SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 300 SOUTH GRAND AVENUE LOS ANGELES, CALIFORNIA 80071-3144 nozton TEL (213) 687-5000 sousvon FAX (213) 687-5600 Patol \ww.skadden.com December 15, 2014 shawana: Via Email and Federal Express Ms. Elva Nuiio-O'Donnell Hearing Officer Los Angeles Department of City Planning Marvin Braude San Fernando Valley Constituent Services Center 6262.N. Van Nuys Boulevard, Suite 351 Los Angeles, CA 91401 RE: Archer Forward Project CPC-2014-666- VCU-ZAA-SPR and ENV-2011-2689-EIR, Dear Ms. Nuiio-O'Donnell This letter supplements our brief comments at the hearing as well as the detailed written comments we submitted to Mr. Villani on April 29, 2014 and the charts provided to you at the December 8 hearing (the “Hearing”), regarding the Archer Forward Project (the “Plan” or “Project”) put forward by the Archer School for Girls (“Archer” or the “School”).' This letter will also respond to some of the testimony at the Hearing, as we were not provided the opportunity for rebuttal at that time. But first, on behalf of ourselves as well as the Residential Neighbors of Archer (the “Residential Neighbors”), Thelma and I want to reiterate our thanks to you and your staff for your work on this Project, which, unless abated, will have an enormous effect not only on Archer’s immediate neighbors (like my family) but also on the ' For your convenience, Tab 1 to this submission is a copy of our April 29, 2014 comment letter on the DEIR sent to Mr. Villani. 152896 01-LACSRO2A - MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 2 entire community that depends on Sunset Boulevard as a major east/west thoroughfare.” I. INTRODUCTIOT ‘The “we deserve it” mantra frequently invoked at the Hearing unfortunately underscores the institutional arrogance inherent in Archer’s approach to the Project since inception. That institutional arrogance explains why Archer went to “Harvard” to begin planning for “Archer Forward” but never bothered to consult and negotiate with its immediate neighbors ~- the people most effected by Archer’s enormous expansion plan - before designing a community college-like campus in a quiet residential neighborhood. That approach also explains why, in its original plan. Archer actually moved its baseball diamond so that it was immediately adjacent to its western neighbors facing east as opposed to being on the opposite side of the athletic field facing west as it has been for 15 years,’ (See Tab 2 Attachment (Map of Archer showing current footprint and permitted but never constructed gymnasium/multipurpose building.) When asked to justify that design change to a group of incredulous neighbors when Archer finally unveiled its Plan, the remarkable response was “it provides batters with a better line of sight.” Thus, while Archer likes to loudly and frequently proclaim the “concen” it had for its neighbors in designing the Plan, the Schoo!’s actions speak more clearly. It s that approach and the School’s failure to consider reasonable alternatives (including a generous plan put forward by the Residential Neighbors) that explains the opposition to Archer’s Plan, not “hatred for the school” as suggested by a faculty member who spoke on Archer’s behalf at the Hearing. 2 We live at 11840 Chaparal Street, which is the residence immediately adjacent to the School’s athletic field on Archer's western boundary. s Among other design features that displayed a complete lack of concern for its neighbors, Archer’s original plan included: (i) lights on the field despite that being expressly prohibited by the current CUP, as Archer’s western neighbors are within six feet of the School’s athletic field; (ii) virtually no landscape buffering; (iii) exits from its proposed underground parking oriented toward the neighboring residences, which would channel noise directly into the residences rather than away; (iv) a performance arts center larger than either the Geffen Playhouse or the Wallis Annenberg Center for the Performing Arts; and (v) doors and windows facing toward residences and away from the School’s main building. While Archer changed a few of these features in a subsequent version of the Plan, that these design features were included in the first instance despite being reviewed by Archer's entire team speaks volumes about The School’s purported concern for its neighbors. 