’s screening criteria, the project does not appear to be screened out from providing a Transportation Impact Analysis. Please provide a Transportation Impact Analysis that evaluates potential Vehicle Miles Traveled (VMT)-related impacts associated with the proposed Project.
b. Local Transportation Assessment – For projects that generate over 75 peak hour trips, a local transportation assessment/traffic study shall be required using Level of Service (LOS) metric to evaluate signalized and unsignalized intersection operation and use the percentage increase in traffic volumes to evaluate impacts on local residential streets. Analyzed locations should primarily consist of major signalized intersections that are likely to be affected by the project. Additionally, the study area should also look at roadways providing access to the project site, such as the roadway(s) containing the project’s primary driveway or secondary access point, or the intersection(s) immediately adjacent to the project site along with the surrounding area. Such report shall be prepared by the applicant and submitted to the City for review and comment by the City’s Traffic Engineer.

Please see the enclosed Transportation Impact Analysis from LLG (Attachment E), dated July 31, 2023 in response to this comment.

27. Transportation and Trip Reduction Measures
Pursuant to BHMC Section 10-7-301, the applicant is required to incorporate various measures to provide for transportation demand management and trip reduction. As the project appears to provide 18 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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more than 50,000 SF of gross floor area for commercial uses, the applicant shall incorporate all required measures into this project, which includes but is not limited to, providing bicycle parking, spaces reserved for vanpool, and information on rideshare and public transit opportunities.

Revise the project to incorporate the applicable transportation and trip reduction measures accordingly.

Please see the enclosed Transportation Impact Analysis by LLG (Attachment E), dated July 31, 2023 in response to this comment.

28. Geotechnical/Soils Report
Provide a geotechnical/soils report for the project and project site. The geotechnical/soils report shall evaluate the proposed project and provide recommendations for the construction of the proposed building based on existing soil conditions. The report should also address the site-specific fault issues and constraints.

Please see the enclosed Geotechnical Investigation by Geocon West, Inc. dated April 8, 2021 (Attachment F) in response to this comment.

29. Construction Management Plan
Provide a construction management plan that provides relevant project construction details, including but not limited to:
• Anticipated timelines forthe different construction phases of the project (e.g., demolition, grading, shoring and excavation, construction of the basement, foundations, and above grade work).
• Proposed locations for the staging of construction materials and equipment. • Anticipated closures of any right-of-way area (alley/street) and timelines for such closures.

Please see the enclosed Draft version of the Construction Management Plan dated June 12, 2023 (Attachment G). This document will be finalized and signed are required during plan check, prior to issuance of a building permit.

30. Noise Study
Provide a noise study of the project to evaluate projected construction noise and noise levels anticipated post-construction with the proposed rooftop outdoor living space uses.

The DPR checklist states that a Noise Study is required “only if request involves rooftop uses or an environmental report is required per CEQA” and then states “Please note that if any type of environmental report is required for the project, a noise study will be prepared by the City’s environmental consultant. The applicant is responsible for all fees associated with such report.” As noted in item #21, the City will contract with an environmental consultant for which the applicant must provide payment after the application resubmittal process is complete. 19 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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The applicant does not need to provide a Noise Study at this time.

31. Metro Adjacent Development Review
The project site is located within close proximity to the upcoming Metro Purple (D Line) subway, which is currently under construction. The subway line is projected to run under Wilshire Boulevard and travel southwest to a station located in Century City, potentially under the project site. To ensure safety, developers, utility companies, and other third parties must consult with Metro for development, construction, and maintenance activities occurring within 100 feet from Metro right-of-way (ROW) and otherreal estate assets.

For information on how to request and obtain Metro Adjacent Development Review, please contact Metro’s Development Review Team at (213) 418-3484 or by email at [email protected]. Additional information can be obtained by visiting https://www.metro.net/about/adjacent-development-review/.

Noted. The project will consultant with Metro and incorporate these requirements as required during the construction document phase.

32. Public Works Stormwater/Environmental Compliance/Sustainability Comments Below are Stormwater/ Environmental Compliance/ Sustainability comments provided by the Public Works Department:
• Project to use available 100% renewable energy from local utilities. • Sewer system capacity requirement. Require hydraulic modeling to assess sewer capacity issues for the development. Improvement to wastewater system if it impacts sewer system flow. • If permanent dewatering system is needed, design the project to re-use groundwater for nonpotable water systems as required pursuant to BHMC Section 9-4-610.B.2. All ground water discharges must have a permit (NPDES) from the Regional Water Quality Control Board and may require a permit from the City of Beverly Hills.
• Appropriate number of approved Meter Service Protection backflow prevention assemblies for Domestic, Irrigation and Fire Meters required.
• Must implement Low Impact Development (LID) meeting requirements of LID ordinance to mitigate stormwater runoff.
• The applicant is required to install a grease interceptor for food service establishment use.

Grease interceptor design shall meet the Los Angeles County Public Works Industrial Waste Program requirements. Placement should be accessible for maintenance operation. • Water discharged from a loading dock and trash enclosure shall be directed through grit/oil separator. A loading dock is not to be confused with a loading zone or designated parking space forloading and unloading.
• Organic residuals from daily operations and water used to wash trash rooms cannot be discharged to surface public right of way.
• Condensate from HVAC and refrigeration equipment shall drain to the sanitary sewer, not 20 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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curb drains.

For questions regarding these comments, please contact Trevor Alsop, Environmental Compliance Inspector, at (310) 288-2837 or by email at [email protected].

Noted. The project will incorporate these requirements as required during the construction document phase.

33. Building and Safety – Building and Technical Code Comments Below are comments provided by Building and Safety regarding compliance with applicable building and technical codes:
• These comments reflect high-level conceptual review comments. Complete code compliance review will be forthcoming upon plan check submittal.
• The review comments are in accordance with 2022 California Building Code and its references. • General contractor must submit Construction Management Plan for review and approval prior to any building permit issuance. The plan needs to address how to the building to be built including demolition, excavation, shoring, access to site for ingress and egress, haul route, tower crane if needed, pedestrian protection, sanitary facilities, a temporary or permanent stairway, standpipe, fire watch during construction, traffic control plan (will be reviewed by Public Works), etc. Referto California Building Code (CBC) Chapter 33. • The project to comply with requirements of Beverly Hills Municipal Code, Title 10 and Chapter 6, STREET, ALLEY, AND HIGHWAY DEDICATIONS AND IMPROVEMENTS. • Survey map is required to show all easements on the properties. • Comply with the City’s applicable parking standards.
https://www.beverlyhills.org/cbhfiles/storage/files/563485925821755963/ParkingStandards(R EV2.18).pdf
• The project requires LID (Low Impact Development) plan check. • On site plan, confirm the location of seismic fault line with dimensions per the seismic fault investigation report.
• Provide complete Fire department and vehicle access.
• Hotel will be classified as R-1 occupancy. CBC 310.
• The project is required to be designed in compliance with requirements of CBC 403, High-rise building and CBC 405, Underground Building.
• The project is required to provide separate accessible parking requirements per CBC 11A and CBC 11B for residential and nonresidential, respectively. Additionally, the project shall provide accessible and standard EV charging parking spaces. Show the location of these required EV parking spaces in the proposed garage.
• The project shall comply with both residential and nonresidential requirements of California Green Building Standards Code in accordance with Beverly Hills Municipal Code, Title 9, Chapter 2 and Article 11.
• The project is required to fully comply with California Energy Code. 21 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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• The project is required fully comply with accessibility provisions of CBC 11A and CBC 11B for residential and nonresidential,respectively.
• The hotel shall be designed in compliance with CBC 11B-224. • The project building shall be designed in compliance with requirements of CBC 705.5 and CBC 705.8.
• The project shall fully comply with requirements of CBC Chapter 10. No exiting analysis was provided.
• The project shall comply with accessible means of egress requirements per CBC 1009. • The enclosed parking structure shall be designed in compliance with CBC 406.

For questions regarding these comments, please contact Ocean Kwon, Senior Plan Review Engineer, at (310) 285-1153 or by email at [email protected].

Noted. The project will incorporate these requirements as required during the construction document phase.

34. Building and Safety – Right of Way Comments
Below are comments provided by Building and Safety regarding areas in the public right-of-way:
• Provide a water demand study to evaluate anticipated water demand for project and for the City to evaluate the types of upgrades and improvements that will be necessary to existing infrastructure.
• Obtain will serve letter from the Public Works Water Division. • Coordinate with Edison to evaluate necessary upgrades to existing infrastructure to facilitate the project and provide the City a proposal of all upgrades required to provide service to the project.
• Provide a Construction Management Plan with a narrative detailing the types of temporary encroachments that the project would require during project construction. Based on the proposal, the project would require working areas for the staging and storage of construction materials, equipment, crane(s), trailers, deliveries, and for a laydown area for transport and maneuvering of vehicles.
• Provide a plan showing the proposed haul routes and delivery route to the project site. To limit construction impacts to residential properties within the vicinity of the project site, all construction-generated traffic should provide ingress and egress to and from the project site directly to Wilshire Boulevard.

For questions regarding these comments, please contact Ara Retchian, Senior Plan Review Engineer, at (310) 285-1106 or by email at [email protected].

Noted. The project will incorporate these requirements as required during the construction document phase.
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35. Fire Department Comments
Below are comments provided by the City’s Fire Department:
• The project shall be designed in compliance with all applicable California Fire Code (CFC) and California Building Code (CBC) requirements for high rise buildings. Although these are preliminary drawings, all applicable high rise requirements shall be considered and incorporated into the project during the design process.

For questions regarding these comments, please contact Cecilia Sohn, Plan Check Inspector, at (310) 281-2716 or by email at [email protected].

Noted. The project will incorporate these requirements as required during the construction document phase.

36. Responses to Corrections Required
On a separate sheet, provide a detailed response to each correction noted in this letter clarifying how each correction was addressed. Submit this response letter when resubmitting your project.

The resubmittal includes this response sheet, with responses to each of the 38 items identified, revised plans, and other materials as noted.

37. Additional Corrections
Based on the responses to this incomplete letter and changes to the project plans, additional corrections may result from the review of the revised project.

Noted.

38. Additional Comments
See redlined set of plans for additional comments.

The plans have been revised per the applicable comments, as noted in this response.

In order for staff to continue processing the case, the foregoing list of corrections must be addressed on a resubmittal of plans and/or application materials, and additional entitlement applications. Before resubmitting your project to the Planning Division, please ensure that all corrections have been addressed and that each correction has been initialed as acknowledged by the architect team. 23 ATTACHMENT B - WRITTEN RESPONSES TO DEEMED INCOMPLETE LETTER COMMENTS

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Once the items above have been addressed and submitted, the application will once again be assessed for completeness. In your response resubmittal, please provide a copy of this letter. Should you have any questions regarding the above comments, please feel free to call me at (310) 285-1138.

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RESIDENTIAL:ACCESSIBLE PARKING REQUIREDCBC SECTION 1109A.3:2% OF COVERED MULTIFAMILY DWELLING UNITS. AT LEAST 1 SPACE: OF EACH TYPE OF PARKING FACILITY SHALL BE MADE ACCESSIBLE.2% x 165 UNITS = 3.3 (ROUNDED) = 4 SPACES.CBC SECTION 1109A.8.61 OF EVERY 8 ACCESSIBLE SPACES SHALL BE VAN ACCESSIBLE, MINIMUM 1 VAN ACCESSIBLE SPACE: 1 SPACE.ELECTRICAL VEHICLE PARKING REQUIRED & PROVIDED:PER CALIFORNIA GREEN BUILDING CODE SECTION 4.106.4.2.25% OF PARKING SHALL BE EV CHARGING STATION INSTALLED 5% x 126 STALLS = 6.3 (ROUNDED) = 6 EVCS25% OF PARKING SHALL BE EV READY25% x 126 STALLS = 31.5 (ROUNDED) = 32 EVSE 10% OF PARKING SHALL BE RACEWAY/ CONDUIT SUPPLIED10% x 126 STALLS = 12.6 (ROUNDED) = 13 CONDUIT INSTALLED PER CALIFORNIA GREEN BUILDING CODE SECTION 4.106.4.2.2: ONE IN EVERY EV 25 SPACES SHALL HAVE AN 8 WIDE MINIMUM AISLE, MINIMUM 1 SPACE.RESIDENTIAL:PARKING SPACES REQUIRED FOR RESIDENTIALPER BHMC 10-3-2830HOTEL:PARKING SPACES REQUIRED FOR HOTELPER BHMC 10-3-27301 PARKING SPACE PER RENTABLE ROOM OR UNIT 73 ROOMS = 73 PARKING SPACES STUDIO, NO BEDROOMS1 BEDROOM2 BEDROOMGUEST PARKING (PER 10-3-2817) 1 SPACE PER UNIT2 SPACES PER UNIT2 1/2 SPACES PER UNIT 1/4 SPACE PER UNIT 352-(&7,1)250$7,21PROJECT NAME:ADDRESS:OWNER:CONSTRUCTION TYPE:PROPOSED BLDG HEIGHT:PROPOSED NUMBER OF STORIES:OCCUPANCY TYPE:
129 LINDEN DR125-129 S LINDEN DR, BEVERLY HILLS, CA 90212DROMY 1995 FAMILY TRUST;9300 WILSHIRE, LLC;9300 WILSHIRE FEE, LLC;E.D. FLORES, LLC;1112 INVESTMENT CO., LLC;EJT WILSHIRE LINDEN, LLC TYPE IA200' - 0"19 STORIESS2 - PARKINGR2 - RESIDENTIAL A3 - ROOF DECK
ALL THAT CERTAIN REAL PROPERTY SITUATED IN THE COUNTY OF LOS ANGELES, STATE OF CALIFORNIA, DESCRIBED AS FOLLOWS:

LOTS 38, 39, AND 40 OF TRACT NO.6648, IN THE CITY OF BEVERLY HILLS, IN COUNTY OF LOS ANGELES, STATE OF CALIFORNIA, AS PER MAP RECORDED IN BOOK 71, PAGE 48 OF MAPS, IN THE OFFICE OF THE COUNTY RECORDER OF SAID COUNTY.

APN: 4328-009-007, 4328-009-021
/(*$/'(6&5,37,21
9,&,1,7<0$3

SANTA MONICA BLVD
SITE:125-129 S LINDEN DR

WILSHIRE BLVD

CHARLEVILLE BLVD

LASKY DR

SPLAUDING DR

S LINDEN DR

S MCCARTY DR

S ROXBURY DR

DURANT DR

ROBBINS DR
ZONING:LOT SIZE:RESIDENTIAL UNITS PROPOSED:HOTEL ROOMS PROPOSED:FAR PROVIDED:

R421,676.05 SF165 UNITS73 ROOMS14.3:1
=21,1*'$7$
$))25'$%/(+286,1*
REQUIRED AFFORDABLE RESIDENTIAL UNITS CALCULATION:REQUIRED AFFORDABLE UNITS: 20% OF TOTAL UNITS 165 x 20% = 33 AFFORDABLE UNITS BUILDING AREA PER 2022 CBC SECTION 202:

AREA, BUILDING. THE AREA INCLUDED WITHIN SURROUNDING EXTERIOR WALLS, OR EXTERIOR WALLS AND FIRE WALLS, EXCLUSIVE OF VENT SHAFTS AND COURTS. AREAS OF THE BUILDING NOT PROVIDED WITH SURROUNDING WALLS SHALL BE INCLUDED IN THE BUILDING AREA IF SUCH AREAS ARE INCLUDED WITHIN THE HORIZONTAL PROJECTION OF THE ROOF OR FLOOR ABOVE. %8,/',1*$5($3(5&%&
259,547 SF X 19.9% = 51,650TOTAL - 311,197 SF
352-(&7'(6&5,37,21
PROPOSED 19-STORY RESIDENTIAL AND HOTEL BUILDING WITH A TOTAL OF 165 UNITS AND 73 HOTEL ROOMS. THERE ARE 4 LEVELS OF SUBTERRANEAN PARKING PROVIDING A TOTAL OF 126 PARKING STALLS. 23(163$&(
REQUIRED OPEN SPACE PER BHMC 10-3-2802
200 SF OF OUTDOOR LIVING SPACE IS REQUIRED FOR EACH DWELLING UNIT. OUTDOOR LIVING SPACE CAN BE PROVIDED WITH A COMBINATION OF PRIVATE AND COMMON SPACES.

COMMON OPEN SPACE
PER BHMC 10-2-2803 COMMON OUTDOOR LIVING SPACE CAN BE PROVIDED AS LONG AS EACH DIMENSION IS AT LEAST 15'-0".

