A Ted Fikre Vice Chairman Chief Legal and Development Officer March 16, 2015 Mayor Jim Dear City of Carson 701 B. Carson Street Carson, California 90745 Re: Stadium Initiative Honorable Mayor Dear: As you know, AEG developed, owns and operate: the StubHub Center in the City of Carson. We take pride in the great relationship we have developed over the past 15 years with the community and the City. We are also proud of the wide variety of sports and entertainment events and activities that we host at StubHub Center, where over 1,000,000 fans visit the complex each year and approximately 4,000 athletes compete on-site annually. Our LA Galaxy have played over 200 games since the opening of the StubHub Center and, with four championships during that period, have established themselves as the preeminent soccer team in the United States. The StubHub Center hosts a wide range of events every year, including not only soccer matches, but tennis, cycling, boxing, football, track, rugby, concerts, community events, and film, television and commercial shoots. In addition, training activities are conducted at this facility throughout the year, with numerous organizations, including the USOC, USTA, US Soccer and US Cyeling all utilizing facilities at StubHub Center for regular training. With the hundreds of millions of capital invested in the StubHub Center and with these significant on- going businesses at that facility, we are among the biggest investors and business stakeholders in the City of Carson. That is why the prospect of an NFL stadium nearby, although potentially exciting, is of great concern to us. As you consider the issues, obstacles and opportunities for the City with a potential football stadium, we trust that you and other City leaders will be mindful of ensuring the continued success of the StubHub Center and the Galaxy. We are writing both out of concem for ongoing operations of our businesses in Carson and to express our public policy concems from the perspective of a leading corporate stakeholder in Carson, In our experience of owning, operating and consulting on more than 100 of the preeminent venues in the world, we have found that the design, construction and operation of our projects have benefited from thorough public review and community engagement. We are deeply concerned that the announced stadium initiative in Carson, which on its face is similar to the one recently concluded in Inglewood for a rival project, is deeply flawed because it results in 800 West Olympic Bivd., Suite 305 * Los Angeles, CA 90015 * p. (213) 742-7115 « f. (213) 763-7711Mayor Jim Dear March 16, 2015 Page 2 of 6 none of the public input and community engagement that normal land use development requires. Frankly, we think this process is an open invitation to litigation. Rather than simply trying to endure the minimum process, or avoid a public process altogether, as was the case in Inglewood and as appears to be the manner in which the Carson stadium proposal is proceeding, we chose to embrace full public review, as well as public dialogue and community agreement on benefits with respect to the projects we have pursued. AEG prepared a full Environmental Impact Report (“EIR”) in Carson. In Los Angeles, separate EIRs were prepared for STAPLES Center, L.A. Live and the proposed Convention and Event Center Project Just as with L.A. Live before it, the process by which we sought to develop a stadium in downtown Los Angeles is regarded as a model for working with the community to jointly craft a range of benefits that would ensure the community we serve will be a better place by virtue of completion of the project. The Community Benefits Program for our downtown site would have provided many millions of dollars for a wide range of benefits, including living wage jobs and job training, parks, neighborhood protection and improvement, and affordable housing to name a few. In addition, our downtown project contemplated major offsite infrastructure improvements and numerous mitigation measures resulting in tens of millions of dollars of investment that ‘would have benefited the public. Finally, the robust and transparent public approval process that our project went through ensured financial terms that were fair to the City of Los Angeles and allowed for a broad representation of potentially impacted constituents to have a voice and have their concerns addressed. ‘The proposed ballot initiative to build an NFL football stadium approximately two miles from the StubHub Center would involve numerous environmental and operational impacts. In addition to a stadium of up to 75,000 seats, the proposed initiative would allow for 850,000 square feet of a wide range of commercial developments including restaurants, bars, offices, theaters, heliports, and television and movie studios. Further, a hotel of up 350 rooms would be allowed. The initiative also authorizes a massive signage program of well over 120,000 sq. ft. which is equivalent to 100 billboards. With all of these components it is more than just a stadium; it is a mega-project. It would be one thing if the impacts on StubHub Center, Carson and surrounding neighborhoods in general were to be fully analyzed in an EIR where the analyses