150896 01-LACSROQA - MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 3 Institutional arrogance also explains why Archer could propose a Plan that eviscerates the carefully and painstakingly negotiated conditions in the original CUP that were agreed upon as a condition to Archer’s being allowed to commence operations in a quiet residential neighborhood in the first instance. As Dan Green, the Zoning Plan Administrator, so aptly noted at a 2007 Plan Approval hearing when Archer was yet again attempting to eliminate some of the protections contained in ‘the CUP: ‘The restrictions on school operations were carefully and painstakingly negotiated in an effort to balance the needs of the School while, at the same time, protecting and preserving the rights of Archer’s immediate neighbors to the quiet enjoyment of their homes. That effort, if allowed to succeed, will damage public confidence in the planning process and make initial compromises more difficult to reach as persons most affected by development will have no surety that the agreements and compromises reached initially will not be ‘unwound in future years. (See Zoning Administrator Dan Green’s November 14, 2007 Determination Letter at p. 7 (emphasis added).) Yet, under the slogan “we deserve it.” that damage to public confidence is precisely what Archer's Plan will cause if the School succeeds in its effort to gut the existing “carefully and painstakingly negotiated” CUP, as if it never existed in the first instance. Unfortunately, itis all too easy for the School to bus people to the Hearing so they can denounce the CUP as “discriminatory” to a cheering section of Archer students, What that carefully orchestrated show cannot conceal is that neither of those groups are within the class of people the CUP was primarily intended to protect -- Archer’s immediately adjacent neighbors. Again, that unfortunate spectacle simply exemplifies Archer's approach to the Project: place all the burden on the neighbors to benefit a private school and those affiliated with it.’ Again, ‘ Although Archer suggests the “community” somehow benefits from its massive expansion, that claim cannot survive scrutiny. Along with other private schools operating within an approximate three square mile radius of Archer, the School has been successfully operating for 15 years. Thus, to the extent a private school ever provides any community benefit, that benefit has already occurred. Building a Taj Mahal style project adds no incremental benefit to the community, however much it might satisfy the ambitions of the School. 752896 01-LACSRO2A - MSWMs. Elva Nun-O'Donnell December 15,2014 Page 4 with great foresight, Mr. Green previously addressed this approach when at the 2001 hearing he specifically found: The compatibility of the school with its residential neighbors has been and will always be a delicate balance; as proposed, the requested change is a one-way burden to be shouldered solely by the neighbors. (1d, at 8 (emphasis added).) In short, Archer’s aggressive expansion is simply incompatible with the neighborhood in which Archer chose to locate. The neighborhood is, however, no less deserving of protection now than it was when Archer first negotiated and agreed to the CUP. Archer either needs to reign in its ambition and develop a plan consistent with its location or find a location consistent with its ambition. Given Archer's implacable refusal to consider the Residential Neighbors’ proposal, none of Archer's alternatives, with the exception of Alternative 2, preserves the “delicate balance” so carefully established by Mr. Green, Upon deconstructing the mythology Archer has attempted to create around its Plan and replacing rhetoric with a detailed factual analysis, we hope the conclusion you will reach preserves that “balance” rather than destroys it. Il, | DECONSTRUCTING THE MYTHS A. ‘The CUP Does Not Discriminate Against the Girls Perhaps the most incredible claim articulated at the hearing was that Archer is justified in tearing up and discarding the current CUP because it “discriminates against the girls.” Absurd on its face, that suggestion reflects a profound misunderstanding of the role a CUP plays in preserving and protecting communities while allowing for appropriate development. A CUP is not put in place to punish an applicant; rather, the role of a CUP is to permit a new use but to do so in a manner that preserves and protects the character of the neighborhood in which the applicant seeks to operate. While Archer apparently now believes the conditions to which it agreed are punitive and “discriminatory,” Mr. Green put the lie to that fantasy when he found that: Stasis exists because the balance established by the Conditions is fair. The Archer School's initial approval for this location required the cobbling together of Conditions and restrictions that allowed it to be shoe homed into a residential neighborhood on a lot previously occupied for many years by retired nuns. 152896 01-LACSRO2A- MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 5 (November 14, 2007 Determination Letter at p. 10) (emphasis added).) In short, Archer's argument that the Zoning Administrator would have imposed weaker conditions had Archer not been a school for girls simply defies credulity and should be rejected out of hand. Rather than punishing Archer because itis a school for girls, the current CUP properly took into account that, prior to Archer moving into the current facility, the property (the “Property”) was utilized as a retirement home for elderly women. In effect, the Property consists of two lots. The first lot fronts Sunset Boulevard and had upon it the “historic building” that Archer now uses as its primary facility or main building. The second, or “back lot” where the school currently has its athletic field, basketball and volleyball