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Preliminary Report: Space 134 Project Implementation, Operation & Economic Benefits

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A preliminary analysis of the possibilities for implementing and operating the proposed Space134 cap park project, as well as the project’s potential economic benefits.

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Preliminary Report: Space 134 Project Implementation, Operation & Economic Benefits

  1. 1. HR&A Advisors, Inc. | Los Angeles | New York | Dallas | Washington, D.C. Memorandum To: Alan Loomis, The City of Glendale Cc: Amber Hawkes, Melendrez From: HR&A Advisors, Inc. Date: December 18, 2015 Re: Conclusions on the Funding, Operation and Implementation of Space 134 HR&A Advisors, Inc. (“HR&A”) has, in collaboration with Melendrez and as part of a multidisciplinary team, prepared a preliminary analysis of the possibilities for implementing and operating the proposed Space 134 cap park project, as well as the project’s potential economic benefits. To help the City of Glendale (“City” or “Glendale”) in continuing its efforts toward implementing Space 134, HR&A has summarized these analyses and identified a series of next steps. This memo provides a summary of:  The range of economic and social benefits that the new park could generate;  HR&A’s preliminary assessment of capital and operational funding strategies for the proposed Space 134 cap park based on national precedents and best practices;  Findings from HR&A’s preliminary operating model for the park prepared as part of separate scope of work and based on an illustrative park program; and  A series of best practices for the implementation, governance and continued success of the park as identified through HR&A’s precedent research. A Cap Park – A Wide Range of Benefits Glendale has the potential to dramatically transform its Downtown, re-stitching its urban fabric by creating much-needed active open space over the 134 Freeway which currently bisects the city. Space 134 will have a wide range of benefits for local and regional stakeholders, which Glendale should actively promote to rally support for the project, and which as discussed below, will be critical to the success of the park. These benefits include:  New open space on previously unusable land, which will physically and psychologically re-connect North Glendale with Downtown, repairing the divide created by the 134 Freeway. This green, open space will have a range of benefits, including promoting active lifestyles to improve public health, reducing pollution and runoff, enhancing air quality and encouraging biodiversity.  Increased visibility for Glendale and expanded visitation, which will rely on regular park programming, including major events that will attract new visitors to Glendale, increase how long they stay Downtown, and encourage repeat visits. New foot traffic to Downtown will support local
  2. 2. HR&A ADVISORS, INC. Space 134 Implementation Conclusions | 2 businesses through increased spending. The signature park significantly will enhance Glendale’s brand, further enabling the City to compete regionally to attract new employees and residents.  Creating a regional amenity and destination with a highly amenitized and programmed, world- class park, which could become a major attraction for out of town tourists visiting Southern California, significantly increasing their length of stay and likelihood to return. The park, augmented by new transit options proposed to be incorporated into Space 134, will serve the open space and gathering needs of a diverse cross-section of the regional population.  Value creation on a large and broad scale, benefiting property owners, businesses, the City of Glendale and the County of Los Angeles. Properties nearby and adjacent to the site are likely to see a significant positive affect on property values, and as demonstrated by successful park projects across the country, this may catalyze real estate development opportunities on currently underutilized properties near the freeway. Value created through appreciation and new opportunities will benefit property owners and the private sector, the fiscal benefits of which may be harnessed through an increased tax base, and reinvested via targeted value capture tools like Enhanced Infrastructure Financing Districts, as discussed in detail below. There may also be the potential to unlock real estate opportunities within the public right-of-way used to create Space 134, which could generate significant revenue that could be re-invested into the park in partnership with Caltrans. As noted before, increased visitation and spending will benefit Glendale’s businesses, generating sales tax to support City and County services. Building Space 134 – Requires Partnerships at Multiple Levels Cap parks are not a new phenomenon, as evidenced by the more than 20 examples across the country. However, there are few examples that have successfully managed to achieve all of the potential benefits described above. Many cap park projects are implemented by State or Regional transportation agencies with non-local resources, collaborating loosely with municipal governments to build freeway caps in order to mitigate the negative impacts of existing or new freeways. These projects, while well-intentioned, often focus on building the ‘cap’ infrastructure, with little emphasis on the ‘park’ component and are typically the result of resource limitations or the priorities of the implementing entities. The more successful cap parks have been conceived in an integrated fashion where project proponents have emphasized the allocation of adequate resources to deliver high-quality urban amenities, parks and connections that sit atop the cap. A fully integrated project may increase up front project costs, but is more likely to unlock the full transformative potential of a cap park. National case studies show that successful cap park projects are often conceived locally by coalitions of community groups and other private sector stakeholders, in conjunction with municipal government, but implemented in partnership with regional, State and Federal resources. Engaging these groups of stakeholders in the community and broader region and elected officials at the state or federal level will be critical to the success of the project. Furthermore, proactive coordination with relevant jurisdictions and other agencies early on will be necessary to understand their issues with the project, especially Caltrans, which controls the right of way in question, the County of Los Angeles and Metro who can be potential stewards of the project in addition to the City. Lessons from HR&A’s national precedent research, along with HR&A’s independent analysis of the funding capacity for Space 134 from a series of