PRIVATE OPEN SPACE
PER BHMC 10-3-2803 PRIVATE OUTDOORD SPACE THAT IS CONTIGUOUS TO A UNIT ( SUCH AS A PATIO) IT SHALL BE SCREENED FROM VIEW FROM THE GROUND LEVEL ADN EACH DIMENSION (LENGTH, WIDTH, DEPTH) SHALL BE AT LEAST 6 FEET.
(17,7/(0(176
'(9(/230(17

ZONING CONFORMANCE TABLE IS NOT APPLICATION AS PROJECT UTILIZES BUILDER'S REMEDY 5(9,(:3(50,7
352-(&77($0
ARCHITECTOTTINGER ARCHITECTS1117 VENICE BLVDLOS ANGELES, CA 90015323.250.2820CONTACT: JESSE OTTINGERLAND USE ATTORNEYRPN LLP633 W. FIFTH STREET, 64TH FLOORLOS ANGELES, CA 90071213.557.7222CONTACT: DAVE RAND OWNERS9300 WILSHIRE, LLC 9744 WILSHIRE BLVD, SUITE 203LOS ANGELES, CA 90212CONTACT: LEO PUSTILNIKOV 6+((7,1'(;
5(6,'(17,$/81,7&2817

UNIT COUNT BY TYPE PERCENTAGE

OF TOTAL AVERAGE AREA UNIT TYPE COUNT
STUDIO 10 6% 450STUDIO AFF 3 2% 4861 BR 47 28% 6491 BR AFF 12 7% 6442 BR 73 44% 9552 BR AFF 18 11% 8932 BR PENTHOUSE 2 1% 3,250TOTAL 165 7,326 $5($6&+('8/(
*5266)/225$5($

LEVEL TYPE AREA
LEVEL P4 PARKING 14,977 SFLEVEL P3 PARKING 14,977 SFLEVEL P2 PARKING 14,977 SFLEVEL P1 PARKING 14,977 SF1ST FLOOR RESIDENTIAL/HOTEL 12,572 SF2ND FLOOR HOTEL 12,748 SF3RD FLOOR HOTEL 12,605 SF4TH FLOOR HOTEL 12,652 SF5TH FLOOR HOTEL 13,638 SF6TH FLOOR RESIDENTIAL 13,932 SF7TH FLOOR RESIDENTIAL 13,905 SF8TH FLOOR RESIDENTIAL 13,908 SF9TH FLOOR RESIDENTIAL 13,905 SF10TH FLOOR RESIDENTIAL 13,970 SF11TH FLOOR RESIDENTIAL 13,974 SF12TH FLOOR RESIDENTIAL 13,970 SF13TH FLOOR RESIDENTIAL 13,907 SF14TH FLOOR RESIDENTIAL 13,902 SF15TH FLOOR RESIDENTIAL 13,909 SF16TH FLOOR RESIDENTIAL 13,824 SF17TH FLOOR RESIDENTIAL 13,887 SF18TH FLOOR RESIDENTIAL 11,295 SF19TH FLOOR RESIDENTIAL 8,785 SFGRAND TOTAL 311,197 SF A00 COVER SHEETA01 PROJECT INFORMATIONA02 RENDERINGA03 RENDERINGA04 RENDERINGA05 MATERIAL BOARDA06 FAR CALCULATIONSA07 FAR CALCULATIONSA08 OPEN SPACE CALCULATIONSA09 OPEN SPACE CALCULATIONSA10 SURVEYA11 SITE PLANA12 P3 & P4 FLOOR PLANA13 P1 & P2 FLOOR PLANA14 1ST & 2ND FLOOR PLANA15 3RD & 4TH FLOOR PLANA16 5TH & 6TH FLOOR PLANA17 7TH & 8TH FLOOR PLANA18 9TH & 10TH FLOOR PLANA19 11TH & 12TH FLOOR PLANA20 13TH & 14TH FLOOR PLANA21 15TH & 16TH FLOOR PLANA22 17TH & 18TH FLOOR PLANA23 19TH FLOOR & ROOF PLANA24 ELEVATIONSA25 ELEVATIONSA26 ELEVATIONSA27 ELEVATIONSA28 SECTIONSA29 SECTIONSA30 SECTIONSA31 SECTIONSA32 SOLAR STUDYA33 DOOR AND WINDOW SCHEDULESA34 DOOR AND WINDOW SCHEDULES 6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
352-(&7,1)250$7,21

/,1'(1'5 
6/,1'(1'5
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3$5.,1*3529,'('

TYPE COUNT
STANDARD 71COMPACT 51
ACCESSIBLE - VAN 2ACCESSIBLE 2
GRAND TOTAL 126

OPEN SPACE REQUIRED

UNIT TYPE NUMBER OF UNITS REQ'D OPEN SPACE
STUDIO 10 2,000 SFSTUDIO AFF 3 600 SF1 BR 47 9,400 SF1 BR AFF 12 2,400 SF2 BR 73 14,600 SF2 BR AFF 18 3,600 SF2 BR PENTHOUSE 2 400 SFTOTAL: 165 33,000 SF +27(/5220&2817

HOTEL ROOM COUNT BY TYPE PERCENTAGE

OF TOTAL AVERAGE AREA ROOM TYPE COUNT
HOTEL ROOM 62 85% 426HOTEL SUITE 11 15% 651TOTAL 73 1,077 $5($6&+('8/(
23(163$&(3529,'('

LEVEL AREA
COMMON OPEN SPACE1ST FLOOR 8,590 SF18TH FLOOR 1,845 SF19TH FLOOR 1,342 SF 11,777 SF
PRIVATE OPEN SPACE6TH FLOOR 455 SF7TH FLOOR 456 SF8TH FLOOR 464 SF9TH FLOOR 464 SF10TH FLOOR 456 SF11TH FLOOR 457 SF12TH FLOOR 465 SF13TH FLOOR 461 SF14TH FLOOR 456 SF15TH FLOOR 541 SF16TH FLOOR 466 SF17TH FLOOR 465 SF18TH FLOOR 453 SF19TH FLOOR 391 SF 6,451 SF
TOTAL 18,228 SF
5(48,5('3$5.,1*

UNIT TYPE QUANTITY STALLS ALLOWED
1 BR 47 941 BR AFF 12 242 BR 73 182.52 BR AFF 18 452 BR PENTHOUSE 2 5HOTEL ROOM 62 62HOTEL SUITE 11 11STUDIO 10 10STUDIO AFF 3 3TOTAL 436.5 L1.00 LEGEND AND NOTESL1.10 GROUND FLOOR CONCEPTUAL

LANDSCAPE PLAN
L1.11 18TH FLOOR CONCEPTUAL

LANDSCAPE PLAN
L1.12 19TH FLOOR CONCEPTUAL

LANDSCAPE PLAN
L1.13 GROUND FLOOR PLANTING
PLAN
L1.14 18TH FLOOR PLANTING PLANL1.15 19TH FLOOR PLANTING PLAN 6+((77,7/(
6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$
W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
5(1'(5,1*

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6/,1'(1'5
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6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$
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30
$
5(1'(5,1*

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6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$
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30
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5(1'(5,1*

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6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$
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30
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0$7(5,$/%2$5'

/,1'(1'5 
6/,1'(1'5
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*/$66*8$5'5$,/
:+,7(
0(7$/)$6&,$
(;7(5,2560227+3/$67(5:+,7(
6725()5217*5$<)5$0(
0(7$/3$1(/6:+,7(
ZONING:

LOT SIZE:RESIDENTIAL UNITS PROPOSED:HOTEL ROOMS PROPOSED:FAR PROVIDED:

R421,676.05 SF165 UNITS73 ROOMS14.3:1
=21,1*'$7$
2' - 6"
2' - 6"
7"
11' - 0" 2' - 6" 2' - 6" 7"
11' - 0"

HOTELRESIDENTIAL
2' - 6" 7"
2' - 6" 11' - 0"
7" 2' - 6"
2' - 6" 11' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
2' - 6" 7"
2' - 6" 11' - 0" 11' - 0" 2' - 6"2' - 6"
7"
11' - 0" 2' - 6"
2' - 6" 7"
2' - 6" 7"
2' - 6" 11' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
/(*(1'
$5($6&+('8/(
)/225$5($

LEVEL TYPE AREA
1ST FLOOR HOTEL 1,708 SF1ST FLOOR RESIDENTIAL 7,140 SF2ND FLOOR HOTEL 11,600 SF3RD FLOOR HOTEL 11,535 SF4TH FLOOR HOTEL 11,597 SF5TH FLOOR HOTEL 11,594 SF6TH FLOOR RESIDENTIAL 11,587 SF7TH FLOOR RESIDENTIAL 11,850 SF8TH FLOOR RESIDENTIAL 11,789 SF9TH FLOOR RESIDENTIAL 11,666 SF10TH FLOOR RESIDENTIAL 11,795 SF11TH FLOOR RESIDENTIAL 11,844 SF12TH FLOOR RESIDENTIAL 11,739 SF13TH FLOOR RESIDENTIAL 11,804 SF14TH FLOOR RESIDENTIAL 11,779 SF15TH FLOOR RESIDENTIAL 11,690 SF16TH FLOOR RESIDENTIAL 11,851 SF17TH FLOOR RESIDENTIAL 11,851 SF18TH FLOOR RESIDENTIAL 9,293 SF19TH FLOOR RESIDENTIAL 7,695 SFTOTAL 213,408 SF 6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
)$5&$/&8/$7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



 
  67)/225
 
  1')/225 
  5')/225
 
  7+)/225 
  7+)/225 
  7+)/225
 
  7+)/225 
  7+)/225 


7+)/225
 
  7+)/225 
  7+)/225 
  7+)/225
ZONING:

LOT SIZE:RESIDENTIAL UNITS PROPOSED:HOTEL ROOMS PROPOSED:FAR PROVIDED:

R421,676.05 SF165 UNITS73 ROOMS14.3:1
=21,1*'$7$
2' - 6" 7"
2' - 6" 11' - 0"
2' - 6" 7"
2' - 6" 11' - 0"

HOTELRESIDENTIAL
11' - 0" 2' - 6"
2' - 6" 7"
2' - 6" 7"
2' - 6" 11' - 0"
2' - 6" 7"
2' - 6" 11' - 0" 11' - 0" 2' - 6" 2' - 6" 7"
2' - 6" 7"
2' - 6" 11' - 0"
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
)$5&$/&8/$7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



/(*(1'
$5($6&+('8/(
)/225$5($

LEVEL TYPE AREA
1ST FLOOR HOTEL 1,708 SF1ST FLOOR RESIDENTIAL 7,140 SF2ND FLOOR HOTEL 11,600 SF3RD FLOOR HOTEL 11,535 SF4TH FLOOR HOTEL 11,597 SF5TH FLOOR HOTEL 11,594 SF6TH FLOOR RESIDENTIAL 11,587 SF7TH FLOOR RESIDENTIAL 11,850 SF8TH FLOOR RESIDENTIAL 11,789 SF9TH FLOOR RESIDENTIAL 11,666 SF10TH FLOOR RESIDENTIAL 11,795 SF11TH FLOOR RESIDENTIAL 11,844 SF12TH FLOOR RESIDENTIAL 11,739 SF13TH FLOOR RESIDENTIAL 11,804 SF14TH FLOOR RESIDENTIAL 11,779 SF15TH FLOOR RESIDENTIAL 11,690 SF16TH FLOOR RESIDENTIAL 11,851 SF17TH FLOOR RESIDENTIAL 11,851 SF18TH FLOOR RESIDENTIAL 9,293 SF19TH FLOOR RESIDENTIAL 7,695 SFTOTAL 213,408 SF  
  7+)/225
 
  7+)/225 
  7+)/225
 
  7+)/225 
  7+)/225 
  7+)/225
 
  
7+)/225
23(163$&(
REQUIRED OPEN SPACE PER BHMC 10-3-2802
200 SF OF OUTDOOR LIVING SPACE IS REQUIRED FOR EACH DWELLING UNIT. OUTDOOR LIVING SPACE CAN BE PROVIDED WITH A COMBINATION OF PRIVATE AND COMMON SPACES.

COMMON OPEN SPACE
PER BHMC 10-2-2803 COMMON OUTDOOR LIVING SPACE CAN BE PROVIDED AS LONG AS EACH DIMENSION IS AT LEAST 15'-0".

PRIVATE OPEN SPACE
PER BHMC 10-3-2803 PRIVATE OUTDOORD SPACE THAT IS CONTIGUOUS TO A UNIT ( SUCH AS A PATIO) IT SHALL BE SCREENED FROM VIEW FROM THE GROUND LEVEL ADN EACH DIMENSION (LENGTH, WIDTH, DEPTH) SHALL BE AT LEAST 6 FEET.
2' - 6" 7"
2' - 6" 11' - 0"
25' - 5" 30' - 6" 53' - 9"
11' - 0" 41' - 4" 44' - 9"
2' - 6" 7"
2' - 6" 11' - 0"

COMMON OPEN SPACEPRIVATE OPEN SPACE
2' - 6" 7"
2' - 6" 11' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
6' - 0"
6' - 0"
6' - 0"
10' - 0"
15' - 0" 14' - 9"
36' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
6' - 0"
36' - 0"
6' - 0"
10' - 0"
29' - 8"
6' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
6' - 0"
16' - 10" 20' - 7"
6' - 0" 10' - 0"
29' - 6"
6' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
6' - 0"
16' - 10" 20' - 7"
10' - 0"
29' - 9"6' - 0"
6' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
6' - 0"
36' - 0"
6' - 0" 10' - 0"
29' - 8"
6' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
6' - 0"
36' - 0"
6' - 0"
6' - 0"
14' - 9" 15' - 0"
10' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
6' - 0"
17' - 0" 20' - 7"
6' - 0"
14' - 10" 14' - 9"
6' - 0"
2' - 6" 7"
2' - 6" 11' - 0"
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
23(163$&(&$/&8/$7,216

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6/,1'(1'5
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  67)/225
 
  1')/225
 
  5')/225
 
  7+)/225 
  7+)/225
 
  7+)/225 
  7+)/225 


7+)/225
 
  7+)/225 
  7+)/225 
  7+)/225
 
  7+)/225

OPEN SPACE REQUIRED

UNIT TYPE NUMBER OF UNITS REQ'D OPEN SPACE
STUDIO 10 2,000 SFSTUDIO AFF 3 600 SF1 BR 47 9,400 SF1 BR AFF 12 2,400 SF2 BR 73 14,600 SF2 BR AFF 18 3,600 SF2 BR PENTHOUSE 2 400 SFTOTAL: 165 33,000 SF /(*(1'
$5($6&+('8/(
23(163$&(3529,'('

LEVEL AREA
COMMON OPEN SPACE1ST FLOOR 8,590 SF18TH FLOOR 1,845 SF19TH FLOOR 1,342 SF 11,777 SF
PRIVATE OPEN SPACE6TH FLOOR 455 SF7TH FLOOR 456 SF8TH FLOOR 464 SF9TH FLOOR 464 SF10TH FLOOR 456 SF11TH FLOOR 457 SF12TH FLOOR 465 SF13TH FLOOR 461 SF14TH FLOOR 456 SF15TH FLOOR 541 SF16TH FLOOR 466 SF17TH FLOOR 465 SF18TH FLOOR 453 SF19TH FLOOR 391 SF 6,451 SF
TOTAL 18,228 SF
23(163$&(
REQUIRED OPEN SPACE PER BHMC 10-3-2802
200 SF OF OUTDOOR LIVING SPACE IS REQUIRED FOR EACH DWELLING UNIT. OUTDOOR LIVING SPACE CAN BE PROVIDED WITH A COMBINATION OF PRIVATE AND COMMON SPACES.

COMMON OPEN SPACE
PER BHMC 10-2-2803 COMMON OUTDOOR LIVING SPACE CAN BE PROVIDED AS LONG AS EACH DIMENSION IS AT LEAST 15'-0".