courts lay vacant for decades.” The back lot borders Chaparal on the north, a very narrow, quiet residential street. Immediately adjacent on the east and west border of the back lot are residential houses. Archer’s “we deserve it” approach is also flawed because it both conflates “needs* with “wants” and ignores the promises Archer made to its neighbors as a condition to being allowed to commence operations in a sensitive area. When the School chose the Eastern Star Home for its location, it knew the limitations of the Property, including the size of the lot and the location of the back lot squarely within a quiet residential neighborhood. Significantly, even the Eastern Star Home, whose operations were far less intense than the School’s, had to maintain a setback of 200 feet from Chaparal. Despite these known limitations, Archer chose the Eastern Star Property over other available locations, presumably because it was more concerned with having a prestigious Brentwood address than the inherent limitations arising from lot size and location. Archer's original choice to utilize the Eastern Star Home site for its Schoo! with the substantial intendant increase in the intensity of use drew numerous objections from the immediately adjacent neighbors — the group that * tn 1931, the Eastern Star Home received approval to build a facility for aged members with a condition that the building be set back 224 feet from Chaparal Street. The back lot of Archer on Chaparal Street has remained free of buildings for well over 80 years, a narrow street without sidewalks and a more rural than urban feel. © This point is significant because, as our expert, Mr. Watry, pointed out in his report, filed in response to Archer’s DEIR, the baseline for analyzing significant noise impact is zero, not the new baseline established by Archer’s nonconforming use. Moreover, on weekends, that remains the baseline even today as Archer has not made use of its athletic field on weekends, even though the CUP allowed for some de minims use 15289601-4ACSROZA- MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 6 then and now bears the primary burden arising from Archer's decision to operate within a residential community. ‘Apparently unaware then of its newly discovered claim of “discrimination,” ‘Archer negotiated and agreed to the CUP as a means of protecting and preserving the residential character of the neighborhood, Among other things, Archer promised its neighbors that it would: ‘© Limit the physical size of the School with regard to the number of buildings permitted and requiring a substantial setback from ‘Chaparal; © Limit hours of operation so as to protect the neighbors’ ability to enjoy the peace and quiet of their homes, particularly at night and on the weekends; © Limit enrollment; ‘© Limit the number of special events that could take place at night and on the weekends; + Restrict the number of special events that could take place at night and on the weekends; + Restrict the number of cars that could come onto campus; ‘* Prohibit lights on the athletic field and ban the use of amplified sound or loud music outside with graduation as the sole exemption; and ‘© Prohibit outside use of the School’s facilities. Again, these conditions were not created because Archer was a school for girls; the conditions were, and are, necessary to preserve the residential character of Archer’s back lot. Moreover, Archer’s characterization of the conditions as “discriminatory” simply ignores the significant differences between itself and many other schools with which it compares itself. Those significant differences include the size of the School’s property, that many of those schools have been in the same location for decades and that none are in as close proximity to neighboring homes as is Archer, Archer's mythology also ignores that its Project includes facilities 750406 01-LACSRO2A - MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 7 significantly greater than those possessed by other schools, many of which are located on much larger properties.’. B. This Is Not About Equal Access A new chapter in the Archer mythology is that its Plan must be approved to provide its students with “equal access.” However, Archer’s use of a loaded phrase cannot withstand analysis for several reasons. First, Archer has been extremely successfull under the current CUP. Applications were at a record number last year and its graduates attend some of the finest universities in the country. Archer's argument that its success should not be “capped” is a red herring because it suggests that academic excellence (what Archer refers to euphemistically in its DIER response as “academic synergies”) somehow depends on having massive buildings constructed within 25 feet of residences and moving activities to the School’s back lot that were formerly conducted off campus. Archer’s 15 year track record proves that is not the case Importantly, Archer’s massive expansion Plan is not designed to alleviate some perceived shortage in programming. To the contrary, Archer has significant programs in performing