  3. 3. HR&A ADVISORS, INC. Space 134 Implementation Conclusions | 3 relevant funding sources, are summarized in this memorandum. A table identifying key precedent projects that HR&A evaluated is included below. Phasing Given the scale of Space 134, which is proposed to stretch roughly seven-tenths of a mile from Central Avenue to Balboa Avenue, it is appropriate to envision the project as a series of successive phases. The scale of each phase will have to be aligned with the availability of resources, but should also create a critical mass of activity to pave the way for future success. An initial phase should be of large enough scale and program intensity to demonstrate the benefits of the cap park to community, regional and other stakeholders. If the first phase is successful, the project could attract and justify funding for subsequent phases. It is important to note that while construction costs are tied to the overall scale of the project, the project’s ability to attract funding from a broader base of sources will depend upon its ability to demonstrate value to a wider constituency. As such, an optimized first phase could reduce the need for construction funding, but if it can add value as a regional asset, it will still be better positioned to draw from a variety of resources. The project team and the City have proposed an initial phase comprised of a 4.3-acre cap, stretching from Central Avenue to Brand Boulevard (“Phase 1”), and would be the westernmost component of the full park, which may stretch from Central Avenue to Balboa Avenue, totaling 24 acres at completion (“Full build-out”). Construction Costs In similar cap park projects with dynamic and highly-programmed open spaces, HR&A has found that total construction costs are split almost evenly between the deck infrastructure and the park on top, with total costs ranging from $15 to $25 million per acre. This may vary based on specific conditions of each project: Klyde Warren Park, a 5.2-acre cap park in Dallas, Texas that is highly-programmed and generally regarded to be one of the most successful recently completed cap parks, cost roughly $110 million in 2010 (roughly $120 million in 2015 dollars). Of this, total, $31 million was used to construct the park, with an additional $27 million dedicated to the creation of amenities, programming and an operational endowment. Based on Melendrez’ preliminary design, an initial cost analysis performed by Cumming estimates that the cap infrastructure portion of Phase 1 of the park will cost about $140 million in 2015 dollars, with additional costs to be incurred for park improvements. Based on these estimates and the cost of Klyde Warren Park’s park improvements, total Phase I costs may be as much as $170 million. Park Location Acreage Year Built Capital Cost ($ 2015 M) Operating Cost ($ 2015 M) Cap. Cost/Ac. ($ 2015 M) Op. Cost/Ac. ($ 2015 000s) Klyde Warren Park Dallas, TX 5 2012 $120 $3.9 $23.5 $765 Millennium Park Chicago, IL 21 2010 $570 $16.8 $27.7 $815 Rose Kennedy Greenway Boston, MA 30 2004 $500 $4.6 $17.0 $155 Hance Park Phoenix, AZ 32 1992 $190 $2.0 $6.1 $60 Source: HR&A Advisors, Inc. Precedent Cap Park Projects
  4. 4. HR&A ADVISORS, INC. Space 134 Implementation Conclusions | 4 Layered Resources The successful development of Space 134 will require the City to leverage a wide range of resources to support the significant capital costs associated with the construction of the park and to ensure that planning and construction are closely aligned with the anticipated availability of financial resources, and with the priorities of the funding entities. A majority of project funding for the cap infrastructure is often derived from non-local resources in partnership with State and Federal agencies, while funds to build and operate the park and other urban amenities that sit atop the cap rely largely on a variety of local resources. Developing a blended funding approach to meet capital needs will require rallying both public- and private-sector support, as well as exploring public-private partnerships to capture value created by the new park. Public and Public-Private Funding Funds for the deck structure will have to rely on a wide variety of public sources, but will require extensive grassroots efforts to demonstrate Space 134’s wide-ranging community impacts in Sacramento and Washington, DC. Cap parks are not yet a transportation priority and capturing significant amounts of funds will require a proactive policy shift in state and regional agencies, making advocacy and education on the benefits of the project become ever more important. While local public funding sources are limited, especially after the dissolution of Redevelopment Agencies in California and the related Tax Increment Financing authority, there are a number of new and existing tools that could enable the City to capture future value created by the project to support a portion of capital construction costs. Often, cities will use these techniques to minimize taxpayer burden for ongoing bond debt service by leveraging new, infrastructure-attributable land value. Glendale has a number of tools and resources that it can take advantage of including: Deck Infrastructure Costs and Funding Park Construction Costs and Funding Source: HR&A Advisors, Inc.