PRIVATE OPEN SPACE
PER BHMC 10-3-2803 PRIVATE OUTDOORD SPACE THAT IS CONTIGUOUS TO A UNIT ( SUCH AS A PATIO) IT SHALL BE SCREENED FROM VIEW FROM THE GROUND LEVEL ADN EACH DIMENSION (LENGTH, WIDTH, DEPTH) SHALL BE AT LEAST 6 FEET.
6' - 0"
16' - 10" 20' - 7"
10' - 0"
29' - 0"
6' - 0"
6' - 0"
6' - 0"
36' - 2"
6' - 0"
29' - 7"
6' - 0"
10' - 0"

COMMON OPEN SPACEPRIVATE OPEN SPACE
6' - 0"
36' - 2"
6' - 0"
43' - 7"
6' - 0"
10' - 0"
6' - 0"
17' - 0" 20' - 9"
6' - 0"
6' - 0"
10' - 0"
29' - 5"
17' - 0" 20' - 9"
6' - 0"
6' - 0" 10' - 0"
29' - 3"
6' - 0"
36' - 0"
6' - 0"
6' - 0"
15' - 1" 14' - 1"
6' - 1"
25' - 6"
35' - 9"
26' - 0"
35' - 11"
35' - 4"
6' - 0"
6' - 0"
14' - 8"
44' - 9"
30' - 0"
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$

23(163$&(&$/&8/$7,216

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6/,1'(1'5
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/(*(1'

OPEN SPACE REQUIRED

UNIT TYPE NUMBER OF UNITS REQ'D OPEN SPACE
STUDIO 10 2,000 SFSTUDIO AFF 3 600 SF1 BR 47 9,400 SF1 BR AFF 12 2,400 SF2 BR 73 14,600 SF2 BR AFF 18 3,600 SF2 BR PENTHOUSE 2 400 SFTOTAL: 165 33,000 SF  
  7+)/225
 
  7+)/225
 
  7+)/225
 
  7+)/225 
  7+)/225 
  7+)/225
 
  
7+)/225 $5($6&+('8/(
23(163$&(3529,'('

LEVEL AREA
COMMON OPEN SPACE1ST FLOOR 8,590 SF18TH FLOOR 1,845 SF19TH FLOOR 1,342 SF 11,777 SF
PRIVATE OPEN SPACE6TH FLOOR 455 SF7TH FLOOR 456 SF8TH FLOOR 464 SF9TH FLOOR 464 SF10TH FLOOR 456 SF11TH FLOOR 457 SF12TH FLOOR 465 SF13TH FLOOR 461 SF14TH FLOOR 456 SF15TH FLOOR 541 SF16TH FLOOR 466 SF17TH FLOOR 465 SF18TH FLOOR 453 SF19TH FLOOR 391 SF 6,451 SF
TOTAL 18,228 SF

S. LINDEN DRIVE
(E) BUILDING
4 STORIES
PROPOSED 19-STORY RESIDENTIAL BUILDING
WITH 165 UNITS AND 73 HOTEL ROOMS. 4

LEVELS OF SUBTERRANEAN PARKING
PROVIDING 126 PARKING STALLS
SITE SF: 21,676.05

PARKING

ENTRANCE
HOTEL

ENTRANCE

LOADING
ZONE
(E) BUILDING
4 STORIES
(E) BUILDING
2 STORIES

EMPTY LOT
(E) PARKING
LOT
(E) BUILDING
2 STORIES
(E) BUILDING
2 STORIES
(E) BUILDING
2 STORIES
7"
7' - 6" 127' - 6" 12' - 0" 18' - 0"
11' - 0"
169' - 11"
5' - 10"
ALLEY
ALLEY
7' - 6"

RESIDENTIAL

ENTRANCE
163' - 0" 7' - 0" (E) TREE
(E) TREE

SITE FAULT LINE

LINE OF BUILDING OUTLINE ABOVE
(N) TREE
(E) TREE
(N) TREE
(N) TREE

DEDICATION
2' - 6" SITE

DEDICATION
2' - 6" SITE
(E) SIGN POST
(E) STREET LIGHT

SIDE WALK

PARKWAY
CURB
5' - 0"
7' - 0" 18' - 0" 18' - 0" 7' - 0"
5' - 0"
60' - 0"
129 S. LINDEN DRIVEHEIGHT DISTRICT CMAX 5 STORIES / 55' TALL 125 S. LINDEN DRIVEHEIGHT DISTRICT BMAX 4 STORIES / 45' TALL

NO BUILD ZONE
(E) SIGN POST
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
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6,7(3/$1

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  6,7(3/$1






1 NOTE:PER BHMC SECTION 8-4-1, THE PARKWAY

ADJACENT TO THE PROJECT SITE SHALL BE
PLANTED AND MAINTATED WITH GRASS OR OTHER PLANT MATERIAL THAT IS MAINTAINED AT NO MORE THAN SIX INCHES (6") IN HEIGHT. REFER TO L1.00-L1.15 FOR PROPOSED LANDSCAPING. 6' HIGH SETAL SECURTIY GATE AND FENCE
83 83
'1
'1
'1
5(6 65(6 65(6 65(6 6
5(6
&
5(6
&
5(66
5(66
5(66
5(66
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5(6 6
5(665(665(665(665(665(665(66
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$

$

$

$

$

$

$


$

67$,5

SITE DEDICATION
2' - 6"
123' - 6" 1' - 6"
S
T
I
E
D
E
D
C
I
A
T
O
I
N
2 '
-
6 "
1 5
9 '
-
5 "
8 '
-
0 "
2' - 6" 123' - 6" 1' - 6"
8 '
-
0 "
1 5
9 '
-
5 "
2'
-
6 "

16.6% MAX
SLOPE
5% MAX SLOPE

16.6% MAX
SLOPE
5% MAX SLOPE
3$5.,1*
67$,5
(/(9/2%%<
5(6(/(9
+27(/(/(9
(/(9/2%%<
87,/,7<
TY
P
1 '
-
0 "
M
N
I
24' - 6" TYP 19' - 0" TYP
19'
- 0"
TYP
24'
- 0"
MIN
4 '
-
5 "
19' - 0" TYP 23' - 0" MIN
1 7
'
-
0 "
T
Y
P
7' - 6" TYP
TY
P
1 '
-
0 "
M
N
I
TY
P
1 '
-
0 "
M
N
I
24' - 0" MIN
5(6(/(9
+27(/(/(9

NO BUILD ZONE

$

$

$

$

$

$

$


$

SITE DEDICATION
2' - 6"
123' - 6" 1' - 6"
S
T
I
ED
E
D
C
I
A
T
O
I
N
2 '
-
6 "
1 5
9 '
-
5 "
8'
-
0 "
2' - 6" 123' - 6" 1' - 6"
8'
-
0 "
1 5
9 '
-
5 "
2 '
-
6 "
5% MAX SLOPE

16.6% MAX
SLOPE
5% MAX SLOPE
(/(9/2%%<
67$,5
5(6(/(9
67$,5
+27(/(/(9
(/(9/2%%<
87,/,7<
TY
P
1 '
-
0 "
M
IN
24' - 6" TYP 19' - 0" TYP
19'
- 0"
TYP
24'
- 0"
MIN
4'
-
5 "
1 7
'
-
0 "
T
Y
P
7' - 6" TYP
TY
P
1 '
-
0 "
M
N
I
TY
P
1 '
-
0 "
M
N
I
24' - 0" MIN
5(6(/(9
+27(/(/(9
1' - 6"

NO BUILD ZONE
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
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$

$

$

$

$

$

$


$

17' - 0" TYP 25' - 0" MIN
1 '
-
0 "

SITE DEDICATION
2' - 6"
123' - 6" 1' - 6"
S
T
I
E
D
E
D
C
I
A
T
O
I
N
2 '
-
6 "
1 5
9 '
-
5 "
8 '
-
0 "
2' - 6" 123' - 6" 1' - 6"
8 '
-
0 "
1 5
9 '
-
5 "
2'
-
6 "
2 4
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-
0 "
M
N
I
2 8
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-
3 "
2 4
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0 "
67$,5
67$,5
5(6(/(9
+27(/(/(9
(/(9/2%%<
17'
- 0"
24'
- 0"
MIN
19'
- 0"
TYP (/(9/2%%<

16.6% MAX
SLOPE

16.6% MAX
SLOPE
3$5.,1*
2 3
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-
0 "
'1 83
5(6(/(9
+27(/(/(9

NO BUILD ZONE
87,/,7<
19' - 0" TYP

$

$

$

$

$

$

$


$

SITE DEDICATION
2' - 6"
123' - 6" 1' - 6"
S
T
I
ED
E
D
C
I
A
T
O
I
N
2 '
-
6 "
1 5
9 '
-
5 "
8 '
-
0 "
2' - 6" 123' - 6" 1' - 6"
8'
-
0 "
1 5
9 '
-
5 "
2 '
-
6 "
TY
P
1 '
-
0 "
M
N
I
19' - 0" TYP 19' - 0" TYP
24' - 0" MIN
24' - 6"
67$,5
67$,5
5(6(/(9
+27(/(/(9
(/(9/2%%<

16.6% MAX
SLOPE
5% MAX SLOPE

16.6% MAX
SLOPE
5% MAX SLOPE
3$5.,1*
19'
- 0"
TYP
24'
- 0"
MIN
4'
-
5 "
(/(9/2%%<
87,/,7<
TY
P
1 '
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0 "
M
N
I
TY
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1 '
-
0 "
M
N
I
1 7
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0 "
T
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7' - 6" TYP
24' - 0" MIN
5(6(/(9
+27(/(/(9

NO BUILD ZONE
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
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6)
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6)
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6)
+27(/5(6785$17
5' - 10" 121' - 1" SETBACK 7"
7' - 0" 152' - 0" 11' - 0"
7' - 0" 152' - 0"

SETBACK
11' - 0"
37' - 2" 14' - 0" 14' - 9" 65' - 2" 20' - 11"
5' - 10" 67' - 11" 53' - 9"
37' - 5" 30' - 6"
5(6(/(9
+27(/(/(9
5(6(/(9

SEISMIC FAULT LINE

SITE DEDICATION
2' - 6"
S
T
I
E
D
E
D
C
I
A
T
O
I
N
2 '
-
6 "
70' - 6" 13' - 11" 36' - 8"

$

$

$

$
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$

$

$


SEISMIC FAULT LINE
$//(<
6)
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6)
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67$,5
67$,5
(/(9$725/2%%<(/(9$725/2%%<
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5(6(/(9
6)
/2$',1,*=21(
)5(,*+7(/(9
6)
5(6
/2%%<
87,/,7<
5' - 10" 121' - 1" SETBACK
7"
7'
-
0 "
7 '
-
0 "
1 5
2 '
-
0 "
S
E
T
B
A
C
K
1 1
'
-
0 "
3 7
'
-
2 "
2 8
'
-
9 "
4 4
'
-
9 "
5' - 10" 67' - 11" 53' - 9"
31' - 6" 5' - 11" 30' - 6" 44' - 6"
67$,5
MIN.
18' - 0" 48' - 7" 9' - 9" 26' - 7"
2 5
'
-
5 "
5 '
-
9 "
2 3
'
-
9 "
1 4
'
-
1 1
"
3 0
'
-
7 "
1 4
'
-
1 1
"
9 '
-
9 "
2 7
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-
1 "
1 5
2 '
-
0 "
1 1
'
-
0 "
5(6(/(9
+27(/(/(9
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'
-
4 "
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12.5% MAX SLOPE 16.6% MAX SLOPE '1
6' HIGH METAL SECURITY GATE & FENCE

NO BUILD ZONE

SITE DEDICATION
2' - 6"
S
T
I
E
D
E
D
C
I
A
T
O
I
N
2 '
-
6 "
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
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$

$

$

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$

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$

$


$

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67$,5
67$,5
(/(9$725/2%%<
6725$*(
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+27(/(/(9
)5(,*+7(/(9
,')
75$6+
,')
5' - 10" 121' - 1" SETBACK
7"
7 '
-
0 "
1 5
2 '
-
0 "
1 1
'
-
0 "
7 '
-
0 "
S
E
T
B
A
C
K
1 5
2 '
-
0 "
S
E
T
B
A
C
K
1 1
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0 "
3 7
'
-
2 "
1 4
'
-
2 "
1 4
'
-
8 "
1 9
'
-
9 "
3 0
'
-
1 0
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1 4
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-
7 "
2 0
'
-
1 1
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5' - 10" 74' - 0" 47' - 8"
37' - 5" 30' - 6" 6' - 1"
5(6(/(9 5(6(/(9
+27(/(/(9
40' - 4" 14' - 3" 66' - 6"
1 4
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-
3 "
3 7
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-
9 "
1 4
'
-
4 "
8 5
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-
9 "

SEISMIC FAULT LINE
6)
+27(/
5220
6)
+27(/
5220
6)
+27(/
5220
6)
+27(/
5220

6)
+27(/
5220
6)
+27(/68,7(
6)
+27(/
5220
6)
+27(/68,7(
6)
+27(/
5220
6)
+27(/
5220
6)
+27(/
5220

6)
+27(/
5220
6)
+27(/
5220

6)
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5220
6)
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5220
6)
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6)
+27(/
5220
6)
+27(/
5220
6)
+27(/
5220
6)
+27(/
5220
6)
+27(/
5220

SITE DEDICATION
2' - 6"
S
T
I
E
D
E
D
C
I
A
T
O
I
N
2 '
-
6 "

$

$

$

$
$

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$

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75$6+
,')
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(/(9$725/2%%<
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5' - 10" 121' - 1" SETBACK
7"
7'
-
0 "
1 5
2 '
-
0 "
1 1
'
-
0 "
7 '
-
0 "
1 5
2 '
-
0 "
S
E
T
B
A
C
K
1 1
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-
0 "
3 7
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-
2 "
1 4
'
-
0 "
1 4
'
-
4 "
2 0
'
-
2 "
3 0
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-
1 0
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1 4
'
-
7 "
2 0
'
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1 1
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5' - 10" 74' - 0" 47' - 8"
37' - 5" 30' - 6" 6' - 1"
67$,5
67$,5
+27(/(/(9
5(6(/(9
70' - 2" 14' - 4" 36' - 7"
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1 0
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1 4
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2 "
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1 "

SEISMIC FAULT LINE
6)
+27(/
5220
6)
+27(/
5220
6)
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5220
6)
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5220

6)
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6)
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5220
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5220
6)
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5220

SITE DEDICATION
2' - 6"
S
T
I
E
D
E
D
C
I
A
T
O
I
N
2 '
-
6 "
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
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5' - 10" 121' - 1" SETBACK
7"
7 '
-
0 "
1 5
2 '
-
0 "
1 1
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-
0 "
7 '
-
0 "
1 5
2 '
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0 "
S
E
T
B
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1 1
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2 "
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0 "
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4 "
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2 "
1 5
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6 "
1 4
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5 "
1 5
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1 1
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5' - 10" 74' - 0" 47' - 8"
37' - 5" 30' - 6" 6' - 1"
5(6(/(9
4 5
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-
5 "
1 4
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-
2 "
4 7
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-
0 "
1 4
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4 "
3 1
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-
2 "
14' - 11" 106' - 3"

SEISMIC FAULT LINE
6)
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6)
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6)
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SITE DEDICATION
2' - 6"
S
T
I
E
D
E
D
C
I
A
T
O
I
N
2 '
-
6 "

$

$

$

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$

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6)
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6)
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6)
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6)
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6)
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75$6+
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5220
6)
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5' - 10" 121' - 1" SETBACK
7"
7'
-
0 "
1 5
2 '
-
0 "
1 1
'
-
0 "
7 '
-
0 "
S
E
T
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K
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9 "
1 4
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-
2 "
1 5
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7 "
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2' - 6"
77' - 4" 47' - 8"
40' - 9" 30' - 6" 6' - 1"
5(6(/(9
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1 4
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-
3 "9
2 '
-
5 "
1 4
'
-
2 "
3 1
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-
2 "
40' - 4" 14' - 4" 66' - 5"

SEISMIC FAULT LINE

SITE DEDICATION
2' - 6"
S
T
I
E
D
E
D
C
I
A
T
O
I
N
2 '
-
6 "
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
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67$,5
67$,5
5(6(/(9
(/(9$725/2%%<
,')
75$6+
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5' - 10" 121' - 1" SETBACK
7"
7 '
-
0 "
1 5
2 '
-
0 "
1 1
'
-
0 "
7 '
-
0 "
1 5
2 '
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0 "
S
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B
A
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4 "
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4 "
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1 1
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5' - 10" 74' - 0" 47' - 8"
37' - 5" 30' - 3" 6' - 5"
5(6(/(9
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5 "
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3 "
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SEISMIC FAULT LINE
6)
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SITE DEDICATION
2' - 6"
S
T
I
E
D
E
D
C
I
A
T
O
I
N
2 '
-
6 "
106' - 1" 14' - 4"

$

$

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$

$

$


$

$

$


$

67$,5
67$,5
5(6(/(9
(/(9$725/2%%<
,')
75$6+
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5' - 10" 121' - 1" SETBACK
7"
7'
-
0 "
1 5
2 '
-
0 "
1 1
'
-
0 "
3 7
'
-
2 "
1 3
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-
9 "
1 4
'
-
7 "
2 0
'
-
2 "
1 5
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-
0 "
3 0
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5' - 10" 74' - 0" 47' - 8"
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SEISMIC FAULT LINE
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16' - 10" 14' - 2" 39' - 4" 14' - 1" 36' - 8"

SEISMIC FAULT LINE
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SITE DEDICATION
2' - 6"
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SEISMIC FAULT LINE
33' - 3"
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SITE DEDICATION
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SEISMIC FAULT LINE
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SITE DEDICATION
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$

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5' - 10" 74' - 0" 47' - 8"
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SITE DEDICATION
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5' - 10" 74' - 0" 47' - 8"
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5 "
40' - 4" 14' - 4" 66' - 5"

SEISMIC FAULT LINE
1 0
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2 "

SITE DEDICATION
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5' - 10" 74' - 0" 47' - 8"
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SEISMIC FAULT LINE
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SITE DEDICATION
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SEISMIC FAULT LINE
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SITE DEDICATION
2' - 6"
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SITE DEDICATION
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SEISMIC FAULT LINE

SITE DEDICATION
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37' - 5" 30' - 6" 6' - 1"
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SITE DEDICATION
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SOLAR PANEL TRELLIS OVER MECH EQUIP

MECHANICAL EQUIP

MECHANICAL EQUIP
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5' - 10" 94' - 11" 26' - 10"
7 '
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5' - 10" 67' - 11" 53' - 9"
31' - 6" 36' - 6"
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84' - 5" 10' - 6"
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SEISMIC FAULT LINE
INTERNAL DRAIN, TYP.SLOPE 2% MIN, TYP.