and conclusions would be subject to public review and scrutiny. But it is entirely unacceptable for a massive development project such as this one, with a fifty-year life span, to short cut the environmental and public review process entirely by use of the proposed initiativeMayor Jim Dear March 16, 2015 Page 3 of 6 When StubHub Center was proposed, AEG had to prepare an EIR which provided in- depth analysis of thirteen different impact areas, including traffic and parking, noise, air quality from automobiles, light and glare and publie services, The current proposed stadium would have almost three times the seating capacity of StubHub Center in addition to substantial collateral commercial development, and yet, it would not be subject to any public review. We do not have the benefit of any real details of the Carson development project—the type of details that come to light in the preparation of an EIR. In fact, a development plan is not required until prior to construction and then the proposed initiative purports to deprive the City of any meaningful right to review the appropriateness of the site planning and design. That said, even at a cursory level it is obvious that this massive project would have the following types of impacts and involve the following types of issues: Traffic, Major events will generate in the range of 20,000 ~ 25,000 trips to and from the stadium. This will have impacts on the freeways and the areas surrounding the stadium. The freeways serving the project will include the 405, the 110 and the 91, all of which carry a substantial amount of regional and sub-regional traffic. There are, however, only a limited number of freeway ramps (Del Amo Blvd. on 110, Avalon Blvd. on 405 and Avalon Blvd. and Main St. on 91) that could serve proposed stadium traffic. Similarly, there are a limited number of arterials (Del Amo, Avalon and Main) that could serve stadium traffic ‘These streets and freeways ramps currently serve a diverse range of land uses in the area including the South Bay Pavilion Mall, the Victoria Golf Course, the StubHub Center, Cal State University Dominguez Hills, numerous residential neighborhoods, and numerous commercial /industrial centers. Many of these uses are served directly by Avalon Boulevard and the ramps at the 405 and 91, and would therefore likely be affected by any stadium traffic The operational impacts of stadium traffic on all of these facilities, particularly on the Avalon Boulevard corridor and its freeway ramps, should be studied and measures developed to mitigate any potential impacts. It is important to note in this regard that there is substantial overlap with the MLS and NFL seasons and NFL games are played at the same or similar times as the Galaxy currently play at StubHub Center. Other stadium events such as concerts could be scheduled at times that conflict with the Galaxy or other StubHub Center events. Therefore, it is likely that a number of times each year there will be simultaneous events at the stadium that conflict with long-established operations at StubHub Center. Given that no analysis is provided in the proposed initiative for any issue, traffic or otherwise,Mayor Jim Dear March 16, 2015 Page 4 of 6 obviously there is no analysis for simultaneous events. These impacts must be fully analyzed and publicly reviewed. While the stadium developer chose so-called “environmental measures” it proposed with the initiative, no event coordination measures were proposed. We would also expect that a potential stadium would prepare a comprehensive Transportation Management Plan to address traffic operations for events, including measures to mitigate traffic impacts, and measures to work cooperatively with the StubHub Center with respect to sporting events and concerts on a year-round basis, as ‘well as to accommodate the needs of CSUDH — a major educational facility. Such a plan should also address ways to reduce and minimize auto trips, not only to address traffic impacts but also air quality impacts and sustainability issues, Parking. Given the location of the proposed project, the vast majority of trips would be by passenger automobile. Parking demand for stadium events alone would be at least 20,000 spaces. However, the proposal only requires a minimum of 10,000 spaces—for the stadium and all other development combined. The proposed initiative authorizes off- site parking but does not identify where this huge gap could or would be met, The failure to provide all parking on-site has the very real potential of creating severe impacts on residential neighborhoods and commercial businesses. As with traffic, conflicting events at the stadium could impact StubHub Center parking. Public Services. There is no analysis on the demand the stadium would create on police, fire and EMT services. Further, conflicting events at the stadium during StubHub Center events would further impact public services. No coordination measures were provided in the proposed initiative for simultaneous events. Signage. The initiative provides a huge volume of allowable signage, including the equivalent of 100 billboards. Further, six Electronic Message Centers are allowed, half of which would be adjacent to the surrounding area