  5. 5. HR&A ADVISORS, INC. Space 134 Implementation Conclusions | 5 Local Resources  An Enhanced Infrastructure Financing District (“EIFD”) which could capture and bond against the incremental tax revenue generated by new development and increased values of existing, nearby development related to Space 134. EIFD is a new funding tool authorized by California Senate Bill No. 628 and can include a wide array of tax and non-tax revenues; these funding sources can be used to repay bonds for up to 45 years from the date of the issuance. EIFDs allow bundling of incremental property tax revenue, which can be included in an EIFD, net of moneys payable to school districts or educational funds, but only with approval from relevant taxing authorities. This could limit revenue to the City’s share of the 1% property tax, but could be significant if an agreement is reached with the County of Los Angeles to contribute its share of property taxes. To issue EIFD bonds, 55 percent of voters voting on the proposition (who are registered to vote within the EIFD boundaries) must vote to approve the EIFD, unless less than 12 persons are registered to vote in the EIFD, in which case a vote is held by landowners with one vote given per acre, which sets a lower bar than previous IFDs which required the vote of two-thirds of property owners. EIFD formation requires that Cities that had created redevelopment agencies have received a finding of completion from the state and have complied with all requirements from the State Department of Finance and the State Controller’s office. HR&A tested the potential development capacity within ¼ mile of the full build-out of Space 134 (as a potential EIFD boundary) and found that the value of new development and incremental value of existing properties around the park could surpass $2 billion (all figures in 2015 dollars) by 2035, which could generate around $11 million in new property tax to the City and County of Los Angeles. If the County were to contribute their share of property tax revenue, an EIFD could support around $95 million in capital funding; if property tax revenue was limited to the City’s share, an EIFD could only fund around $25 million in capital costs. HR&A’s high-level estimates did not account for the possible implications of a phased development of Space 134, and more precise estimates would require further analysis. To implement an EIFD, the City would need to identify and execute a public outreach strategy to gauge voter support and to clarify that similar to other recent bonds, implementing an EIFD would not involve new or increased taxes.  Park Impact Fees from the development of new residential units around Space 134, which could support as much as $80 million for park capital funding over the next 20 years per HR&A’s preliminary estimates, assuming that the City’s Park Mitigation Fee is held at the same level, and that residential development in Glendale continues at a steady pace.  Infrastructure Financing Districts and Special Assessment Districts which are authorized by state law to create a particular and distinct benefit and require a majority vote of property owners within the specific district. These would require new assessments, which must be proportional to a specific benefit conferred on each parcel and become liens on each property. These districts are often used to support debt to pay for specific improvements, but typically come at a greater cost than a general obligation or revenue bond. These districts can benefit the City by transferring risk to property owners.