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60" HIGH MECHANICAL SCREENING, TYP.

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5' - 10" 74' - 0" 47' - 8"
36' - 8" 31' - 3" 6' - 1"
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SEISMIC FAULT LINE
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SITE DEDICATION
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7+)/225 522)3/$1

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



1 





 
  522)/(9(/  
  
7+)/2253/$1
1ST FLOOR
+255.93
2ND FLOOR
+270.93
3RD FLOOR
+285.93
4TH FLOOR
+295.93

TO PARAPET
+461.43

ROOF LEVEL
+457.93
5TH FLOOR
+305.93

ROOF STRUCTURES
+468.93
7<3

7<3

6TH FLOOR
+315.93
7TH FLOOR
+325.93
8TH FLOOR
+335.93
12TH FLOOR
+375.93

HIGHEST POINT
+258.05
3/ 3/ 7<3

7<3

7' - 6" 3' - 6" 12' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 15' - 0" 15' - 0" 200' - 0".
9TH FLOOR
+345.93
10TH FLOOR
+355.93
11TH FLOOR
+365.93
13TH FLOOR
+385.93
14TH FLOOR
+395.93
15TH FLOOR
+405.93
16TH FLOOR
+415.93
17TH FLOOR
+425.93
18TH FLOOR
+435.93
19TH FLOOR
+445.93
7<3

7<3

MAX 4 STORIES/ 45' TALL

HEIGHT DISTRICT B
MAX 5 STORIES / 55' TALL

HEIGHT DISTRICT C

SITE DEDICATION
2' - 6"
7<3
SETBACK 
11' - 0"
7<3

1 CLEAR ANODIZED ALUMINUM WINDOW SYSTEM W/

LOW E GLASS
2 CLEAR ANONODIZED ALUMINUM STOREFRONT3 42" HIGH GLASS GUARDRAIL4 EXTERIOR SMOOTH PLASTER, WHITE5 42" HIGH PARAPET6 METAL PANEL SIDING, WHITE7 EXTERIOR LINEAR RECESSED LED STRIP LIGHT8 60" HIGH MECHANICAL SCREEN, TYP9 MECHANICAL TRELLIS 6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
(/(9$7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



.(<127(6
 
  ($67%8,/',1*(/(9$7,21
1ST FLOOR
+255.93
2ND FLOOR
+270.93
3RD FLOOR
+285.93
4TH FLOOR
+295.93

TO PARAPET
+461.43

ROOF LEVEL
+457.93
5TH FLOOR
+305.93

ROOF STRUCTURES
+468.93
6TH FLOOR
+315.93
7TH FLOOR
+325.93
8TH FLOOR
+335.93
12TH FLOOR
+375.93

HIGHEST POINT
+258.05
3/ 3/
7<3

7<3

15' - 0" 15' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 12' - 0" 3' - 6"
7' - 6"
200' - 0".
9TH FLOOR
+345.93
10TH FLOOR
+355.93
11TH FLOOR
+365.93
13TH FLOOR
+385.93
14TH FLOOR
+395.93
15TH FLOOR
+405.93
16TH FLOOR
+415.93
17TH FLOOR
+425.93
18TH FLOOR
+435.93
19TH FLOOR
+445.93
7<3

7<3

7<3

7<3


SITE DEDICATION
2' - 6"
7<3


SETBACK
7"
7<3

6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
(/(9$7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



 
  1257+%8,/',1*(/(9$7,21
1 CLEAR ANODIZED ALUMINUM WINDOW SYSTEM W/

LOW E GLASS
2 CLEAR ANONODIZED ALUMINUM STOREFRONT3 42" HIGH GLASS GUARDRAIL4 EXTERIOR SMOOTH PLASTER, WHITE5 42" HIGH PARAPET6 METAL PANEL SIDING, WHITE7 EXTERIOR LINEAR RECESSED LED STRIP LIGHT8 60" HIGH MECHANICAL SCREEN, TYP9 MECHANICAL TRELLIS .(<127(6
1ST FLOOR
+255.93
2ND FLOOR
+270.93
3RD FLOOR
+285.93
4TH FLOOR
+295.93

TO PARAPET
+461.43

ROOF LEVEL
+457.93
5TH FLOOR
+305.93

ROOF STRUCTURES
+468.93
6TH FLOOR
+315.93
7TH FLOOR
+325.93
8TH FLOOR
+335.93
12TH FLOOR
+375.93

HIGHEST POINT
+258.05
3/ 3/ 7<3

7' - 6"
3' - 6"
12' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 15' - 0" 15' - 0" 7<3

7<3

9TH FLOOR
+345.93
10TH FLOOR
+355.93
11TH FLOOR
+365.93
13TH FLOOR
+385.93
14TH FLOOR
+395.93
15TH FLOOR
+405.93
16TH FLOOR
+415.93
200' - 0".
17TH FLOOR
+425.93
18TH FLOOR
+435.93
19TH FLOOR
+445.93
*$5$*((175<
7<3

7<3

7<3

MAX 5 STORIES / 55' TALL

MAX DISTRICT C
MAX 4 STORIES / 45' TALL

MAX DISTRICT B

SITE DEDICATION
2' - 6"
7<3


SETBACK
11' - 0"
7<3

6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76




30
$
(/(9$7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



1 CLEAR ANODIZED ALUMINUM WINDOW SYSTEM W/

LOW E GLASS
2 CLEAR ANONODIZED ALUMINUM STOREFRONT3 42" HIGH GLASS GUARDRAIL4 EXTERIOR SMOOTH PLASTER, WHITE5 42" HIGH PARAPET6 METAL PANEL SIDING, WHITE7 EXTERIOR LINEAR RECESSED LED STRIP LIGHT8 60" HIGH MECHANICAL SCREEN, TYP9 MECHANICAL TRELLIS .(<127(6
 
  :(67%8,/',1*(/(9$7,21
1ST FLOOR
+255.93
2ND FLOOR
+270.93
3RD FLOOR
+285.93
4TH FLOOR
+295.93

TO PARAPET
+461.43

ROOF LEVEL
+457.93
5TH FLOOR
+305.93

ROOF STRUCTURES
+468.93
6TH FLOOR
+315.93
7TH FLOOR
+325.93
8TH FLOOR
+335.93
12TH FLOOR
+375.93

HIGHEST POINT
+258.05
3/ 3/
7' - 6"
3' - 6"
12' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 15' - 0" 15' - 0" 200' - 0".
7<3

7<3

7<3

9TH FLOOR
+345.93
10TH FLOOR
+355.93
11TH FLOOR
+365.93
13TH FLOOR
+385.93
14TH FLOOR
+395.93
15TH FLOOR
+405.93
16TH FLOOR
+415.93
17TH FLOOR
+425.93
18TH FLOOR
+435.93
19TH FLOOR
+445.93
7<3

7<3

7<3

7<3


SITE DEDICATION
2' - 6"
7<3


SETBACK
7"
7<3

6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
(/(9$7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



1 CLEAR ANODIZED ALUMINUM WINDOW SYSTEM W/

LOW E GLASS
2 CLEAR ANONODIZED ALUMINUM STOREFRONT3 42" HIGH GLASS GUARDRAIL4 EXTERIOR SMOOTH PLASTER, WHITE5 42" HIGH PARAPET6 METAL PANEL SIDING, WHITE7 EXTERIOR LINEAR RECESSED LED STRIP LIGHT8 60" HIGH MECHANICAL SCREEN, TYP9 MECHANICAL TRELLIS .(<127(6
 
  6287+%8,/',1*(/(9$7,21
1ST FLOOR
+255.93
2ND FLOOR
+270.93
3RD FLOOR
+285.93
4TH FLOOR
+295.93
LEVEL P1
+244.93
LEVEL P2
+234.93

TO PARAPET
+461.43

ROOF LEVEL
+457.93
LEVEL P3
+224.93
5TH FLOOR
+305.93

ROOF STRUCTURES
+468.93

LOWEST POINT
+255.82
6TH FLOOR
+315.93
7TH FLOOR
+325.93
8TH FLOOR
+335.93
12TH FLOOR
+375.93

HIGHEST POINT
+258.05
9TH FLOOR
+345.93
10TH FLOOR
+355.93
11TH FLOOR
+365.93
13TH FLOOR
+385.93
14TH FLOOR
+395.93
15TH FLOOR
+405.93
16TH FLOOR
+415.93
10' - 0" 10' - 0" 10' - 0" 11' - 0" 15' - 0" 15' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 12' - 0" 3' - 6"
7' - 6"
17TH FLOOR
+425.93
18TH FLOOR
+435.93
19TH FLOOR
+445.93
LEVEL P4
+214.93
3/ 3/
+27(/5(6785$17
&20081,7<
5220 3$5.,1*5$03
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220+27(/
5220
+27(/
5220
%5$)) 678',2$)) 678',2%5$)) 678',2$))%5$))
%5$))%5$))
%5$))
%5%5%5%5
%5%5%5
678',2$))
678',2
678',2
678',2678',2678',2678',2678',2678',2678',2
%5
%5%5%5%5%5%5%5%5%5%5%5
+27(/
5220
%5%5%5%5%5%5%5
%5%5
%5%5%5%5
%53(17+286( %53(17+286(
  
3$5.,1*3$5.,1*3$5.,1*3$5.,1*
&2857<$5'
3$5.,1*
3$5.,1*3$5.,1*3$5.,1*
5(6
/2%%<
3$5.,1*5$033$5.,1*5$033$5.,1*5$033$5.,1*5$03
+27(/(/(9
5(6(/(9
$//(<
&255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 (E) 2 STORY BUILDING
(E) 6 STORY BUILDING
60' - 0"
24' - 0"

SITE DEDICATION
2' - 6"

(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<
(/(9
/2%%<

SETBACK
11' - 0"
200' - 0".
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
6(&7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



1 MECHANICAL TRELLIS2 MECHANICAL EQUIPMENT3 ELEVATOR PENTHOUSE4 STAIR PENTHOUSE5 60" HIGH MECHANICAL SCREENING, TYP 





.(<127(6
 
  6(&7,21
1ST FLOOR
+255.93
2ND FLOOR
+270.93
3RD FLOOR
+285.93
4TH FLOOR
+295.93
LEVEL P1
+244.93
LEVEL P2
+234.93

TO PARAPET
+461.43

ROOF LEVEL
+457.93
LEVEL P3
+224.93
5TH FLOOR
+305.93

ROOF STRUCTURES
+468.93

LOWEST POINT
+255.82
6TH FLOOR
+315.93
7TH FLOOR
+325.93
8TH FLOOR
+335.93
12TH FLOOR
+375.93

HIGHEST POINT
+258.05
9TH FLOOR
+345.93
10TH FLOOR
+355.93
11TH FLOOR
+365.93
13TH FLOOR
+385.93
14TH FLOOR
+395.93
15TH FLOOR
+405.93
16TH FLOOR
+415.93
17TH FLOOR
+425.93
18TH FLOOR
+435.93
19TH FLOOR
+445.93
LEVEL P4
+214.93
15' - 0" 15' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 12' - 0" 3' - 6"
7' - 6"
3/ 3/
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
%5%5%5%5%5%5%5%5%5%5%5%5 %5$)) %5 %5 %5 %5
%53(17+286(
67$,5
%5$)) %5 %5
5(6
/2%%<
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220 +27(/68,7(
+27(/68,7(+27(/68,7(+27(/68,7( +27(/ 5220 +27(/ 5220 +27(/ 5220 +27(/ 5220 +27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
%5$))%5$))%5$))%5$))%5$))%5$)) %5
%5%5%5%5%5
%5%5%5%5%5%5%5%5%5
%5 %5%5%5
%5$)) %5%5$))%5$))%5$))
  
3$5.,1*
3$5.,1* 3$5.,1*
3$5.,1*3$5.,1*3$5.,1*
3$5.,1*3$5.,1*
/,1'(1'5 $//(<
CLR
8' - 2"
67$,567$,567$,567$,567$,567$,567$,567$,567$,567$,567$,567$,567$,567$,567$,567$,567$,567$,5 (E) BUILDING 50' - 0"

SITE DEDICATION
2' - 6" 

SETBACK
7"
200' - 0" .
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$

6(&7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



1 MECHANICAL TRELLIS2 MECHANICAL EQUIPMENT3 ELEVATOR PENTHOUSE4 STAIR PENTHOUSE5 60" HIGH MECHANICAL SCREENING, TYP 





.(<127(6
 
  6(&7,21
1ST FLOOR
+255.93
2ND FLOOR
+270.93
3RD FLOOR
+285.93
4TH FLOOR
+295.93
LEVEL P1
+244.93
LEVEL P2
+234.93

TO PARAPET
ROOF LEVEL +461.43
+457.93
LEVEL P3
+224.93
5TH FLOOR
+305.93

ROOF STRUCTURES
+468.93

LOWEST POINT
+255.82
3' - 6"
12' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 15' - 0" 15' - 0" 6TH FLOOR +315.93 7TH FLOOR +325.93 8TH FLOOR +335.93 12TH FLOOR +375.93 HIGHEST POINT +258.05 9TH FLOOR +345.93 10TH FLOOR +355.93 11TH FLOOR +365.93 13TH FLOOR +385.93 14TH FLOOR +395.93 15TH FLOOR +405.93 16TH FLOOR +415.93 17TH FLOOR +425.93 18TH FLOOR +435.93 19TH FLOOR +445.93 LEVEL P4
+214.93
3/ 3/
%5%5%5%5%5%5%5%5%5%5
+27(/
5220
+27(/
5220
+27(/
5220
%5%5%5
%53(17+286(
%5%5%5%5%5%5%5%5%5%5%5%5
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220
+27(/
5220 +27(/68,7(
+27(/68,7(
+27(/68,7(
%5%5%5%5%5%5%5%5%5%5%5
%5 %5%5%5%5%5%5%5%5%5%5%5%5
%5
%53(17+286(
+27(/
5220
/2$',1,*=21(
3$5.,1*3$5.,1*3$5.,1*3$5.,1*
+27(/5(6785$17
+27(//2%%<
&255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 (/(9$725 29(5581 +27(/(/(9$725
+27(/(/(9$725
&255 &255 &255 &255 (E) 6 STORY BUILDING
60' - 0"
$//(< /,1'(1'5

SITE DEDICATION
2' - 6"

SETBACK
7"
200' - 0" .
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76




30
$
6(&7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



1 MECHANICAL TRELLIS2 MECHANICAL EQUIPMENT3 ELEVATOR PENTHOUSE4 STAIR PENTHOUSE5 60" HIGH MECHANICAL SCREENING, TYP 





.(<127(6
1ST FLOOR
+255.93
2ND FLOOR
+270.93
3RD FLOOR
+285.93
4TH FLOOR
+295.93
LEVEL P1
+244.93
LEVEL P2
+234.93

TO PARAPET
ROOF LEVEL +461.43
+457.93
LEVEL P3
+224.93
5TH FLOOR
+305.93

ROOF STRUCTURES
+468.93

LOWEST POINT
+255.82
6TH FLOOR
+315.93
7TH FLOOR
+325.93
8TH FLOOR
+335.93
12TH FLOOR
+375.93

HIGHEST POINT
+258.05
9TH FLOOR
+345.93
10TH FLOOR
+355.93
11TH FLOOR
+365.93
13TH FLOOR
+385.93
14TH FLOOR
+395.93
15TH FLOOR
+405.93
16TH FLOOR
+415.93
17TH FLOOR
+425.93
18TH FLOOR
+435.93
19TH FLOOR
+445.93
LEVEL P4
+214.93
3/ 3/
67$,567$,567$,567$,567$,567$,567$,567$,567$,5 %5$))
%5$))%5$))%5$))
+27(/
5220
+27(/
5220
+27(/
5220
+27(/5(6785$17
&20081,7<
5220 &2857<$5'
67$,567$,567$,567$,567$,567$,567$,5 %5
%5%5%5%5
%5$))%5$))
67$,567$,567$,5 %53(17+286(
%5%5
7' - 6"
3' - 6"
12' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 10' - 0" 15' - 0" 15' - 0" 

3$5.,1*3$5.,1*3$5.,1*3$5.,1*
$//(< /,1'(1'5
(E) 6 STORY BUILDING
60' - 0"

SITE DEDICATION
2' - 6"

SETBACK
7"
&255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 &255 
200' - 0" .
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
6(&7,216

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



1 MECHANICAL TRELLIS2 MECHANICAL EQUIPMENT3 ELEVATOR PENTHOUSE4 STAIR PENTHOUSE5 60" HIGH MECHANICAL SCREENING, TYP 





.(<127(6
6+((77,7/(
6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$
W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
62/$5678'<

/,1'(1'5 
6/,1'(1'5
%(9(5/<+,//6&$



6AM 9AM 12 NOON 3PM 6PM 9PM
6AM 9AM 12 NOON 3PM 6PM 9PM
:,17(562/$5678'<176 6800(562/$5678'<176 
1 1. ALL FIRE RATED DOORS SHALL HAVE SMOKE GASKETS.

