6/25/2019 City of Los Angeles Mail - Support of Appeal Opposing Barry's Bootcamp CUP

Support of Appeal Opposing Barry's Bootcamp CUP

Kathleen Flanagan <flanagan1203@gmail.com> To: clerk.plumcommittee@lacity.org Cc: Mike Bonin <mike.bonin@lacity.org>

Sun, Jun 23, 2019 at 5:36 PM

Ms. Zina Cheng:

Brentwood Homeowners Association submits the attached letter in support of the appeal challenging the Conditional Use Permit granted to Barry's Bootcamp, Council File 19-0538.

Sincerely,Kathleen FlanaganPresident, Brentwood Homeowners Associationflanagan 1203@gmail. com310.728.5119

— Itrto PLUM RE Barry's Bootcamp.pdf^ 74K

https://mail.google.com/mail/u/0?ik=bc19ce6208&view=pt&search=all&permmsgid=msg-f%3A1 637180114311125990&simpl=msg-f%3A163718011431... 1/1

BrentwoodHOMEOWNERSASSOCIATION

PO Box 49427 □ Los Angeles, California 90049 □ (424) BHA-8765 □ info@brentwoodhomeowners.org

June 21,2019

PLUM Committee of City Council By email to clerk.plumcommittee@lacity.org

Re: Council File: 19-0538Case No.: APCW-2018-3556-SPE-CU-DRB-SPP 11677 West San Vicente Blvd / Conditional Use Permit

Support of Appeal of West Los Angeles Area Planning Commission (“APC”) Determination (“APC Decision”) approving a Conditional Use Permit (“CUP”) to allow a health club to operate 5:00 AM to 7:00 AM (“Extended Hours”)

Dear Councilmembers Harris-Dawson, Blumenfeld, Cedillo, Price, Smith,

The Brentwood Homeowners Association (“BHA”) has been representing the interests of area homeowners for over 70 years. Today, our territory covers 3,200 homes north of San Vicente and west of the 405 Freeway.

The Findings in the APC Decision to support granting a CUP are factually incorrect. Barry’s Bootcamp is not unique. Orange Theory Fitness is the same kind of class-oriented health club and is located in the adjacent building.

The Finding that the applicant would provide a service that is essential and beneficial to the community is based on the statement:

“Unlike other health clubs, Barry’s Bootcamp is strictly regimented by a pre-determined class schedule. In comparison to other types of fitness/health clubs within the area, Barry’s Bootcamp would provide a unique service to the community.”

The Finding that the project substantially conforms with the General Plan, community plan, and Specific Plan is based on the following statement:

“Barry’s Bootcamp is a unique, class oriented fitness facility that provides a variety of fitness programming to its clientele. The business would allow for a new neighborhood service that’s currently not available to local residents.”

In fact, Barry’s Bootcamp and Orange Theory Fitness (in the adjacent building to the east at 11661 San Vicente) are the same —intense group class workouts led by a trainer using cardio equipment and weights. The description on each of their web sites almost reads as if one company copied it from the other:

https://www.orangetheorvfitness.com/the-workout

https://www.barrvsbootcamp.com/best-workout/

1

The most significant difference between these two health clubs is that one uses orange lighting and the other one uses red lighting - obviously, not a difference making the applicant “unique.” Both clubs have one-hour group classes that are run by a trainer. If we Delete the statements quoted above about the uniqueness of Barry’s Bootcamp. there remains no factual support for a CUP. In addition, a google search of “health clubs on San Vicente in Brentwood” shows 12 locations. In other words, there is no substantial evidence to legally support the required Findings and the Appeal of the APC Decision must be granted on legal grounds. The grant of a CUP by the APC was erroneous and an abuse of discretion.

In addition, this proposed new health club use should not be granted in view of the statement in the Staff Recommendation to the APC that “San Vicente Boulevard and the adjacent residential neighborhood streets are greatly impacted by spillover parking from commercial uses (visitors and employees) and the lack of parking for the residential uses.” (paragraph 4 of Findings in APC Decision) It would be inconsistent to recognize the parking and traffic issues in the area and nevertheless grant a conditional use for a health club with up to 45 people per class every hour, starting at 5:00 AM.