arts, visual arts and athletics, including 24 different teams — twice the number Archer had in 2007, However, like most private schools, Archer conducts some of its activities off campus. Although Archer's athletic director claims that Archer’s teams were somehow disadvantaged because they had to travel by bus, that inconvenience simply places Archer on a “level playing field” with many of its peers. Marlborough, a highly regarded school for girls, plays soccer and softball off campus and buses team members to the offsite locations. Marymount, another private girls school, plays softball as well other sports, off campus, as does Crossroads, Sierra Canyon and Windward, the last three of which must accommodate teams for both girls and boys and are not located immediately adjacent 7 A related saga in the mythology Archer propagates is that it has been a “good neighbor” and that somehow it is now entitled to dismantle the protections put in place to preserve the neighborhood simply because the School generally abided by the conditions that allowed it to move into the neighborhood in the first instance. Archer has not been a “good neighbor,” however, because of some altruistic motivation. Archer has been a good neighbor because “good fences (the CUP) make for good neighbors” and that there is no extra credit for following the mutually negotiated and agreed upon rules. It is also worth noting that for years Archer was in violation of the CUP by using for School operations one of the residential houses it acquired, despite the CUP clearly defining the physical boundaries within which the School could operate. (See Tab 3, Letter from Eric Waxman dated October 9, 2012.) 152896 01-LACSRIZA- MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 8 to residences in close proximity, like Archer. Thus, Archer’s aggressive expansion is not about access; it is all about excess and convenience, all of which comes at the expense of the Schoo!’s neighbors. Although Archer parents were very quick to claim “it will not be that bad,” and that “the neighbors are over reacting,” those parents do not bear the burden of the massive expansion Archer “deserves.” Second, while several speakers decried students not having proper locker facilities, Archer has only itself to blame for that “lack of access.” From inception, the CUP has provided for Archer to construct a 12,000 square foot gymnasium, which because of its allowed seating capacity of 450 could also have served as a multipurpose facility. The site for that gymnasium was carefully selected to ensure a 75 foot setback from Chaparal so as to preclude an institutional building from invading the buffer zone established for Chaparal. (See Tab 2.) Archer could have easily satisfied this “basic need” for locker space and a gym by simply building that facility, which is also contemplated by Alternative 2. Archer's Board chose not to build the permitted facility and instead opted to acquire two private residences to lay the groundwork for the massive expansion it currently seeks, It is, therefore, not the CUP that deprives Archer’s students of appropriate locker facilities but rather the strategy employed by the School’s Board of Trustees. Finally, Archer’s aggressive expansion goes far beyond “equal access.” Many of Archer’s comparable peers do not have two gymnasiums and several do not, have performing art centers and instead make use of “black box” theaters. Rather than a reasonable expansion that would allow Archer to modernize its facilities while respecting its neighbors’ quality of life, the School has chosen to sacrifice the neighbors’ interests so that Archer can participate in the existing arms race amongst private schools to build the largest, most grand facilities, regardless of whether those facilities are appropriate to the location in which the schools reside. To supports its bigger is better “vision,” Archer proclaims that it “needs” the massive Project to offer a 21st century education for its students. According to Archer's construct, it cannot offer a first class educational experience unless the School is permitted to build all four new buildings it seeks ~ an additional 66,000 square feet. Apparently, the education needs of the 21st century also require Archer to gut the existing CUP and exponentially expand the intensity of use without regard to the effect on the neighborhood. As the chart below illustrates, those changes are both dramatic and wildly disproportionate to any reasonable improvement plan, such as that contemplated by Alternative 2 or the more generous proposal made by the Residential neighbors but rejected by Archer. 