2. ALL ACCESSIBLE DOORS TO ROOMS SHALL BE A MINIMUM 34" WIDE WHEN FULLY OPENED.3. THE EXIT DOOR MUST OPEN OVER A LANDING NOT MORE THAN 1/2" BELOW THE THRESHOLD.4. GLASS DOORS, ADJACENT PANELS AND ALL GLAZED OPENINGS WITHIN 18" OF THE FLOOR SHALL BE TEMPERED GLASS.5. GLAZED OPENINGS WITHIN 24" OF THE DOOR LOCK WHEN DOOR IS IN THE CLOSED POSITION SHALL BE FULLY TEMPERED GLASS OR APPROVED BURGLARY-RESISTANT MATERIAL.6. EXIT DOORS SHALL BE OPENABLE FROM THE INSIDE WITHOUT THE USE OF A KEY, SPECIAL KNOWLEDGE, OR EFFORT.6. FLUSH BOLTS OR SURFACE BOLTS ARE PROHIBITED ON EXIT DOORS.8. HAND ACTIVATED DOOR OPENING HARDWARE IS TO BE BETWEEN 30 & 40 INCHES ABOVE THE FLOOR. LATCHING AND LOCKING DOORS THAT ARE HAND ACTIVATED AND IN A PATH OF TRAVEL SHALL HAVE LEVER TYPE HARDWARE, PANIC BARS, PUSHPULL ACTIVATING BARS, OR OTHER HARDWARE THAT PROVIDES PASSAGE WITHOUT GRASPING THE HARDWARE.9. EXIT DOOR HARDWARE SHALL BE AN APPROVED TYPE TESTED IN ACCORDANCE WITH THE PROCEDURES ESTABLISHED BY CALIFORNIA STATE FIRE MARSHALL STANDARDS 33.2.10. MAXIMUM EFFORT TO OPERATE DOORS MUST NOT EXCEED 8.5 POUNDS FOR EXTERIOR DOORS AND 5 POUNDS INTERIOR DOORS. THIS MAXIMUM EFFORT IS MEASURED AS THE AMOUNT OF PUSH OR PULL APPLIED AT RIGHT ANGLES TO HINGED DOORS, AND AT THE CENTER PLANE OF SLIDING OR FOLDING DOORS. COMPENSATING DEVICES OR AUTOMATIC DOOR OPENERS MAY BE USED TO MEET THESE STANDARDS. WHEN FIRE DOORS ARE REQUIRED, THE MAXIMUMEFFORT TO OPERATE THE DOORS MAY BE INCREASED UP TO 15 POUNDS.11. THE BOTTOM 10 INCHES OF ALL DOORS, EXCEPT AUTOMATIC

AND SLIDING DOORS, MUST HAVE A SMOOTH, UNINTERRUPTED
SURFACE TO ALLOW THE DOOR TO BE OPENED BY A WHEELCHAIR FOOTREST WITHOUT CATCHING ON OR TRAPPING THE FOOTREST.12. EVERY ENTRANCE OR PASSAGE DOORWAY SHALL BE OF A SIZE TO PERMIT THE INSTALLATION OF A DOOR NOT LESS THAN 3 FEET IN WIDTH. DOORS SHALL BE CAPABLE OF OPENING AT LEAST 90 DEGREES AND SHALL BE SO MOUNTED THAT THE CLEAR WIDTH OF THE DOORWAY IS NOT LESS THAN 32 INCHES. 13. PROVIDE PANIC HARDWARE FOR ALL DOORS WITH OCCUPANT LOAD 50 OR MORE.14. ALL HARDWARE SHALL BE LEVER HARDWARE MEETING DAS REQUIREMENTS.15. REFER TO SHEET A020-A032 FOR ADDITIONAL NOTES.16. DOORS OPENING INTO ONE-HOUR FIRE RESISTIVE CORRIDOR SHALL BE PROTECTED WITH A SMOKE OR DRAFT-STOP FIRE ASSEMBLY HAVING A MINIMUM 20 MINUTE RATING.

17. ALL DOORS WITH MAGNETIC HOLD DOWNS (HOM) ARE TO BE CONNECTED WITH THE SMOKE AND FIRE ALARM SYSTEMS. 7<3,&$/'225$1'6,'(/,7(127(6
ABC
EF
U Z
J K
DOOR TYPES:

D
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
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NOTE:REFER TO EXTERIOR ELEVATIONS ON SHEETS A201 & A202 FOR ACOUSTIC ZONES AND STC REQUIREMENTS. SEE 'CALCULATED

INTERIOR CNEL NOISE LEVELS' TABLE BELOW
&20021'2256&+('8/( 
  

DOOR SCHEDULE (COMMON DOORS) GROUND FLOOR
DOOR
MARK
DOOR

TYPE LOCATION

DOOR SIZE DOOR

CONSTRUCTION
DOOR
FINISH
FRAME

CONSTRUCTION
FRAME
FINISH
UL

WIDTH HEIGHT THICKNESS RATING
103 U ENTRY 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 90 MIN104 C UTILITY 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD107 B ELEV LOBBY 6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN108 A UTILITY 3' - 0" 8' - 0" 0' - 1 3/4" HCWD PTD STL PTD -109 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN110 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN111 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN112 C STAIR 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 20 MIN113 C STAIR 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 20 MIN114 C STAIR 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 20 MIN115 A UTILITY 3' - 0" 8' - 0" 0' - 1 3/4" HCWD PTD STL PTD -116 A UTILITY 3' - 0" 8' - 0" 0' - 1 3/4" HCWD PTD STL PTD -117 B ELEV LOBBY 6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN118 B COMMUNITY ROOM
6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN
119 B COMMUNITY
ROOM
6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN
120 B LOADING 6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN121 B ELEV LOBBY 6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN122 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN123 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN124 U ENTRY 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 90 MIN125 B LOBBY 6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN 5945 D GATE 3' - 0" 6' - 0" 0' - 1 3/4" STL PTD STL PTD 90 MIN

DOOR SCHEDULE (COMMON DOORS) TYPICAL HOTEL FLOOR
DOOR
MARK
DOOR

TYPE LOCATION

DOOR SIZE DOOR

CONSTRUCTION
DOOR
FINISH
FRAME

CONSTRUCTION
FRAME
FINISH
UL

WIDTH HEIGHT THICKNESS RATING
301 C STAIR 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 20 MIN302 B ELEV LOBBY 6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN303 C STAIR 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 20 MIN304 K IDF 6' - 0" 8' - 0" 0' - 1 3/4" SCWD PTD WD PTD 20 MIN305 K IDF 6' - 0" 8' - 0" 0' - 1 3/4" SCWD PTD WD PTD 20 MIN306 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN307 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN308 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN309 B ELEV LOBBY 6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN

DOOR SCHEDULE (COMMON DOORS) TYPICAL RESIDENTIAL FLOOR
DOOR
MARK
DOOR

TYPE LOCATION

DOOR SIZE DOOR

CONSTRUCTION
DOOR
FINISH
FRAME

CONSTRUCTION
FRAME
FINISH
UL

WIDTH HEIGHT THICKNESS RATING
701 C STAIR 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 20 MIN702 B ELEV LOBBY 6' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 45 MIN703 A UTILITY 3' - 0" 8' - 0" 0' - 1 3/4" HCWD PTD STL PTD -704 C STAIR 3' - 0" 8' - 0" 0' - 1 3/4" STL PTD STL PTD 20 MIN705 K IDF 6' - 0" 8' - 0" 0' - 1 3/4" SCWD PTD WD PTD 20 MIN706 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN707 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN708 - ELEVATOR 3' - 6" 8' - 0" 0' - 1" MFR FF MFR FF 90 MIN709 K IDF 6' - 0" 8' - 0" 0' - 1 3/4" SCWD PTD WD PTD 20 MIN 5884 K IDF 6' - 0" 8' - 0" 0' - 1 3/4" SCWD PTD WD PTD 20 MIN

DOOR SCHEDULE (UNIT DOORS)
UNIT
DOOR
MARK
DOOR

TYPE LOCATION

DOOR SIZE
DOOR

CONSTRUCTION
DOOR
FINISH
FRAME

CONSTRUCTION
FRAME

WIDTH HEIGHT THICKNESS FINSH UL RATING GLAZING
U01 U ENTRY 3' - 0" 8' - 0" 0' - 1 3/4" SCWD PTD WD PTD 20 MIN -U02 A 3' - 0" 7' - 0" 0' - 1 3/8" SCWD PTD WD PTD -U03 A 3' - 0" SCWD PTD WD PTD -U04 E LAUNDRY 2' - 8" 8' - 0" 0' - 1 3/8" SCWD PTD WD PTD - -U05 A BATHROOM 3' - 0" 7' - 6" 0' - 1 3/4" SCWD PTD WD PTD -U07 V CLOSET 6' - 0" 7' - 0" 0' - 0 3/4" HCWD PTD WD PTD - -U08 V CLOSET 8' - 0" 7' - 0" 0' - 0 3/4" HCWD PTD WD PTD - -U09 F LAUNDRY 7' - 0" 0' - 1 3/8" SCWD PTD WD PTD - -U10 A CLOSET 3' - 6" 7' - 6" 0' - 1 3/8" SCWD PTD WD PTD -U11 A CLOSET 3' - 0" 7' - 6" 0' - 1 3/4" SCWD PTD WD PTD -U12 W CLOSET 4' - 0" 7' - 0" 0' - 1 3/8" AL GLASS AL SILVER FF
- TEMP
U13 Z BALCONY AL FF AL FF - TEMPU14 Z BALCONY 0' - 1" AL FF AL FF - TEMP 81,7'2256&+('8/( 
  
'2257<3(6 
  
T
9'
-
0 "
3'
-
6 "
5 '
-
6 "
T
DOOR
PER
PLAN
9 '
-
0 "
3 '
-
6 "
5 '
-
6 "
S
C
H
E
DU
L
E
S
E
E
DO
O
R

SCHEDULE

SEE DOOR
T T
9'
-
0 "

SEE STRUCTURAL DRAWINGS FOR ADDITIONAL INFORMATION ON WIND AND ANY OTHER LOADING CRITERIA APPLICABLE TO WINDOWS.

SEE T-24 FOR WINDOW U-FACTOR AND SHGC.TEMPERED GLASS TO BE INSTALLED AT ALL WINDOWS, PANELS WITHIN 18" OF FINISH FLOOR AND WITHIN 24" OF DOOR JAMBS UP TO 60" H.WEATHER STRIPPING REQUIRED AT ALL WINDOWS.PER CBC 1138A.4.2 CLEAR FLOOR SPACE COMPLYING WITH SECTION 1138A.1.4 THAT ALLOWS A FORWARD OR PARALLEL APPROACH BY A PERSON USING A WHEELCHAIR SHALL BE PROVIDED AT ALL CONTROLS AND OPERATING MECHANISMS IN COMMON AREA SPACES.PER CBC 1138A.4.3 CONTROLS AND OPERATING MECHANISMS SHALL BE LOCATED NO HIGHER THAN 48 INCHES (1219mm), AND NO LOWER THAN 15 INCHES (381 mm), ABOVE THE FINISHED FLOOR MEASURED TO THE CENTER OF THE GRIP FOR WINDOWS IN COMMON AREA SPACES.PER CBC 11B-229.1 WHERE GLAZED OPENING ARE PROVIDED IN ACCESSIBLE ROOMS OR SPACES FOR OPERATION BY OCCUPANTS, AT LEAST ONE OPENING SHALL COMPLY WITH SECTION 11B-309. EACH GLAZED OPENING REQUIRED BY AN ADMINISTRATIVE AUTHORITY TO BE OPERABLE SHALL COMPLY WITH SECTION 11B-309.2406.2 IMPACT TEST. WHERE REQUIRED BY OTHER SECTIONS OF THIS CODE, GLAZING SHALL BE TESTED IN ACCORDANCE WITH CPSC 16 CFR PART 1202.

GLAZING SHALL COMPLY WITH THE TEST CRITERIA FOR CATEGORY II, UNLESS OTHERWISE INDICATED IN TABLE 2406.2(1). EXCEPTION: GLAZING NOT IN DOORS OR ENCLOSURED FOR HOT TUBS, WHIRLPOOLS, SAUNAS, STEAM ROOMS, BATHTUBS AND SHOWERS SHALL BE PERMITTED TO BE TESTED IN ACCORDANCE WITH ANSI Z97.1. GLAZING SHALL COMPLY WITH THE CRISTERIA FOR CLASS A, UNLESS OTHERWISE INDICATED IN TABLE 2406.2(2).EXTERIOR WINDOWS, WINDOW WALLS, GLAZE DOORS, AND GLAZED OPENINGS WITH EXTERIOR WALLS SHALL BE INSULTING-GLASS UNITS WITH A MINIMUM OF ONE TEMPERED PANE , OR GLASS BLOCK UNITS, OR HAVE A FIRE RESISTANCE OF NOT LESS THAN 20 MINS WHEN TESTED ACCORDING TO NFPA 275, OR COMFORM TO THE PERFORMANCE REQUIREMENTS OD SFM 12-7A-2. (PER 708A.2.1) :,1'2:127(6

1.2.3.4.5. 6.7.8.9.
6+((77,7/(6+((7180%(5,668('$7(9(1,&(%/9%/26$1*(/(6&$ W
‹&23<5,*+7277,1*(5$5&+,7(&76



30
$
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6&+('8/(6

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EXTERIOR GLASS WALL TYPES
TYPE

MARK LOCATION DESCRIPTION UL RATING GLAZING COMMENTS
S1S2S3
:,1'2:6&+('8/( 
  

EXTERIOR WINDOWS EXTERIOR WINDOWS EXTERIOR WINDOWS

FIXED GLAZING TEMP, CLEAR

TEMP, CLEARTEMP, CLEAR

FIXED GLAZING , CASEMENT OPENINGFIXED GLAZING , CASEMENT OPENING 6725()52177<3(6 
  
6 6 6
ABBREVIATIONS:AL

FFGHMGLHCWDHOMHRLGMDFMINPTD SCWDSTLTEMPVNL

ALUMINUM
FACTORY FINISHGALVANIZED STEELGLASSHOLLOW CORE WOOD DOORHOLD OPEN MAGNETHOURLIGHT-GAUGE STEEL, 20 GAMEDIUM DENSITY FIBERBOARDMINUTEPAINTEDSOLID CORE WOOD DOORSTEEL, 18 GATEMPEREDVINYL PLANTING LEGEND: TREES

SYMBOL SIZE WUCOLS COMMENTS QTY
SHRUB, VINE & GROUNDCOVER LEGEND:

SYMBOL SIZE WUCOLS COMMENTS QTY
PLATANUS ACERIFOLIA 48" BOX
"LONDON PLANE TREE"

MULTI TRUNK

BOTANICAL NAME
"COMMON NAME"

BOTANICAL NAME
"COMMON NAME"
1 GAL MED FULL CAN
9 LOMANDRA LONGIFOLIA 'BREEZE'
"DWARF MAT RUSH" 9
MED

FEIJOA SELLOWIANA
"PINEAPPLE GUAVA"
ARCTOSTAPHYLOS U. 'GREEN SUPREME'
"GREEN SUPREME MANZANITA"

JUNCUS PATENS
"CALIFORNIA GRAY RUSH" 1 GAL AT 18" O.C. LOW FULL CANOLEA EUROPAEA 'LITTLE OLLIE'"DWARF OLIVE" 15 GAL

LEYMUS CONDENSATUS 'CANYON PRINCE'
"CANYON PRINCE WILD RYE" 1 GAL AT 30" O.C.

LOW FULL CANLOW FULL CAN
15 GAL
5 70
193
1960
214

LOW FULL CAN
1 GAL AT 2' O.C. LOW FULL CAN

STABLIZED DECOMPOSED GRANITE
"DESERT GOLD"
-

SUBMIT SAMPLE

FOR APPROVAL
- 384 SF
9" CALIPER 3 PROTECT IN
PLACE
- STREET TREE TO REMAIN.

PROTECT IN PLACE.
3 24" BOX STANDARD NEW STREET TREE TO MATCH EXISTING PLATANUS ACERIFOLIA "LONDON PLANE TREE"

CANOPY TREE

STREET TREE
PLANT

FUNCTION

GROUNDCOVER

ORNAMENTAL
GRASS

GROUNDCOVER
24" BOX LOW COLUMNAR FORM 25 SCREEN HEDGE

1. ALL CLEARANCE DATA PER CITY OF BEVERLY HILLS TREE AND SHRUB PLANTING STANDARDS AND GUIDELINES.

2. RECIRCULATING WATER SYSTEMS SHALL BE USED FOR WATER FEATURES.

3. A MINIMUM 3-INCH LAYER OF MULCH SHALL BE APPLIED ON ALL EXPOSED SOIL SURFACES OF PLANTING AREAS EXCEPT TURF AREAS, CREEPING OR ROOTING GROUNDCOVERS, OR DIRECT SEEDING APPLICATIONS WHERE MULCH IS CONTRAINDICATED.