CONCLUSIONThe Appeal should be granted.The PLUM Committee should Deny a Conditional Use Permit because there is no factual evidence in the record to support the mandated Findings.Thank you,

Kathleen Flanagan, President

cc: Mike Bonin; Krista Kline; Len Nguyen; Juliet Oh

2

6/25/2019 City of Los Angeles Mail - Barrys Bootcamp Applicant Letter Response - Council File No. 19-0538

Barrys Bootcamp Applicant Letter Response - Council File No. 19-0538

Justin Mahramas <justin@mcadvise.com>To: "clerk.plumcommittee@lacity.org" <clerk.plumcommittee@lacity.org> Cc: Loren Montgomery <loren@mcadvise.com>

Mon, Jun 24, 2019 at 11:53 PM

Hi Rita,

Per our conversation last week, attached is the Applicant Response Letter and a separate attachment for Council File No 19-0538. We are submitting this letter to the PLUM committee for their consideration in preparation for tomorrow’s hearing. Please note, however, that we are still in discussions with Appellant about an agreement and are hopeful that we will reach one. In an abundance of caution and so there is a written response to the appeal in the record, we are submitting this to be included in the PLUM materials.

Please let either myself or Loren Montgomery (copied) know if you have any questions.

Best Regards, Justin

Justin MahramasMONTGOMERY CLARK ADVISORS

10877 Wilshire Blvd. Ste. 1102

Los Angeles, CA 90024 E-Mail: justin@mcadvise.com Office: (310) 443-7711 Mobile: (412) 916-2455

2 attachments

-o Barrys Bootcamp Applicant Letter Response - Council File 19-0538.pdf5519K

— »l Attachment B - Council File 19-0538.pdf^ 17469K

https://mail.google.com/mail/u/0?ik=bc19ce6208&view=pt&search=all&permmsgid=msg-f%3A1 637294449397277192&simpl=msg-f%3A16372944493... 1/1

10877 Wilshire Boulevard Suite 1103Los Angeles, California 90024 Telephone 310.443.7711

MONTGOMERYCLARKADVISORS

June 24, 2019

VIA EMAIL

Honorable Chair Harris-Dawson and Honorable Councilmembers Planning and Land Use Management Committee 200 North Spring Street, Room 395 Los Angeles, California 90012

11677 West San Vicente Boulevard;Case No. APCW-2018-3556-SPE-CU-DRB-SPP;

Re:

ENV-2018-3557-CECouncil File No. 19-0538

Dear Honorable Members of the PLUM Committee:

On behalf of our client, Barry’s Bootcamp, LLC, (“Barry’s.” or “Applicant”), we look forward to presenting to your committee and appreciate the opportunity to comment on the appeal filed by Brentwood Residents Coalition (“Appellant”) on May 1, 2019, regarding the above-referenced project.1 Since first presenting to the Planning Department in early 2018, Barry’s Bootcamp has carefully considered the comments from City staff and the public, and has worked diligently to address any input and improve the design and operation of the project. After careful review, the Applicant is no longer requesting a specific plan exception for parking and has strong support from the community. It is our hope that after two years of working with the City and the Brentwood Community, and where the only remaining project requests involve a change of tenant use and an extension of operating hours for that use, we will finally be able to fill a vacant space and bring an exciting new business to Brentwood.

We respectfully request that the PLUM Committee recommends that the City Council deny the appeal and affirm in full the Area Planning Commission Letter of Determination, dated April 17, 2019.

Background - Project is to fill vacant tenant space with a productive useI.

Barry’s Bootcamp is proposing to move into long-vacant tenant space at Brentwood Gardens to house its unique and internationally recognized gym/health studio that focuses on regularly scheduled group fitness classes that are available by appointment only. The Project would convert approximately 4,751 square feet of vacant retail space into the gym/health studio use (the “Project”). The Project proposes no change to the existing overall gross square footage at Brentwood Gardens. As this is all existing space, Barry’s Bootcamp would only require interior tenant improvements and some minor exterior fa<?ade alterations.

On March 20,2019, a hearing was conducted by the West Los Angeles Area Planning Commission (“APC”). The APC approved the project permit compliance for the tenant change of use and design review, the conditional use permit for extended hours of operation, and the CEQA review for a categorical

1 http://planning.lacity.org/StaffRpt/lnitialRpts/APCW-2018-3556.pdf

City Council PLUM CommitteeJune 24, 2019Page 2

exemption. APC denied the request for a specific plan exception to deviate from the San Vicente Scenic Corridor Specific Plan’s (the “Specific Plan”) required parking for the change of use from retail to gym, but this approval is no longer necessary. On May 1, 2019, the Project approvals were appealed by Brentwood Residents Coalition, despite having support from our nearest homeowner association, the South Brentwood Residents Association (SBRA), the Brentwood Community Council (BCC), and other close by neighbors. The following discussion will help clarify the main factual errors and misunderstandings in Appellant’s letter.