752896 01-LACSRO2A-MSWMs, Elva Nun-O'Donnell December 15, 2014 Page 9 ARCHER'S CURRENT USE UNDER THE CUP COMPARED TO ARCHER’S MODIFIED PLAN Physical Plant near ka One Main Building eas i One Main Building One Gym, Four New Buildings Total sq ft 84,178 150,203 North Wing Addition 300 Proposed buildings Gym 12,000 Multipurpose Facility (2 gyms) 39,300 | (sq ft) Maintenance Bldg 709 Performing Arts Center 19,025 | Visual Arts Center 7,400 | Setback of gym (from Chaparal property line) 75 feet 2S feet Total addi ‘ional square feet of 12,709 66,025 new buildings % Increase of physical plant 15% 18% (buildings only, not garage) Parking Spaces 109 185-251 ‘# of Athletic events on campus: 39 149 ‘# of Special events 47 86 Instructional Hours of operation Monday-Friday 7am to 6pm Monday-Saturday 7am to 6pm Rather than being about “equal access,” Archer’s contempt for the current CUP and its effort to ignore the reasons, which gave rise to those protections in the first instance (the need to protect and preserve the residential aracter of the neighborhood so that Archer’s neighbors can continue the quiet enjoyment of their homes) is unmistakable. Simply stated, while the scope of Archer's ambitions may have changed, the residential character of the neighborhood has not. C. Archer Has Not Compromised 752896 01-LACSRORA- MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 10 The final myth that analysis debunks is that “Archer has compromised.” Unfortunately, simply printing a slogan on a tee shirt does not make it so, and no ‘matter how frequently repeated, the facts prove otherwise. In an October 2, 2014 letter to the community (a copy of which is included as Tab 4), Councilman Bonin stated: “I cannot support a proposal unless dramatic changes are made.” At a meeting with various stakeholders, including Archer representatives, the Councilman made clear that his framework for looking at the Project is to “work from the current CUP on up” since the Project is in a “residential neighborhood in a complicated locale.” Councilman Bonin also identified certain deal breakers that had to be removed from the Plan before further negotiations could take place, including, among other things: (i) no lights on the athletic field; (ii) no outside use of the facilities; (iii) no aquatic center; and (iv) the maintenance of current traffic ‘management practices. While Archer did remove those deal breakers, all of those items were already prohibited by the current CUP or, in the case of traffic management practices, already required. The Councilman never indicated that was all that needed to be done by Archer to satisfy the requirement for “dramatic changes” was for the School to take off of its wish list items that Archer was never entitled to in the first instance. To find that tactics a “compromise” would simply further encourage the gamesmanship that so many applicants employ of requesting items for which they know approval will not be granted so they can be later surrendered under a claim of “compromise.” That is precisely the ploy Archer has engaged in here and it should not be allowed to succeed. When you look at how Archer has responded to the Councilman’s direction that Archer reduce the physical size of the Project and its proposed intensity of use, Archer has made only modest changes that can hardly be considered a true concession or compromise. To demonstrate the absence of any real compromise, set forth below is each area about which Councilman Bonin expressed concern and Archer's response and the reasons it does not represent a true compromise: 1, “Reduce the overall square footage of the Project” (Bonin 10/2/14 Community Letter) Of the original 167,400 square feet Archer originally proposed for its multipurpose facility, performing arts center, parking garage and visual arts center, the School has offered to reduce its physical plant only 10%. Accordingly, Archer's physical plant would inerease from its current 84,178 square feet to over 150,000 square feet ~ a gigantic increase of 78%, not including the garage. Given that the current CUP only allows for a 15% increase in the size of Archer's physical plant, Archer's 10% reduction from an excessive starting point is hardly a compromise. 15299601-LACSRO2A - MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 11 2. “Reduce the massing width and length of the multipurpose gym facility” (Id.) * Archer currently proposes a two-story, 39,300 sq. ft. multipurpose gym facility, only a 5% reduction from Archer's original proposal, and set back a mere 25 feet from the Chaparal property line. © This “compromise” is three times larger than the one story, 12,000 sq. ft. gym allowed in the current CUP that must be set back 75 feet from the Chaparal property line. Archer's claim about increasing open space is misleading because the overwhelming majority of current open space is the buffer from Chaparal provided by the Athletic Field. Archer's so called “compromise” invades this buffer by placing the 39,300 sq fi, multipurpose facility and Its 19,025. sq. ft. performing arts center within 25 feet from Chaparal, eradicating the existing buffer between residences and institutional buildings. 3. “Expedite the construction schedule” (Id. © Archer has “compromised” reducing the scheduled construi ‘one year from six years as proposed to five years; mn by only ‘Archer calls this schedule expedited, which must mean the 405 project ‘was super expedited as it took four years — one year less than the schedule prepared by Archer. Archer has no satisfactory explanation as to why its Project should take five years and a one-year reduction is not a compromise to a community that just suffered through four years of the 405 project. Moreover, Archer proposes construction on Sundays, therefore creating “expedition” only through further burdens on its neighbors, not by reducing the scope of its Project, which is what a true compromise requires. 