4. UNLESS CONTRADICTED BY A SOILS TEST, COMPOST AT A RATE OF A MINIMUM OF FOUR CUBIC YARDS PER 1,000 SQUARE FEET OF PERMEABLE AREA SHALL BE INCORPORATED TO A DEPTH OF SIX INCHES INTO THE SOIL.

5. I AGREE TO COMPLY WITH THE REQUIREMENTS OF THE WATER EFFICIENT LANDSCAPE ORDINANCE AND SUBMIT A COMPLETE LANDSCAPE DOCUMENTATION PACKAGE.

6. AT THE TIME OF FINAL INSPECTION, THE PERMIT APPLICANT MUST PROVIDE THE OWNER OF THE PROPERTY WITH A CERTIFICATE OF COMPLETION, CERTIFICATE OF INSTALLATION, IRRIGATION SCHEDULE AND A SCHEDULE OF LANDSCAPE AND IRRIGATION MAINTENANCE.

7. A DIAGRAM OF THE IRRIGATION PLAN SHOWING HYDROZONES SHALL BE KEPT WITH THE IRRIGATION CONTROLLER FOR SUBSEQUENT MANAGEMENT PURPOSES.

8. A CERTIFICATE OF COMPLETION SHALL BE FILLED OUT AND CERTIFIED BY EITHER THE DESIGNER OF THE LANDSCAPE PLANS, IRRIGATION PLANS, OR THE LICENSED LANDSCAPE CONTRACTOR FOR THE PROJECT.

9. AN IRRIGATION AUDIT REPORT SHALL BE COMPLETED AT THE TIME OF FINAL INSPECTION.

PLANTING NOTES
PLANT
FACTOR

0.50.2 PLANT
FACTOR
-

0.20.20.20.30.20.5 -

LAURUS NOBILIS
"BAY LAUREL"

PINUS ELDARICA
"MONDELL PINE"
MED 0.5
48" BOX LOW STANDARD 7 EVERGREEN
TREE

0.3 DIANELLA 'LIL REV'
"LIL REV DIANELLA" 1 GAL AT 12" O.C. LOW 0.2 FULL CAN 80 SHRUB

SHRUBSHRUBSHRUB

ORNAMENTAL
GRASS
PLANT

FUNCTION

STREET TREE
WESTRINGIA F. 'MORNING LIGHT'
"MORNING LIGHT COASTAL ROSEMARY" 5 GAL LOW 0.3 FULL CAN 26 SHRUB

ACACIA COGNATA 'COUSIN ITT'
"COUSIN ITT WATTLE" 5 GAL LOW 0.3 FULL CAN 3 SHRUB

TREE CALCULATIONS
TOTAL EXISTING STREET TREES = 3 TREESTOTAL PROPOSED STREET TREES = 3 TREESTOTAL PROPOSED TREES = 41 TREES TOTAL PROPOSED TREES = 44 TREES

FINE GRADING NOTES
GROUND FLOOR PLANTING AREA = 5,739.0 SF
18TH FLOOR PLANTING AREA = 440.0 SF
19TH FLOOR PLANTING AREA = 305.0 SF
TOTAL PLANTING AREA = 6,484.0 SF
TOTAL SITE AREA = 21,679.0 SFTOTAL BUILDING SF = 12,390.0 SFTOTAL PLANTING AREA = 6,484.0 SFTOTAL HARDSCAPE AREA = 3,550.0 SFTOTAL HARDSCAPE EXCEEDING .30 SRI = 100%TOTAL PERMEABLE HARDSCAPE % = 0%

SITE AREA CALCULATIONS

PLANTING AREA CALCULATIONS
SHEET INDEX:

SHEET SHEET TITLE
L1.00 LEGEND AND NOTESL1.10 GROUND FLOOR CONCEPTUAL LANDSCAPE PLANL1.11 18TH FLOOR CONCEPTUAL LANDSCAPE PLANL1.12 19TH FLOOR CONCEPTUAL LANDSCAPE PLANL1.13 GROUND FLOOR PLANTING PLANL1.14 18TH FLOOR PLANTING PLANL1.15 19TH FLOOR PLANTING PLAN TREE PROTECTION NOTES: CONSTRUCTION NOTES:
125 Linden Drive
125-129 S. Linden Drive
Beverly Hills, CA 90212
Sheet title:

Issue dates
# Date Description
NV
2303
Designed by:

Drawn by:Checked by:Project number:

NVNV
1 7/19/23 Entitlement Submittal
L1.00

LEGEND AND NOTES
0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
NOTE:

1. SEE SHEET L1.00 FOR LEGEND AND NOTES.
125 Linden Drive
125-129 S. Linden Drive
Beverly Hills, CA 90212
Sheet title:

Issue dates
# Date Description
NV
2303
Designed by:Drawn by:

Checked by:Project number:

NVNV
1 7/19/23 Entitlement Submittal
L1.10

GROUND FLOOR

CONCEPTUAL

LANDSCAPE PLAN

PROPERTY LINEPROPERTY LINE

PROPERTY LINE

PROPERTY LINE

LINDEN DRIVE
ALLEY
ALLEY

SEISMIC FAULT LINE

1. NATURAL CONCRETE SIDEWALK WITH LIGHT BROOM
FINISH PER CITY STANDARDS.

2. INTEGRAL COLOR CONCRETE PAVING WITH TOPCAST
FINISH.

3. CONCRETE UNIT PAVER.

4. 18" HIGH CONCRETE SEAT WALL WITH TOPCAST FINISH.

5. METAL SECURITY GATE AND FENCE. COLOR: BLACK.

ARCHITECTURAL REFERENCES:

21. BUILDING OVERHANG.

OTHER REFERENCES:

31. EXISTING TREE TO REMAIN. PROTECT IN PLACE.32. CURB TO REMAIN. PROTECT IN PLACE.

KEYNOTES:

TYP.

P.A.

P.A.

P.A.

P.A.

P.A.

P.A.

P.A.

P.A.

P.A. P.A.

P.A.

P.A.

P.A.

P.A.

P.A.

P.A.

DECORATIVE PAVING

TREE CANOPY

MEANDERING LANDSCAPE

LANDSCAPE MOUNDS

CONCEPT DESIGN IMAGERY

DECORATIVE PAVING CONCRETE PAVING
COLOR: NATURALFINISH: LIGHT BROOM PER CITY STANDARDSINTEGRAL CONCRETE PAVINGCOLOR: DUNEFINISH: TOPCAST #3CONCRETE UNIT PAVERCOLOR: DUNE 0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
NOTE:

1. SEE SHEET L1.00 FOR CONSTRUCTION LEGEND
AND NOTES.
125 Linden Drive
125-129 S. Linden Drive
Beverly Hills, CA 90212
Sheet title:

Issue dates
# Date Description
NV
2303
Designed by:Drawn by:

Checked by:Project number:

NVNV
1 7/19/23 Entitlement Submittal
L1.11
18TH FLOOR

CONCEPTUAL

LANDSCAPE PLAN

1. PORCELAIN TILE PAVING OVER PEDESTAL SYSTEM.

2. 42" HIGH STEEL PLANTER WALL. COLOR: BLACK.

3. NATURAL GAS PREFABRICATED FIRE PIT.

4. COOK CENTER WITH CANTILEVERED COUNTERTOP
AND BAR STOOLS.

5. POTTED PLANTERS.

6. OUTDOOR T.V.

7. DINING TABLE.

8. SITE FURNISHING.

ARCHITECTURAL REFERENCES:

11. PARAPET WALL.

KEYNOTES:

TYP.

P.A. P.A.

P.A.

P.A.

P.A.

SITE FURNISHINGFIREPIT BAR STOOL COUNTER

COOK CENTER

PORCELAIN STONE TILE FIRE LOUNGESTEEL PLANTER WITH TILE PAVING

CONCEPT DESIGN IMAGERY
0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
NOTE:

1. SEE SHEET L1.00 FOR CONSTRUCTION LEGEND
AND NOTES.
125 Linden Drive
125-129 S. Linden Drive
Beverly Hills, CA 90212
Sheet title:

Issue dates
# Date Description
NV
2303
Designed by:Drawn by:

Checked by:Project number:

NVNV
1 7/19/23 Entitlement Submittal
L1.12
19TH FLOOR

CONCEPTUAL

LANDSCAPE PLAN

1. PORCELAIN TILE PAVING OVER PEDESTAL SYSTEM.

2. 42" HIGH STEEL PLANTER WALL. COLOR: BLACK.

3. NATURAL GAS FIREPLACE.

4. COOK CENTER.

5. CANTILEVERED COUNTERTOP WITH BAR STOOLS.

6. COOK CENTER.

7. POTTED PLANTERS.

8. OUTDOOR T.V.9. DINING TABLE.

10. SITE FURNISHING.11. GREENSCREEN.

ARCHITECTURAL REFERENCES:

20. PARAPET WALL.

KEYNOTES:

P.A.

P.A.

PORCELAIN STONE TILE

FURNISHING LAYOUT WITH POTS AND TILE PAVINGFIREPLACE GREENWALL

STEEL PLANTER

COOK CENTER WITH BAR STOOL COUNTERTOP

CONCEPT DESIGN IMAGERY
PLANTING LEGEND: TREES

SYMBOL SIZE WUCOLS
SHRUB, VINE & GROUNDCOVER LEGEND:

SYMBOL SIZE WUCOLS
PLATANUS ACERIFOLIA 48" BOX
"LONDON PLANE TREE"

BOTANICAL NAME
"COMMON NAME"

BOTANICAL NAME
"COMMON NAME"
1 GAL MED LOMANDRA LONGIFOLIA 'BREEZE' "DWARF MAT RUSH" MED

FEIJOA SELLOWIANA
"PINEAPPLE GUAVA"
ARCTOSTAPHYLOS U. 'GREEN SUPREME'
"GREEN SUPREME MANZANITA"

JUNCUS PATENS
"CALIFORNIA GRAY RUSH" 1 GAL AT 18" O.C. LOW

OLEA EUROPAEA 'LITTLE OLLIE'
"DWARF OLIVE" 15 GAL

LEYMUS CONDENSATUS 'CANYON PRINCE'
"CANYON PRINCE WILD RYE" 1 GAL AT 30" O.C.

LOWLOW
15 GAL
LOW
1 GAL AT 2' O.C. LOW
STABLIZED DECOMPOSED GRANITE"DESERT GOLD" - -
9" CALIPER - STREET TREE TO REMAIN.

PROTECT IN PLACE.
24" BOX

NEW STREET TREE TO MATCH EXISTINGPLATANUS ACERIFOLIA
"LONDON PLANE TREE"
LAURUS NOBILIS 24" BOX LOW
"BAY LAUREL"

PINUS ELDARICA
"MONDELL PINE"
MED
48" BOX LOW

DIANELLA 'LIL REV'
"LIL REV DIANELLA" 1 GAL AT 12" O.C. LOW
WESTRINGIA F. 'MORNING LIGHT'
"MORNING LIGHT COASTAL ROSEMARY" 5 GAL LOW

ACACIA COGNATA 'COUSIN ITT'
"COUSIN ITT WATTLE" 5 GAL LOW
0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
NOTE:

1. SEE SHEET L1.00 FOR LEGEND AND NOTES.
125 Linden Drive
125-129 S. Linden Drive
Beverly Hills, CA 90212
Sheet title:

Issue dates
# Date Description
NV
2303
Designed by:Drawn by:

Checked by:Project number:

NVNV
1 7/19/23 Entitlement Submittal
L1.13

GROUND FLOOR

PLANTING PLAN

PROPERTY LINEPROPERTY LINE

PROPERTY LINE

PROPERTY LINE

LINDEN DRIVE
ALLEY
ALLEY

SEISMIC FAULT LINE
PINUS ELDARICA“MONDELL PINE”

LAURUS NOBILIS HEDGE
WESTRINGIA ‘MORNING LIGHT’“COASTAL ROSEMARY”
ARCTOSTAPHYLOS ‘GREEN SUPREME’“GREEN SUPREME MANZANITA” JUNCUS PATENS“CAPE RUSH”
LEYMUS CONDENSATUS ‘CANYON PRINCE’“CANYON PRINCE WILD RYE” PLATANUS X ACERIFOLIA“LONDON PLANE TREE”

CONCEPT DESIGN IMAGERY
PLANTING LEGEND: TREES

SYMBOL SIZE WUCOLS
SHRUB, VINE & GROUNDCOVER LEGEND:

SYMBOL SIZE WUCOLS
PLATANUS ACERIFOLIA 48" BOX
"LONDON PLANE TREE"

BOTANICAL NAME
"COMMON NAME"

BOTANICAL NAME
"COMMON NAME"
1 GAL MED LOMANDRA LONGIFOLIA 'BREEZE' "DWARF MAT RUSH" MED

FEIJOA SELLOWIANA
"PINEAPPLE GUAVA"
ARCTOSTAPHYLOS U. 'GREEN SUPREME'
"GREEN SUPREME MANZANITA"

JUNCUS PATENS
"CALIFORNIA GRAY RUSH" 1 GAL AT 18" O.C. LOW

OLEA EUROPAEA 'LITTLE OLLIE'
"DWARF OLIVE" 15 GAL

LEYMUS CONDENSATUS 'CANYON PRINCE'
"CANYON PRINCE WILD RYE" 1 GAL AT 30" O.C.

LOWLOW
15 GAL
LOW
1 GAL AT 2' O.C. LOW
STABLIZED DECOMPOSED GRANITE"DESERT GOLD" - -
9" CALIPER - STREET TREE TO REMAIN.

PROTECT IN PLACE.
24" BOX

NEW STREET TREE TO MATCH EXISTINGPLATANUS ACERIFOLIA
"LONDON PLANE TREE"
LAURUS NOBILIS 24" BOX LOW
"BAY LAUREL"

PINUS ELDARICA
"MONDELL PINE"
MED
48" BOX LOW

DIANELLA 'LIL REV'
"LIL REV DIANELLA" 1 GAL AT 12" O.C. LOW
WESTRINGIA F. 'MORNING LIGHT'
"MORNING LIGHT COASTAL ROSEMARY" 5 GAL LOW

ACACIA COGNATA 'COUSIN ITT'
"COUSIN ITT WATTLE" 5 GAL LOW
0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
NOTE:

1. SEE SHEET L1.00 FOR LEGEND AND NOTES.
125 Linden Drive
125-129 S. Linden Drive
Beverly Hills, CA 90212
Sheet title:

Issue dates
# Date Description
NV
2303
Designed by:Drawn by:

Checked by:Project number:

NVNV
1 7/19/23 Entitlement Submittal
L1.14
18TH FLOOR

PLANTING PLAN
LOMANDRA ‘BREEZE’“DWARF MAT RUSH”
ACACIA ‘COUSIN ITT’“COUSIN ITT WATTLE”
DIANELLA R. ‘LIL REV’“LIL REV FLAX LILLY”
OLEA EUROPAEA ‘LITTLE OLLIE’“DWARF OLIVE”
WESTRINGIA ‘MORNING LIGHT’“COASTAL ROSEMARY”CONCEPT DESIGN IMAGERY PLANTING LEGEND: TREES

SYMBOL SIZE WUCOLS
SHRUB, VINE & GROUNDCOVER LEGEND:

SYMBOL SIZE WUCOLS
PLATANUS ACERIFOLIA 48" BOX
"LONDON PLANE TREE"

BOTANICAL NAME
"COMMON NAME"

BOTANICAL NAME
"COMMON NAME"
1 GAL MED LOMANDRA LONGIFOLIA 'BREEZE' "DWARF MAT RUSH" MED

FEIJOA SELLOWIANA
"PINEAPPLE GUAVA"
ARCTOSTAPHYLOS U. 'GREEN SUPREME'
"GREEN SUPREME MANZANITA"

JUNCUS PATENS
"CALIFORNIA GRAY RUSH" 1 GAL AT 18" O.C. LOW
OLEA EUROPAEA 'LITTLE OLLIE'"DWARF OLIVE" 15 GAL

LEYMUS CONDENSATUS 'CANYON PRINCE'
"CANYON PRINCE WILD RYE" 1 GAL AT 30" O.C.

LOWLOW
15 GAL
LOW
1 GAL AT 2' O.C. LOW
STABLIZED DECOMPOSED GRANITE"DESERT GOLD" - -
9" CALIPER - STREET TREE TO REMAIN.