Parking - Project will supply more than adequate parking under any scenario and will comply with the parking requirements of the Specific Plan

II.

A. There is adequate parking to meet demand under even the most conservative assumptions

As previously mentioned, the Applicant is no longer pursuing a specific plan exception for a parking reduction for the tenant change of use. The Project will be compliant with the parking requirements of the Los Angeles Municipal Code (the “LAMC”) and the Specific Plan. However, it is important to note that Applicant originally sought a specific plan exception to reduce the vehicle parking requirement for the change of use from thirty-one (31) spaces to zero (0) spaces because of empirical shared parking data that confirms that there is more than adequate parking supply to meet demand at all times - even with assuming full capacity of the new use. It is well known in the community that Brentwood Gardens is in the exceedingly rare position of having a surplus of existing on-site parking.

Under any peak parking demand scenario, the Applicant has provided empirical parking data and analysis that shows there is more than enough parking supply at Brentwood Gardens to meet demand. The Applicant conducted two shared parking studies that show the peak parking demands of Brentwood Gardens can easily be accommodated within the existing parking supply with the addition of Barry’s Bootcamp. (See Attachment “A”). This is true even utilizing the most conservative assumptions assuming full tenant occupancy of the entire shopping center. Additionally, all vehicles arriving to Brentwood Gardens are always parked on site. Thus, there is no reasonable concern that spillover parking will occur into the surrounding community.

B. Even though there is more than enough parking to meet demand, Applicant is committed to providing code parking and is no longer requesting a Specific Plan Exception for parking.

Following the APC hearing, the Applicant retained additional parking experts to determine if any of the solutions referenced by Planning staff at the APC hearing are able to be integrated into the Project. These alternative solutions to the parking requirements involve the possibility of providing offsite leased parking within 750 feet of the shopping center (pursuant to LAMC Section 12.21-A.4(g)) or allowing new or existing required vehicle parking spaces to be replaced with bicycle parking at a ratio of four bicycle spaces for each required vehicle space (pursuant to LAMC Section 12.21-A.4). These alternative solutions are compliant with LAMC and the Specific Plan.

The Applicant engaged both Gibson Transportation Consulting and Retail Design Collaborative to conduct a complete survey of the entire parking area at Brentwood Gardens to determine if the bicycle parking replacement option is feasible at the shopping center. After completing this investigation, a section of the current parking structure was identified that can be utilized as a bicycle room, accommodating a minimum of 130 bicycles. {See Attachment “B”). The addition of a 130 bicycles spaces will offset more than the required 31 vehicle parking spaces. This represents approximately 12 percent of the required

City Council PLUM CommitteeJune 24, 2019Page 3

vehicle parking at Brentwood Gardens (including the addition of Barry’s Bootcamp). Because the change of use from retail to gym only requires an additional 31 vehicle spaces, the 130 new bicycle parking spaces allows Brentwood Gardens to provide the necessary parking for the new use in compliance with both the LAMC and Specific Plan.

The area identified in Attachment B is not currently striped for vehicle parking or any other use. Once completed, the bicycle parking room will be available to all guests and employees of Brentwood Gardens. Further, all bicycle parking would be located onsite and not require the construction of any additional square footage. The bicycle room is completely internal to the existing parking area and would not impact the ground level entry or public right-of-way. Additionally, the room will be fully secured and attended by the existing fulltime valet service. This will provide all visitors to Brentwood Gardens a safe and secure location to leave their bicycle while visiting the center.2

III. Hours of Operation - Project will begin operations earlier on weekday mornings, at a time consistent with other gym uses in the Specific Plan area

A. The proposed hours of operation, to open beginning at 5:00 am on weekdays, are consistent with other similar uses in the Specific Plan area.