4, Reduce the construction and excavation impacts” (Id.) ‘* Aslight reduction of only 10% from the original proposal of 98,595 cubic yards, 8,963 truck hauls for 90 days is not a compromi * The amount of excavation for Archer’s current proposal would still be substantial © 87,798 cubic yards © 7,982 truck hauls for removalMs. Elva Nun-O'Donnell December 15, 2014 Page 12 © 80 days of hauling ‘Under Archer’s current modified plan, thousands of extra-large slow moving trucks will exit onto Sunset Blvd. Monday through Friday from 7 am to 3 pm and Saturdays 8 am to 6 pm from a non-signalized driveway This is not a compromise anyone using Sunset Boulevard can survive, “Reduce the size of the garage to reduce the traffic that can come fo the school” (Id. Archer originally proposed 212 parking spaces/expanded to 282 parking spaces; Archer currently proposes a modest reduction to 185 parking spaces but then wants to substantially expand that capacity through stack parking of up to 251 parking spaces; Current CUP allows 109 cars to park above ground on campus; Proposed underground garage would increase the number of cars entering and exiting via Sunset Blvd. at a non-signalized driveway. © 70% during daily operations (76 more cars coming and going during the day) 130% for special events on weeknights and on the weekends (150 additional cars) This reduction is insufficient as even Archer’s FEIR admits that the School's daily parking needs are only 143 spaces. This is just another example of Archer calling back on an inflated ask and call that a “compromise.” “Reduce the number of school functions and events” (Id.) Archer has reduced the 98 special events originally proposed by only 10 events; 86 events is an 83% increase over the currently allowed 47 events; 86 special events on campus will double the number of visitors allowed to 21,450 and increase the number of events with attendance of more than 200-800 guests from the current 9 events to 37; 152886 0/-LACSROZA MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 13, Once again, Archer is simply following its standard playbook — inflate your original ask and then offer a slight reduetion and call it a “compromise.” 7. “Strietly limit th ‘* Archer proposes increasing the number of athletic events on campus from the current 39 to 149, three times as many events as they hold now; * Archer’s proposal to eliminate all school and athletic events starting between 4:30 pm and 6 pm and the potential of simultaneous special events and athletic events occurring on campus after schoo! during peak traffic hours; + As Councilman Bonin stated in a meeting with the stakeholders in September, moving traffic to weeknights and weekends is not a solution, since it puts the burden on the neighbors as events are moved into later peak traffic congestion. I. CONCLUSION Archer's Plan is not about access, it is about excess. Archer’s Modified Plan is not a compromise and offers no meaningful concessions. The “Modified” Plan is still enormous and includes: ‘© 150,000 square feet of new constructions «Four new buildings ‘* Five years of constructions * 150 more athletic and special events * 30-day summer school for 350 students ‘© 30,000 more visitors to the campus ‘* Extended hours of operation at night and on Saturdays ‘© 70-130 more cars entering and exiting the campus daily © Significant impacts from noise and traffic In stark contrast, the Residential Neighbors offered Archer a true compromise, including: (i) a generous increase in physical size (44%); (ii) an underground garage with more than enough parking to meet their daily operational needs (a 37% inerease over the current parking); and (iii) a two-three year construction schedule from inception to completion. That reasonable proposal lessened (but did not eliminate) the impacts on the neighbors while at the same time 752896 01-LACSRO2A - MSWMs. Elva Nun-O'Donnell December 15, 2014 Page 14 allowing a significant upgrade to Archer’s facilities. Archer rejected that generous proposal because as stated by the School’s Head of Operations: “The School wants what it wants.” That refusal leaves Alternative 2 as the only Plan that will not have significant impact on Archer's neighbors and the community at large. That Alternative will allow Archer to modernize its classrooms through the North Wing renovation and construct a gym/multipurpose center. By approving that Alternative, the Planning Department preserves the delicate balance described by Mr. Green and encourages the School to consider a real compromise rather than simply making modest reductions to a widely inflated Plan, Yours very truly, Eric S. Waxman Residential Neighbors of Archer cc: The Honorable Councilman Mike Bonin 752496 01-LACSRO2A - MSW