with the other half oriented to the 405 Freeway. The Electronic Message Center signs could be five and six stories high, The light intensity allowed would be among the brightest signs in the region. Signage on the stadium itself would not be limited in size and would not count against the already huge volume of 120,000 square feet of other signs. The vast majority of the signage could be off-site outdoor advertising, possibly adjacent to residential areas. Development Standards. ‘The proposed initiative requires extremely limited setbacks and allows heights of 300 feet for the stadium, 200 feet for the hotel and 75 feet for the rest of the large scale development. Development and Signage Plans. The initiative deprives the City and the public of any meaningful review of the currently undisclosed development and signage plans, WhileMayor Jim Dear March 16, 2015 Page 5 of 6 the developer would have to submit plans, the City would be powerless to impose conditions and only the developer has the right to appeal staff"s review of such plans. This only adds insult to the injury of no review under CEQA. Geology, Hazardous Materials and Water Quality. The proposed project would be located on a closed landfill site. By its very location and the nature of the site, the project would create and be subject to risks. There is no analysis of required remediation ‘measures or how any remediation would be coordinated with development of the project. Just about the only thing the proposed initiative makes clear is that the City and the successor Redevelopment Agency are not relieved of any obligation for clean-up funding. ir Quality. Various “environmental measures” are provided in the initiative, but there is no analysis to determine air quality impact. Further, unlike AEGs downtown project that would have been subject to a goal of having the lowest passenger trip ratio in the NFL and a requirement of carbon neutrality, no remotely similar measures are provided in the initiative. Noise. The proposed initiative provides no analysis or even explanation of the special rules, exemptions and measures it creates for noise, Light and Glare, Similarly, the initiative provides no analysis or explanation of the special rules, exemptions and measures it ereates for light and glare from stadium and other operations. Other Environmental Issues. In the EIRs which AEG has prepared, other environmental impact areas analyzed included Recreation, Land Use, Aesthetics, Employment, Population and Housing, and Utilities—as well as other issues specific to those projects. The City and the public will be kept in the dark on these issues, as well as all of the other issues noted above. With the proposed initiative, there is no review under CEQA, no public process, and no public dialogue about the types of benefits provided by other large scale projects such as the ones AEG has developed through a thorough and transparent public process involving extensive community input. We have a very substantial investment in Carson which will be placed at risk if'a loophole is exploited to avoid and evade the protections described above. We are aware of the legal basis for developers to utilize the initiative process to circumvent the well-developed CEQA process whereby community stakeholders have the opportunity to comment on and influence major land use development projects. We question the soundness of this legal reasoning in circumstances where, as in Carson and in Inglewood, immediately surrounding communities are obviously impacted and have no opportunity forMayor Jim Dear March 16, 2015 Page 6 of 6 ‘comment or community involvement. ‘The absence of an opportunity for all stakeholders in surrounding communities to have meaningful input, merely because of the territorial boundary of a city where an initiative is pursued, is an open invitation to litigation from affected stakeholders outside of Carson, The Carson City Couneil cannot stop the developer and its paid petition drive. However, there are several things the Council can and, we respectfully urge, should do, First, the Couneil can require a meaningful, independent review of the impacts of the proposed project, as allowed under the Elections Code. It should initiate this effort immediately to ensure the opportunity for public review and input. Council should insist that this process in fact provide all stakeholders in the region, not just in Carson, with the full equivalent of a CEQA process. Unlike Inglewood, the City should select its own experts rather than using the developer’s consultant team to regurgitate secret reports the developer had previously prepared. Further, while the law may allow the Council to adopt the measure without a vote of the people, it should let the people decide. Just because the Council has the right to bypass the people, it doesn’t make it right to take that huge short-cut. We look forward to the opportunity to work with you in the coming weeks and months to ensure that StubHub Center and the community are protected in the event the proposed project moves forward. Very truly yours, = Ted Fikre Ce: Mayor Pro Tempore Elito Santarina Council Member Lula Davis-Holmes Council Member Albert Robles ‘Acting City Manager Ceeil Rhambo