The Appellant asserts that the APC erred and abused their discretion in approving the project. (App. Ltr. pg. 6). Appellant’s specific claim seems to rest on a noise concern stemming from the earlier start time of 5:00 am for Barry’s Bootcamp. First, Appellant states that there is no substantial evidence on the record that shows that Gorham Alley is utilized by commercial uses starting as early as 5:00 am. (App. Ltr. p. 7). Setting aside the fact that Gorham is a public alley that can be accessed at all times of day by a variety of uses, Appellant’s statement is still false. This statement has been refuted by the Appellant’s own acknowledgment that Orangetheory Fitness is also located along San Vicente Boulevard, with egress onto Gorham Alley. Orangetheory is an existing commercial use that is open on weekdays starting at 5:00 am.3 Barry’s Bootcamp would operate in a similar manner with egress onto Gorham Alley no different than that of their neighbors at Orangetheory. A similar example of earlier hours of operation along San Vicente is Soul Cycle. Soul Cycle is located on the southern side of San Vicente and also provides further precedent for a fitness use that opens prior to 7:00 am.4

B. Barry's Bootcamp provides a unique workout and amenities that make it a distinct type of gym use with its own community of local supporters

Appellant’s contention that Barry’s Bootcamp is not an important and unique addition to the community has been completely refuted by the outpouring of support in the community for the opening of a Brentwood studio. Public comment in support of the project has shown that Barry’s Bootcamp has such

2 Appellant also claims that a Class 1 categorical exemption (CEQA Guidelines Section 15301) is not appropriate for this project. A Class 1 categorical exemption allows for “Existing Facilities” including “interior and exterior alterations involving remodeling or minor construction where there be negligible or no expansion of use.” If a tenant change of use at a longtime existing shopping center that involves no change to gross square footage or floor area doesn’t quality for a categorical exemption, then no project does. (See Attachment “C”).

3 Orange Theory Fitness is located at 11661 San Vicente Blvd. and opens on weekday at 5:00 am with classes beginning at 5:30 am. See https://brentwoodla.orangetheoryfitness.com/

4 Soul Cycle is located at 11640 San Vicente Blvd. and opens on weekdays at 6:00 am. See https://www.soul- cycle.com/find-a-class/studio/16/

City Council PLUM CommitteeJune 24, 2019Page 4

a loyal and enthusiastic group of supporters that they are currently traveling from Brentwood to existing Barry’s locations in Venice and West Hollywood. Yes, this occurs even with other fitness uses nearby. Bringing Barry’s Bootcamp to Brentwood and at a location that is easily accessible to community members via alternative means of transportation will only benefit traffic, especially when every visitor to Brentwood Gardens will be parked on site.

Further, the growing number of vacancies along San Vicente of previously tenanted retail space shows the increasing need for the community to be able to adapt to new businesses. The Appellant relies on the fact that because both Barry’s Bootcamp and Orangetheory Fitness have class-based workouts that they, therefore, provide the exact same service to the community. (App. Ltr. p. 7). It is difficult to understand the logic behind this assertion. The Appellant’s analogy certainly wouldn’t apply to other types of uses, such as a restaurant. For example, simply because two restaurants serve food does not mean that they provide a redundant benefit to the community. Likewise, in today’s evolving world of fitness there are a wide variety of different workout regimes. Barry’s Bootcamp provides a specific exercise program of one-hour classes that are a carefully designed mix of cardio conditioning and strength training. Each day of the week instructors focus on different muscle groups, ensuring the body gets a balanced workout and proper time to recover. Outside of the workout, Barry’s offers premium amenities, including luxury locker rooms, private showers, and the “Fuel Bar.” The Fuel Bar offers freshly crafted nutritional shakes that are focused on the specific workout goals of the individual.

In contrast, Orangetheory provides a different workout experience. A quick glance at their workout description and classes shows another distinct fitness option for the community.5 Additionally, Soul Cycle is also located nearby along San Vicente and provides yet another completely different workout experience.6 Thus, Appellant’s assertion that a singular type of fitness option is equivalent to any other is simply not supported by the facts.

C. Barry’s Bootcamp designs every studio with an acoustical engineer to prevent any audible noise to the surrounding area

As a part of every studio design Barry’s Bootcamp undergoes a thorough acoustical design to eliminate any possibility of noise escaping the premises. As referenced in the adopted Findings, “[cjlasses within the tenant space are proposed within a 1,823 square-foot sound attenuated studio.” (LOD at F-4) The fitness studio is constructed as a room-within-a-room with isolated floor, wall, and ceiling assemblies. By providing additional mass and an airspace, these interior assemblies improve the noise reduction of the existing building construction. All interior surfaces are decoupled acoustically from the surrounding building to reduce noise transmission through common structural elements. The isolated floor also serves to reduce vibration transmission from fitness activities to the rest of the building. It should also be noted that Barry’s is located on the ground floor of Brentwood Gardens and is not above any other tenant space.