PROTECT IN PLACE.
24" BOX

NEW STREET TREE TO MATCH EXISTINGPLATANUS ACERIFOLIA
"LONDON PLANE TREE"
LAURUS NOBILIS 24" BOX LOW
"BAY LAUREL"

PINUS ELDARICA
"MONDELL PINE"
MED
48" BOX LOW

DIANELLA 'LIL REV'
"LIL REV DIANELLA" 1 GAL AT 12" O.C. LOW
WESTRINGIA F. 'MORNING LIGHT'
"MORNING LIGHT COASTAL ROSEMARY" 5 GAL LOW

ACACIA COGNATA 'COUSIN ITT'
"COUSIN ITT WATTLE" 5 GAL LOW
0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
NOTE:

1. SEE SHEET L1.00 FOR LEGEND AND NOTES.
125 Linden Drive
125-129 S. Linden Drive
Beverly Hills, CA 90212
Sheet title:

Issue dates
# Date Description
NV
2303
Designed by:Drawn by:

Checked by:Project number:

NVNV
1 7/19/23 Entitlement Submittal
L1.15
19TH FLOOR

PLANTING PLAN
LOMANDRA ‘BREEZE’“DWARF MAT RUSH”
ACACIA ‘COUSIN ITT’“COUSIN ITT WATTLE”
DIANELLA R. ‘LIL REV’“LIL REV FLAX LILLY”
WESTRINGIA ‘MORNING LIGHT’“COASTAL ROSEMARY”CONCEPT DESIGN IMAGERYJUNCUS PATENS“CAPE RUSH” NOTICE

PLEASE BE ADVISED THAT THE DATA AND

INFORMATION FROM THE PUBLIC RECORDS

CONTAINED HEREIN WILL NEED TO BE

UPDATED PRIOR TO CLOSING AS MANY

COUNTY FACILITIES ARE CLOSED OR HAVE

LIMITED STAFFING AS A RESULT OF THE
CORONAVIRUS PANDEMIC. IF THE

INFORMATION FROM THE COUNTY IS NOT

AVAILABLE THERE WILL BE ADDITIONAL

REQUIREMENTS IN ORDER TO CLOSE AND
INSURE THIS TRANSACTION. PLEASE CONTACT
YOUR LOCAL TITLE OFFICER FOR DETAILS.

Order No. 140-2370903-20

@ExtractStart@ Orange Coast Title Company
2151 E. Convention Center Way, Suite 102
Ontario, CA 91764
909-987-5433

PRELIMINARY REPORT
Orange Coast Title Company
2151 E. Convention Center Way, Suite 102
Ontario, CA 91764
Attention: Tom Krystkowiak Your no.: 2370903-TK
Property address: 129 South Linden Drive, Beverly Hills, CA 90212 Order no.: 140-2370903-20 Dated: June 8, 2023
In response to the above referenced application for a policy of title insurance, Orange Coast Title Company hereby reports that it is prepared to issue, or cause to be issued, as of the date hereof, a Policy or Policies of Title Insurance describing the land and the estate or interest therein hereinafter set forth, insuring against loss which may be sustained by reason of any defect, lien or encumbrance not shown or referred to as an Exception below or not excluded from coverage pursuant to the printed Schedules, Conditions and Stipulations of said Policy forms.

The printed Exceptions and Exclusions from the coverage and Limitations on Covered Risks of said policy or policies are set forth in Exhibit B attached. The policy to be issued may contain an arbitration clause. When the Amount of Insurance is less than that set forth in the arbitration clause, all arbitrable matters shall be arbitrated at the option of either the Company or the Insured as the exclusive remedy of the parties. Limitations on Covered Risks applicable to the CLTA and ALTA Homeowner’s Policies of Title Insurance which establish a Deductible Amount and a Maximum Dollar Limit of Liability for certain coverages are also set forth in Exhibit B.

Copies of the policy forms should be read. They are available from the office which issued this report.

Please read the exceptions shown or referred to below and the exceptions and exclusions set forth in Exhibit B of this report carefully. The exceptions and exclusions are meant to provide you with notice of matters, which are not covered under the terms of the title insurance policy and should be carefully considered.

It is important to note that this preliminary report is not a written representation as the condition of title and may not list all liens, defects, and encumbrances affecting title to the land.

This report (and any supplements or amendments hereto) is issued solely for the purpose of facilitating the issuance of a policy of title insurance and no liability is assumed hereby. If it is desired that liability be assumed prior to the issuance of a policy of title insurance, a Binder or Commitment should be requested.

Dated as of May 19, 2023 at 7:30 AM
_____________________________________________________
Ranny Harper, Title Officer
Email: [email protected]
Ph: 909-987-5433
Fax: 714-415-7961
Order No. 140-2370903-20

The form of policy of title insurance contemplated by this report is:

A.L.T.A. Loan Policy (06-17-06)
Schedule “A”
The estate or interest in the land hereinafter described or referred to covered by this report is:

A Fee
Title to said estate or interest at the date hereof is vested in:

Ely Dromy and Judy Dromy, Trustees of the Dromy 1995 Family Trust dated December 12, 1995, an undivided 28 percent interest, 9300 Wilshire LLC, a Delaware Limited Liability Company, an undivided 10.55 percent interest, 9300 Wilshire Fee, LLC, a Delaware Limited Liability Company, an undivided 43.95 percent interest, 1112 Investment Company, LLC, a California Limited Liability Company, an undivided 5.00 percent interest, and E.D. Flores, LLC, a California Limited Liability Company, an undivided

2.5 percent interest and EJT Wilshire Linden, LLC, a California Limited Liability Company, an undivided 10% interest.

The land referred to in this report is situated in the City of Beverly Hills, the County of Los Angeles, State of California, and is described as follows:

Lot 40 of Tract No. 6648, in the City of Beverly Hills, County of Los Angeles, State of California, as per Map recorded in Book 71,

Assessor's Parcel Numbers(s): 4328-009-007
Order No. 140-2370903-20

Schedule “B”
At the date hereof exceptions to coverage in addition to the printed exceptions and exclusions contained in said policy form would be as follows:
1 General and Special taxes for the fiscal year 2023-2024, including any assessments collected with taxes. A lien not yet payable.

First installment due and payable 11/01/2023, delinquent if not paid by 12/10/2023 Second installment due and payable 02/01/2024, delinquent if not paid by 04/10/2024 2 General and Special taxes for the fiscal year 2022-2023, including any assessments collected with current taxes.

Total amount $73,848.70
1st installment $36,924.35, Paid
Penalty $3,692.43 (after 12/12/2022)
2nd installment $36,924.35, Paid
Penalty $3,702.43 (after 04/10/2023)
Code area 02410 - City of Beverly Hills-10
Parcel No. 4328-009-007
Exemption $None Shown
NOTE: Taxes above mentioned have all been paid and are reported for proration purposes only. 3 Supplemental taxes including special assessments and/or personal property taxes if any, for the fiscal year 2020-2021. 1st installment: $49.85 paid
2nd installment: $49.84 paid
Bill No.: None Shown
Supplemental No.: 4328-009-007
4 Supplemental taxes including special assessments and/or personal property taxes if any, for the fiscal year 2021-2022. 1st installment: $81.79 paid
2nd installment: $81.79 paid
Bill No.: None Shown
Supplemental No.: 4328-009-007
5 The Lien of future supplemental taxes, if any, assessed pursuant to the provisions of section 75, et seq of the revenue and taxation code of the State of California
6 An Oil and Gas Lease affecting this and other property executed by the owner of said land and by others as owners of other land, for the term and upon the terms, covenants and provisions therein provided Recorded: 02/10/1965, as Instrument No. 4151, Official Records.

Dated: 01/05/1965
Term: 20 years from date hereof and any other term as provided for therein Lessor: 9740 Wilshire Building, a Limited Partnership
Lessee: Occidental Petroleum Corporation, a Corporation The present ownership of said leasehold and other matters affecting the interest of the lessee are not shown herein.

Said lease affects that portion of said land lying below a depth of 500 feet from the surface thereof without right of surface entry.

Order No. 140-2370903-20

7 A Deed of Trust to secure the indebtedness of
Amount: $18,500,000.00
Trustor: Ely Dromy and Judy Dromy, Trustees of the Dromy 1995 Family Trust dated December 12, 1995, an undivided 28 percent interest, 9300 Wilshire LLC, a Delaware Limited Liability Company, an undivided 10.55 percent interest, 9300 Wilshire Fee, LLC, a Delaware Limited Liability Company, an undivided 43.95 percent interest, 1112 Investment Company, LLC, a California Limited Liability Company, an undivided

15.00 percent interest, and E.D. Flores, LLC, a California Limited Liability Company, an undivided 2.5 percent interest
Trustee: East West Investment Inc., a California Corporation Beneficiary: East West Bank
Dated: 08/08/2019
Recorded: 10/28/2019 as Instrument No. 2019-1155141 of Official Records Said Deed of Trust contains a provision that the NOTE secured thereby provides for a variable interest rate and allows periodic adjustments in the rate of interest.

Said matter affects the herein described land and other land. 8 An instrument, upon the terms and conditions contained therein Entitled: Memorandum of Tenancy-In-Common Agreement
Dated: 12/28/2020
Executed by and between: EJT Wilshire Linden, LLC, a California Limited Liability Company, 1112 Investment Company, LLC, a California Limited Liability Company, 9300 Wilshire, LLC, a Delaware Limited Liability Company, 9300 Wilshire Fee, LLC, a Delaware Limited Liability Company, E.D. Flores, LLC, a California Limited Liability Company, and Dromy 1995 Family Trust Dated December 12, 1995
Recorded: 02/03/2021, as Instrument No. 2021-189209 of Official Records 9 A lien for unsecured property taxes in favor of the tax collector, County of Los Angeles
Amount: $3,046.54
Taxpayer: E D Flores LLC
Year/account no.: 22/49952581
Recorded: 01/10/2023as Instrument No. 2023-15964 , Official Records 10 The requirement that we be furnished a copy of the Dromy 1995 Family Trust and any amendments thereto. A certification of said trust "may be" acceptable if made pursuant to probate code section 18100.5 and qualified as a trust under section 82 of probate code.
11 This company will require a copy of the Certificate of Registration to transact business in the State of California for 9300 Wilshire LLC, a Delaware limited liability company, a copy of the articles of organization certified by authorities of the state of origin, and copies of any management agreements or operating agreements together with a current list of all members of said limited liability company.
12 This company will require a copy of the Certificate of Registration to transact business in the State of California for 9300 Wilshire Fee, LLC, a Delaware limited liability company, a copy of the articles of organization certified by authorities of the state of origin, and copies of any management agreements or operating agreements together with a current list of all members of said limited liability company.
13 The requirement that we be provided:
(1) A copy of the filed articles of organization of 1112 Investment Company, LLC, a limited liability company. (2) A current list of the names of said limited liability company members. (3) A copy of said limited liability company's operating agreement, with a verified certificate that the operating agreement is a true and correct copy of the agreement now in effect.

Order No. 140-2370903-20

14 The requirement that we be provided:
(1) A copy of the filed articles of organization of E.D. Flores, LLC, a limited liability company. (2) A current list of the names of said limited liability company members. (3) A copy of said limited liability company's operating agreement, with a verified certificate that the operating agreement is a true and correct copy of the agreement now in effect. 15 The requirement that we be provided:
(1) A copy of the filed articles of organization of EJT Wilshire Linden, LLC, a limited liability company. (2) A current list of the names of said limited liability company members. (3) A copy of said limited liability company's operating agreement, with a verified certificate that the operating agreement is a true and correct copy of the agreement now in effect. 16 Rights of parties in possession of said land by reason of unrecorded leases, if any. Please forward said leases for our examination.
17 Any facts, rights, interest or claims which may be shown by an inspection of the land or which may be disclosed by inquiry of persons in possession of said land.
18 (A) Taxes or assessments which are not shown as existing liens by the records of any taxing authority that levies taxes or assessments on real property or by the public records;
Proceedings by a public agency which may result in taxes or assessments, or notices of such proceedings, whether or not shown by the records of such agency or by the Public Records. (B) Any facts, rights, interests, or claims which are not shown by the public records but which could be ascertained by an inspection of the land or which may be asserted by persons in possession thereof. (C) Easements, liens or encumbrances, or claims thereof, which are not shown by the public records. (D) Discrepancies, conflicts in boundary lines, shortage in area, encroachments, or any other facts which a correct survey would disclose, and which are not shown by the public records (E) (a) Unpatented mining claims; (b) reservations or exceptions in patents or in Acts authorizing the issuance thereof; (c) water rights, claims or title to water, whether or not the matters excepted under (a), (b), or (c) are shown by the public records
(F) Any lien or right to a lien for services, labor or material theretofore or hereafter not shown by the public records.

Exceptions A-F will be omitted on extended coverage policies.

End of Schedule B
Order No. 140-2370903-20

“NOTES AND REQUIREMENTS SECTION”
NOTE NO. 1
California Revenue and Taxation Code Section 18662, effective January 1, 1994 and by amendment effective January 1, 2003, provides that the buyer in all sales of California Real Estate may be required to withhold 3 and 1/3% of the total sales price as California State Income Tax, subject to the various provisions of the law as therein contained.

NOTE NO. 2 PAYOFF INFORMATION:

Note: this company does require current beneficiary demands prior to closing.

If the demand is expired and a correct demand cannot be obtained, our requirements will be as follows:

A. If this company accepts a verbal update on the demand, we may hold an amount equal to one monthly mortgage payment.

The amount of this hold will be over and above the verbal hold the lender may have stipulated.

B. If this company cannot obtain a verbal update on the demand, will either pay off the expired demand or wait for the amended demand, at the discretion of the escrow.

C. In the event that a payoff is being made to a servicing agent for the beneficiary, this company will require a complete copy of the servicing agreement prior to close.

NOTE NO. 3
If this company is requested to disburse funds in connection with this transaction, chapter 598, statutes of 1989 mandates hold periods for checks deposited to escrow or sub-escrow accounts. The mandatory hold is one business day after the day deposited. Other checks require a hold period from three to seven business days after the day deposited.

Notice Regarding Your Deposit of Funds
California Insurance Code Sections 12413 et. Seq. Regulates the disbursement of escrow and sub-escrow funds by title companies.

The law requires that funds be deposited in the title company escrow and sub-escrow accounts and be available for withdrawal prior to disbursement. Funds deposited with the Company by wire transfer may be disbursed upon receipt. Funds deposited with the Company via cashier’s checks drawn on a California based bank may be disbursed the next business day after the day of deposit. If funds are deposited with by other methods, recording or disbursement may be delayed. All escrow and sub-escrow funds received by the Company will be deposited with other funds in one or more non-interest bearing escrow accounts of the Company in a financial institution selected by the Company. The Company and/or its parent company may receive certain direct or indirect benefits from the financial institution by reason of the deposit of such funds or the maintenance of such accounts with the financial institution, and the Company shall have no obligation to account to the depositing party in any manner for the value of, or to pay such party, any benefit received by the Company and/or its parent Company. Those benefits may include, without limitation, credits allowed by such financial institution on loans to the Company and/or its parent company and earnings on investments made on the proceeds of such loans, accounting, reporting and other services and products of such financial institution. Such benefits shall be deemed additional compensation of the Company for its services in connection with the escrow or sub-escrow.

Order No. 140-2370903-20

Orange Coast Title Company
2151 E. Convention Center Way, Suite 102
Ontario, CA 91764
909-987-5433
Attention:

Borrower: Dromy\TTEE ETAL
Lenders supplemental report
The above numbered report (including any supplements or amendments thereto) is hereby modified and/or supplemented in order to reflect the following additional items relating to the issuance of an A.L.T.A. Loan Policy (06-17-06) form as follows:

A. This report is preparatory to this issuance of an American Land Title Association loan policy of title insurance. This report discloses nothing, which would preclude the issuance of said American land title association loan policy of title insurance with endorsement no. 100 attached thereto.

B. The improvements on said land are designated as:

A commercial property known as
129 South Linden Drive, in the City of Beverly Hills, County of Los Angeles, State of California.

C. The only conveyance(s) affecting said land recorded within 24 months of the date of this report are as follows:

Grantor: 1112 Investment Company, LLC, a California Limited Liability Company Grantee: EJT Wilshire Linden, LLC, a California Limited Liability Company, an undivided 10% interest
Recorded: 1/26/2021 as Instrument No. 2021-138527, Official Records.

Order No. 140-2370903-20

Attention
Please note that this preliminary report now has an extra copy of the legal description on a separate sheet of paper. There are no markings on the page. The idea is to provide you with a legal description that can be attached to other documents as needed. That legal description page immediately follows this page.

Thank you for your support of Orange Coast Title Company. We hope that this makes your job a little easier.

Order No. 140-2370903-20

Exhibit “A”
Lot 40 of Tract No. 6648, in the City of Beverly Hills, County of Los Angeles, State of California, as per Map recorded in Book 71,

Order No. 140-2370903-20

CLTA Preliminary Report Form – Exhibit B (06-03-11)
CLTA STANDARD COVERAGE POLICY – 1990

EXCLUSIONS FROM COVERAGE
The following matters are expressly excluded from the coverage of this policy and the Company will not pay loss or damage, costs, attorneys' fees or expenses which arise by reason of:

1. (a) Any law, ordinance or governmental regulation (including but not limited to building or zoning laws, ordinances, or regulations) restricting, regulating, prohibiting or relating (i) the occupancy, use, or enjoyment of the land; (ii) the character, dimensions or location of any improvement now or hereafter erected on the land; (iii) a separation in ownership or a change in the dimensions or area of the land or any parcel of which the land is or was a part; or (iv) environmental protection, or the effect of any violation of these laws, ordinances or governmental regulations, except to the extent that a notice of the enforcement thereof or a notice of a defect, lien, or encumbrance resulting from a violation or alleged violation affecting the land has been recorded in the public records at Date of Policy. (b) Any governmental police power not excluded by (a) above, except to the extent that a notice of the exercise thereof or notice of a defect, lien or encumbrance resulting from a violation or alleged violation affecting the land has been recorded in the public records at Date of Policy.