Further, the entirety of the Project is buffered from the exterior walls of the building by a service corridor. At no point does the studio have a shared wall with the exterior of the shopping center. This

5 See https://www.orangetheoryfitness.com/the-workout

6 See https://www.soul-cycle.com/new-to-soul/

City Council PLUM CommitteeJune 24, 2019Page 5

additional buffer will further insulate the studio from both other Brentwood Gardens tenants and the surrounding properties.

IV. Project Support - The Applicant has actively worked with the community to address any concerns regarding parking and noise and has the support of a variety of community groups and stakeholders

The Applicant has engaged in an ongoing dialogue with community groups and stakeholders to address any questions or concerns about the Project. Throughout this ongoing process, the Applicant has had a variety of conversations with the Brentwood Community Council, South Brentwood Residents Association, and individual residents located in the area, as reflected in the number of support letters submitted. Throughout this collaborative process, the Applicant has addressed questions regarding both parking and noise and appreciates the support that we have received from these groups. The Applicant and Brentwood Gardens are both committed to continuing these relationships well into the future, to ensure that Brentwood continues to be a community that values and respects the needs of its residents.

Specifically, the Applicant and Brentwood Gardens have worked with residents along Gorham Alley to further ensure that the operation of Barry’s will address any additional concerns of the neighbors. The primary concern of these residents was the approximate start time of the air chiller mechanical equipment on the roof of Brentwood Gardens. After discussions with the neighbors, Brentwood Gardens undertook multiple maintenance upgrades to the mechanical equipment. These improvements have already been completed, at the sole cost of the owner, to the satisfaction of the neighbors and include: (1) upgrades and insulation of the mechanical unit to reduce noise and (2) screening of the entire unit to prevent a direct line of site from the residences to the air chiller. The installation of these features was completed for the community and to provide greater assurance that noise from the mechanical equipment will be inaudible to adjacent residents.

V. Conclusion

Brentwood Gardens has always taken the utmost care in being a respectful and contributive member of the community. The center has been closely involved with many community volunteer initiatives and events. They take comments from all members of the community very seriously and want to ensure that all tenants at the shopping center are providing a benefit to the community. The Applicant is excited to become a member of the Brentwood community and help strengthen the future of the San Vicente corridor.

For the reasons set forth herein, we respectfully request that the City Council deny the appeal and affirm the APC’s decision. We very much appreciate your careful consideration.

Very truly yours,

Justin Mahramas

Montgomery Clark Advisors

City Council PLUM CommitteeJune 24, 2019Page 6

Copies to:

Rita Moreno, Office of the City Clerk Juliette Oh, City Planning Alex Truong, City Planning Krista Kline, CD 11 Len Nguyen, CD 11Tracy McIntosh, Barry’s Bootcamp LLC Sam Yadegar, Brentwood Gardens LLC Loren Montgomery, Montgomery Clark Advisors

City Council PLUM CommitteeJune 24, 2019Page 7

Attachment “A”

Brentwood Gardens Shared Parking Demand Summary

Gibson Transportation completed a parking demand study for the project on February 20, 2018. Based on the occupancy counts, peak parking demand at Brentwood Gardens occurred on Friday at 1:00 p.m. when 116 spaces (approx. 50% of the parking supply) were occupied. The peak parking demand on Saturday occurred at 1:00 p.m. when 129 parking spaces (approx. 56% of the parking supply) were occupied. The parking demand study then analyzed the likely parking demand at Brentwood Gardens with the addition of Barry’s Bootcamp. The projected peak demand for both weekday and weekend occurred at 12:00 p.m. The projected demand on weekdays is 150 spaces and on weekends is 167 spaces. With the installation of Barry’s Bootcamp, the peak parking demand of 167 spaces will still result in a surplus of 65 spaces. (See APC Recommendation Report Exhibit D).

At the request of community members, a supplemental parking demand report was completed on January 25, 2019 prior to the APC hearing. This study conservatively used the existing demand data from the 2012 San Vicente Corridor Parking Study to further assess the potential impact of Barry’s Bootcamp on the existing parking supply at Brentwood Gardens. {See APC Recommendation Report Exhibit E). Under this scenario, even at 100 percent occupancy of the existing vacant retail spaces and with the addition of Barry’s Bootcamp, the projected peak parking demand is 204 spaces on a weekday and 174 spaces on a weekend. Brentwood Gardens could accommodate peak parking demand at all times of the year when fully occupied. {See APC Recommendation Report Exhibit D).

The purpose of a shared parking model was to determine how the parking demand for different uses interact with each other, not how each individual store demands parking. Shopping centers very rarely have specific allocations of parking supplies to specific uses or businesses, and that is the case here as well. The shared parking analysis shows that the peak parking demands of Brentwood Gardens can be accommodated within the existing parking supply with the addition of Barry’s Bootcamp. Thus, there is no reasonable concern that spillover parking will occur into the surrounding community. Further, Brentwood Gardens has always provided a full-service valet, and under no circumstances parks cars offsite. This will not change in the future, and the valet service will be extended to the earlier weekday hours of operation for Barry’s Bootcamp patrons.

City Council PLUM CommitteeJune 24, 2019Page 8

Attachment “B

Bicycle Parking Room Site Plan

(Attached Under Separate Cover)

City Council PLUM CommitteeJune 24, 2019Page 9

Attachment “C”

A Categorical Exemption for “Existing Facilities” (Class 1) is appropriate, as the Project proposes a tenant change of use with only interior remodeling and minor exterior alterations and a net neutral square footage

CEQA Class 1 categorical exemptions focus on whether a project involves negligible or no expansion of use. (CEQA Guidelines Section 15301). Further, ministerial activities are exempt from CEQA review. (CEQA Guidelines Section 15300.1). Appellant claims that the use of a Categorical Exemption under CEQA is inappropriate because the project is requesting additional future entitlements. (App. Ltr. p. 8-9). However, this claim is simply false. Contrary to the Appellant’s claims, the utilization of LAMC Section 12.21-A.4 to provide additional bicycle parking in-lieu of vehicle parking does not constitute an additional future entitlement. (App. Ltr. p. 9). The Applicant is no longer pursuing a specific plan exception or other discretionary entitlement related to parking. Instead, the Applicant acknowledges the APC’s determination to condition the project to provide an additional 31 spaces and is choosing to provide these additional spaces in a way specifically permitted by LAMC Section 12.21 -A.4. In fact, the very purpose of Section 12.21-A.4 is to encourage bike parking by expressly allowing it to be provided in lieu of vehicle parking for up to 20% of the required parking for the shopping center or building. As noted above, all bicycle parking would be located onsite and not involve any alterations to the existing square footage and automobile parking supply at Brentwood Gardens.

At the time of the APC hearing, it was unclear whether any other alternatives for meeting the APC’s parking condition were feasible. In fact, the difficulty in complying with the parking requirements was a primary reason for the Applicant pursuing a specific plan exception in the first place. Appellant’s claims to the contrary are false. Specifically, Appellant states that the Applicant would “[rjeceive the benefit of a specific plan exception that has been nominally denied.” (App. Ltr. p. 10). This statement has no logical foundation. Rather, the Applicant has been specifically conditioned by APC to either provide the required parking through LAMC compliant means or not be provided the necessary building permits to construct the Project. A compliant parking solution has been identified and will be implemented by the Applicant to the satisfaction of APC’s condition of approval.

Additionally, Appellant claims that a Class 1 categorical exemption (CEQA Guidelines Section 15301) is not appropriate for this project. A Class 1 categorical exemption allows for “interior and exterior alterations involving remodeling or minor construction where there be negligible or no expansion of use.” (LOD p. F-9). If a tenant change of use at a longtime existing shopping center that involves no change to gross square footage or floor area doesn’t qualify for a categorical exemption, then no project does. The only other component is the inclusion of additional bike parking. The bike room would have no impact on the existing parking supply at Brentwood Gardens. In fact, the additional 130 bicycle parking spaces would be completely in addition to the existing parking supply. Additionally, the bicycle room is completely internal to the existing parking structure. Its construction does not involve additional square footage and does not impact the ground level entry or public right-of-way. Even if “spill-over” parking was a CEQA consideration, the Project’s compliance with the LAMC and the Specific Plan completely ameliorates Appellant’s concern. Therefore, the APC’s determination that the Project is categorically exempt from CEQA was appropriate and should be affirmed.

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