2. Rights of eminent domain unless notice of the exercise thereof has been recorded in the public records at Date of Policy, but not excluding from coverage any taking which has occurred prior to Date of Policy which would be binding on the rights of a purchaser for value without knowledge.

3. Defects, liens, encumbrances, adverse claims or other matters: (a) whether or not recorded in the public records at Date of Policy, but created, suffered, assumed or agreed to by the insured claimant; (b) not known to the Company, not recorded in the public records at Date of Policy, but known to the insured claimant and not disclosed in writing to the Company by the insured claimant prior to the date the insured claimant became an insured under this policy; (c) resulting in no loss or damage to the insured claimant; (d) attaching or created subsequent to Date of Policy; or (e) resulting in loss or damage which would not have been sustained if the insured claimant had paid value for the insured mortgage or for the estate or interest insured by this policy.

4. Unenforceability of the lien of the insured mortgage because of the inability or failure of the insured at Date of Policy, or the inability or failure of any subsequent owner of the indebtedness, to comply with the applicable doing business laws of the state in which the land is situated.

5. Invalidity or unenforceability of the lien of the insured mortgage, or claim thereof, which arises out of the transaction evidenced by the insured mortgage and is based upon usury or any consumer credit protection or truth in lending law.

6. Any claim, which arises out of the transaction vesting in the insured the estate of interest insured by this policy or the transaction creating the interest of the insured lender, by reason of the operation of federal bankruptcy, state insolvency or similar creditors' rights laws.

EXCEPTIONS FROM COVERAGE - SCHEDULE B, PART I
This policy does not insure against loss or damage (and the Company will not pay costs, attorneys' fees or expenses) which arise by reason of:

1. Taxes or assessments which are not shown as existing liens by the records of any taxing authority that levies taxes or assessments on real property or by the public records. Proceedings by a public agency which may result in taxes or assessments, or notices of such proceedings, whether or not shown by the records of such agency or by the public records.

2. Any facts, rights, interests, or claims which are not shown by the public records but which could be ascertained by an inspection of the land or which may be asserted by persons in possession thereof.

3. Easements, liens or encumbrances, or claims thereof, which are not shown by the public records.

4. Discrepancies, conflicts in boundary lines, shortage in area, encroachments, or any other facts which a correct survey would disclose, and which are not shown by the public records.

5. (a) Unpatented mining claims; (b) reservations or exceptions in patents or in Acts authorizing the issuance thereof; (c) water rights, claims or title to water, whether or not the matters excepted under (a), (b) or (c) are shown by the public records.

6. Any lien or right to a lien for services, labor or material not shown by the public records.

CLTA/ALTA HOMEOWNER'S POLICY OF TITLE INSURANCE (02/03/10)

EXCLUSIONS
In addition to the Exceptions in Schedule B, You are not insured against loss, costs, attorneys' fees, and expenses resulting from:

1. Governmental police power, and the existence or violation of those portions of any law or government regulation concerning: a.building, b. zoning, c.land use d. improvements on the Land, e.land division; and ,f. environmental protection. This Exclusion does not limit the coverage described in Covered Risk 8.a., 14, 15, 16, 18, 19, 20, 23 or 27.

2. The failure of Your existing structures, or any part of them, to be constructed in accordance with applicable building codes. This Exclusion does not limit the coverage described in Covered Risk 14 or 15.

3. The right to take the Land by condemning it. This Exclusion does not limit the coverage described in Covered Risk 17.

4. Risks: a. that are created, allowed, or agreed to by You, whether or not they recorded in the Public Records; b. that are Known to You at the Policy Date, but not to Us, unless they are recorded in the Public Records at the Policy Date; c. that result in no loss to You; or d. that first occur after the Policy Date - this does not limit the coverage described in Covered Risk 7, 8.e, 25, 26, 27, or 28.

5. Failure to pay value for Your Title.

6. Lack of a right: a. to any land outside the area specifically described and referred to in paragraph 3 of Schedule A; and b. in streets, alleys, or waterways that touch the Land. This Exclusion does not limit the coverage described in Covered Risk 11 or 21.

7. The transfer of the Title to You is invalid as a preferential transfer or as a fraudulent transfer or conveyance under federal bankruptcy, state insolvency, or similar creditors’ rights laws.

LIMITATIONS ON COVERED RISKS
Your insurance for the following Covered Risks is limited on the Owner’s Coverage Statement as follows:
• For Covered Risk 16, 18, 19, and 21 Your Deductible Amount and Our Maximum Dollar Limit of Liability shown in Schedule A.

The deductible amounts and maximum dollar limits shown on Schedule A are as follows:

Your Deductible Amount Our Maximum Dollar Limit of Liability Covered Risk 16: 1 % of Policy Amount shown in Schedule A or $ 2,500 (whichever is less) $ 10,000 Covered Risk 18: 1 % of Policy Amount shown in Schedule A or $ 5,000 (whichever is less) $ 25,000 Covered Risk 19: 1 % of Policy Amount shown in Schedule A or $ 5,000 (whichever is less) $ 25,000 Covered Risk 21: 1 % of Policy Amount shown in Schedule A or $ 2,500 (whichever is less) $ 5,000 ALTA RESIDENTIAL TITLE INSURANCE POLICY (6-1-87)

EXCLUSIONS
In addition to the Exceptions in Schedule B, you are not insured against loss, costs, attorneys' fees, and expenses resulting from:

1. Governmental police power, and the existence or violation of any law or government regulation. This includes building and zoning ordinances and also laws and regulations concerning: * land use * improvements on the land * land division * environmental protection. This exclusion does not apply to violations or the enforcement of these matters which appear in the public records at Policy Date. This exclusion does not limit the zoning coverage described in Items 12 and 13 of Covered Title Risks.

2. The right to take the land by condemning it, unless: *a notice of exercising the right appears in the public records *on the Policy Date *the taking happened prior to the Policy Date and is binding on you if you bought the land without knowing of the taking

3. Title Risks: *that are created, allowed, or agreed to by you *that are known to you, but not to us, on the Policy Date -- unless they appeared in the public records *that result in no loss to you *that first affect your title after the Policy Date -- this does not limit the labor and material lien coverage in Item 8 of Covered Title Risks

4. Failure to pay value for your title.

5. Lack of a right: *to any land outside the area specifically described and referred to in Item 3 of Schedule A OR *in streets, alleys, or waterways that touch your land. This exclusion does not limit the access coverage in Item 5 of Covered Title Risks.
2006 ALTA LOAN POLICY (06-17-06)

EXCLUSIONS FROM COVERAGE
The following matters are expressly excluded from the coverage of this policy, and the Company will not pay loss or damage, costs, attorneys' fees or expenses which arise by reason of:

1. (a) Any law, ordinance or governmental regulation (including those relating to building and zoning) restricting, regulating, prohibiting or relating to (i) the occupancy, use, or enjoyment of the land; (ii) the character, dimensions or location of any improvement erected on the Land; (iii) the subdivision of land; or (iv) environmental protection; or the effect of any violation of these laws, ordinances or governmental regulations. This Exclusion 1(a) does not modify or limit the coverage provided under Covered Risk 5.

2. Rights of eminent domain. This Exclusion does not modify or limit the coverage provided under Covered Risk 7 or 8.

3. Defects, liens, encumbrances, adverse claims or other matters:(a)created, suffered, assumed or agreed to by the Insured Claimant; (b)not known to the Company, not recorded in the public records at Date of Policy, but known to the Insured Claimant and not disclosed in writing to the Company by the Insured Claimant prior to the date the Insured Claimant became an Insured under this policy; (c) resulting in no loss or damage to the Insured Claimant; (d) attaching or created subsequent to Date of Policy (however, this does not modify or limit the coverage provided under Covered Risk 11, 13 or 14);or(e) resulting in loss or damage that would not have been sustained if the Insured Claimant had paid value for the Insured Mortgage.

4. Unenforceability of the lien of the Insured Mortgage because of the inability or failure of an Insured to comply with applicable doing-business laws of the state in which the Land is situated.

5. Invalidity or unenforceability in whole or in part of the lien of the Insured Mortgage that arises out of the transaction evidenced by the Insured Mortgage and is based upon usury or any consumer credit protection or truth in lending law.

6. Any claim, by reason of the operation of federal bankruptcy, state insolvency, or similar creditors’ rights laws, that the transaction creating the lien of the Insured Mortgage, is (a) a fraudulent conveyance or fraudulent transfer, or (b) a preferential transfer for any reason not stated in Covered Risk 13(b) of this policy.

7. Any lien on the Title for real estate taxes or assessments imposed by governmental authority and created or attaching between Date of Policy and the date of recording of the Insured Mortgage in the Public Records. This Exclusion does not modify or limit the coverage provided under Covered Risk 11(b):

EXCEPTIONS FROM COVERAGE
This policy does not insure against loss or damage (and the Company will not pay costs, attorneys' fees or expenses) that arise by reason of:

1.(a) Taxes or assessments that are not shown as existing liens by the records of any taxing authority that levies taxes or assessments on real property or by the Public Records; (b) proceedings by a public agency that may result in taxes or assessments, or notices of such proceedings, whether or not shown by the records of such agency or by the Public Records.

2.Any facts, rights, interests or claims which are not shown by the Public Records but that could be ascertained by an inspection of the Land or that may be asserted by persons in possession of the Land.

3.Easements, liens or encumbrances, or claims thereof, not shown by the Public Records.

4.Any encroachment, encumbrance, violation, variation, or adverse circumstance affecting the Title that would be disclosed by an accurate and complete land survey of the Land and not shown by the Public Records.

5.(a) Unpatented mining claims; (b) reservations or exceptions in patents or in Acts authorizing the issuance thereof; (c) water rights, claims or title to water, whether or not the matters excepted under (a), (b) or (c) are shown by the Public Records.

6. Any lien or right to a lien for services, labor or material not shown by the public records. 2006 ALTA OWNER’S POLICY (06-17-06)

EXCLUSIONS FROM COVERAGE
The following matters are expressly excluded from the coverage of this policy, and the Company will not pay loss or damage, costs, attorneys' fees, or expenses that arise by reason of:

Order No. 140-2370903-20

1. (a) Any law, ordinance, permit, or governmental regulation (including those relating to building and zoning) restricting, regulating, prohibiting, or relating to: (i) the occupancy, use, or enjoyment of the Land; (ii) the character, dimensions, or location of any improvement erected on the Land; (iii) the subdivision of land; or (IV) environmental protection; or the effect of any violation of these laws, ordinances, or governmental regulations. This Exclusion 1(a) does not modify or limit the coverage provided under Covered Risk 5. (b) Any governmental police power. This Exclusion 1(b) does not modify or limit the coverage provided under Covered Risk 6.

2. Rights of eminent domain. This Exclusion does not modify or limit the coverage provided under Covered Risk 7 or 8.

3. Defects, liens, encumbrances, adverse claims, or other matters: (a) created, suffered, assumed, or agreed to by the Insured Claimant; (b) not Known to the Company, not recorded in the Public Records at Date of Policy, but Known to the Insured Claimant and not disclosed in writing to the Company by the Insured Claimant prior to the date the Insured Claimant became an Insured under this policy;(c) resulting in no loss or damage to the Insured Claimant; (d) attaching or created subsequent to Date of Policy (however, this does not modify or limit the coverage provided under Covered Risk 9 and 10); or (e) resulting in loss or damage that would not have been sustained if the Insured Claimant had paid value for the Title.

4. Any claim, by reason of the operation of federal bankruptcy, state insolvency, or similar creditors’ rights laws, that the transaction vesting the Title as shown in Schedule A, is (a) a fraudulent conveyance or fraudulent transfer; or (b) a preferential transfer for any reason not stated in Covered Risk 9 of this policy.

5. Any lien on the Title for real estate taxes or assessments imposed by governmental authority and created or attaching between Date of Policy and the date of recording of the deed or other instrument of transfer in the Public Records that vests Title as shown in Schedule A.

The above policy form may be issued to afford either Standard Coverage or Extended Coverage. In addition to the above Exclusions from Coverage, the Exceptions from Coverage in a Standard Coverage policy will also include the following Exceptions from Coverage:

EXCEPTIONS FROM COVERAGE
This policy does not insure against loss or damage (and the Company will not pay costs, attorneys’ fees or expenses) that arise by reason of:

1. (a) Taxes or assessments that are not shown as existing liens by the records of any taxing authority that levies taxes or assessments on real property or by the Public Records; (b) proceedings by a public agency that may result in taxes or assessments, or notices of such proceedings, whether or not shown by the records of such agency or by the Public Records.

2. Any facts, rights, interests, or claims that are not shown by the Public Records but that could be ascertained by an inspection of the Land or that may be asserted by persons in possession of the Land.

3. Easements, liens or encumbrances, or claims thereof, not shown by the Public Records.

4. Any encroachment, encumbrance, violation, variation, or adverse circumstance affecting the Title that would be disclosed by an accurate and complete land survey of the Land and that are not shown by the Public Records.

5. (a) Unpatented mining claims; (b) reservations or exceptions in patents or in Acts authorizing the issuance thereof; (c) water rights, claims or title to water, whether or not the matters excepted under (a), (b), or (c) are shown by the Public Records.

6. Any lien or right to a lien for services, labor or material not shown by the public records.

ALTA EXPANDED COVERAGE RESIDENTIAL LOAN POLICY (07-26-10)

EXCLUSIONS FROM COVERAGE
The following matters are expressly excluded from the coverage of this policy and the Company will not pay loss or damage, costs, attorneys fees or expenses which arise by reason of:

1. (a) Any law, ordinance, permit, or governmental regulation (including but not limited to building and zoning) restricting, regulating, prohibiting or relating to (i) the occupancy, use, or enjoyment of the Land; (ii) the character, dimensions or location of any improvement erected on the Land; (iii) the subdivision of the land; or (iv) environmental protection, or the effect of any violation of these laws, ordinances or governmental regulations This Exclusion 1(a) does not modify or limit the coverage provided under Covered Risks 5, 6, 13(c), 13(d), 14, and 16.(b) Any governmental police power. This Exclusion 1(b)does not modify or limit the coverage provided under Covered Risks 5, 6, 13(c), 13(b), 14, and 16.

2. Rights of eminent domain. This Exclusion does not modify or limit the coverage provided under Covered Risk 7 or 8.

3. Defects, liens, encumbrances, adverse claims or other matters (a) created, suffered, assumed or agreed to by the Insured Claimant; (b) not Known to the Company, not recorded in the Public Records at Date of Policy, but Known to the Insured Claimant and not disclosed in writing to the Company by the Insured Claimant prior to the date the Insured Claimant became an Insured under this policy;(c) resulting in no loss or damage to the Insured Claimant;(d) attaching or created subsequent to Date of Policy (however, this does not modify or limit the coverage provided under Covered Risks 11, 16, 17, 18, 19, 20, 21, 22, 23, 24, 27 or 26); or (e)resulting in loss or damage which would not have been sustained if the Insured Claimant had paid value for the Insured Mortgage.

4. Unenforceability of the lien of the Insured Mortgage because of the inability or failure of the Insured to comply with applicable doing-business laws of the state in which the Land is situated.

5. Invalidity or unenforceability in whole or in part of the lien of the Insured Mortgage that arises out of the transaction evidenced by the Insured Mortgage and is based upon usury, or any consumer credit protection or truth in lending law. This Exclusion does not modify or limit the coverage provided in Covered Risk 26.

6. Any claim of invalidity, unenforceability or lack of priority of the lien of the Insured Mortgage as to Advances or modifications made after the Insured has Knowledge that the vestee shown in Schedule A is no longer the owner of the estate or interest covered by this policy. This Exclusion does not modify or limit the coverage provided in Covered Risk 11.

7. Any lien on the Title for real estate taxes or assessments imposed by governmental authority and created or attaching subsequent to Date of Policy in accordance with applicable building codes. This Exclusion does not modify or limit the coverage provided in Covered Risk 5 or 6..

8. The failure of the residential structure, or any portion of it, to have been constructed before, on or after Date of Policy in accordance with applicable building codes. This Exclusion does not modify or limit the coverage provided in Covered Risk 5 or 6.

9. Any claim, by reason of the operation of federal bankruptcy, state insolvency, or similar creditors’ rights laws, that the transaction creating the lien of the Insured Mortgage, is (a) a fraudulent conveyance or fraudulent transfer, or (b) a preferential transfer for any reason not stated in Covered Risk 27(b) of this policy.

Order No. 140-2370903-20