  6. 6. HR&A ADVISORS, INC. Space 134 Implementation Conclusions | 6 Other Resources  Other Transportation Funding which could be especially well-leveraged by the inclusion of an Bus Rapid Transit and/or potential future Light Rail Transit tine along the 134 Freeway, which would support multi-modal connectivity between Downtown Glendale and regional destinations. An integrated transportation node and park design with shared capital programs could unlock federal and State transportation funding sources, which are a key source of grant funding available to support a variety of transit, mobility and transportation projects and are awarded on an annual basis. Transportation funding can be used to support streetscape improvements, bus facility improvements, bike lanes and bike trails, and public gathering places.  State Cap and Trade Funds, which are distributed through a program that limits greenhouse gas emissions in California. The rights to produce such emissions are permitted to be traded, with auction proceeds of state allowances appropriated through the annual budget to a range of programs and projects. Roughly 20 percent of funding is dedicated to “Affordable Housing and Sustainable Communities” and is distributed by the Strategic Growth Council. In the current 2014-2015 budget, this amounted to $130 million, a figure that could more than double in coming years. Space 134 could be well-positioned to capture a portion of these funds, especially with the inclusion of a transit component, as this pool of funding is intended to provide support to projects that encourage walking, biking and transit ridership and local planning efforts that reduce greenhouse gas emissions. Other funds specifically target the development of transit infrastructure and could fund BRT and/or LRT construction.  Other Tools, which require further study include a Community Facilities District, or a range of public funding sources such as Long Term Debt Financing Techniques like Voter Propositions and General Obligation Bonds and Special Taxes, each of which would require voter approval and would involve net new taxes or assessments. State and Federal Programs such as USDOT Discretionary Grants (TIGER) could provide one-time grant funding for capital costs, and have proven to be an important component of construction of some cap parks, including Klyde Warren Park. Philanthropic Funding Historically, deck parks and other signature parks have attracted significant corporate and individual donations; this philanthropic funding has been used not only to cover a portion of capital costs, but also to create an operating endowment to cover annual operations and maintenance. Philanthropy, as in the case of Klyde Warren Park, can kick-start the park development process, and will be an essential resource to creating a high- quality park, as there are limited sources of public funds for open space improvements. Both Klyde Warren Park and Millennium Park in Chicago raised over 75 percent of park (not including deck infrastructure) construction costs through private donations, which supported the creation of unusually dynamic, engaging and highly-programmed parks. While the Los Angeles region has a significant philanthropic community and capacity for giving, there are a large number of major projects and initiatives that could compete for contributions. Actual fundraising amounts are likely to vary based upon the organizational capacity of park supporters; typically, independent non-profits are better equipped to attract philanthropic funds than city departments. HR&A developed an estimate of philanthropic funding capacity for Space 134 using a range of metrics and methodologies, including an evaluation of precedent projects, city size and wealth, local fundraising history and
  7. 7. HR&A ADVISORS, INC. Space 134 Implementation Conclusions | 7 corporate community potential. Compared to other cities, including those with built or planned deck parks, Glendale is relatively small and has few households that are in the top 5 percent of national incomes and are likely to have major philanthropic capacity. HR&A estimates that Space 134 could raise up to $60 million over a series of three, five-year campaigns, each aligned with a phase of construction. This figure is based on Los Angeles area average personal contributions, and assumes the capture of a share of Glendale, Burbank and Pasadena residents’ annual giving. It is important to note that there are likely to be significant overlaps between corporate and private giving, and Glendale is home to a number of major corporate and business stakeholders with regional, national and international presences. Additional philanthropic potential could be captured through naming rights opportunities for the entire park or individual elements and on an ongoing basis through event or programming series sponsorship. Corporate donations have been a significant source of funding for cap parks, notably Klyde Warren Park where the park’s naming rights amounted to over $5 million. At Millennium Park, $220 million in private and corporate donations funded specific, named park elements like pavilions and amphitheaters that have contributed to the project’s success, including a $25 million commitment to support the creation of a capital and operating endowment. Long Term Success is Defined by a Sound Operation & Management Strategy1 Highly-programmed, signature downtown parks require significant annual operating funding, ranging from $250,000-$750,000 per acre, and while these parks also have opportunities to earn revenue, income rarely exceeds 20 to 30 percent of total expenses. As such, these parks require funding from a layered set of resources with both public- and private-sector support, as well as an operating entity capable of efficiently handling income generation, management and operations. To estimate ongoing operational funding needs and earned income potential, HR&A, as part of a separate scope of work, prepared a preliminary operating model for Space 134. It is important to note that this was not based on a detailed market study on the viability or economic performance of the individual program elements, but based on benchmarks with limited local market adjustments. Based on Melendrez’ existing program, expenses for the first phase of Space 134 are likely to be relatively high on a per-acre basis because the first five acres are expected to be the most highly-programmed part of the park. Typically, smaller, highly-programmed parks have higher operational costs on a per-acre basis, which decline for larger parks with more passive space, as shown in the above figure. 1 Yerba Buena Gardens, Discovery Green and Brooklyn Bridge Park are all new, highly-programmed American parks. Yerba Buena was built in 1993 in San Francisco, and includes cafes, lawns and public art; Discovery Green was opened in Houston in 2008, and includes bandstands, a lake, parking garage and open space; the first phase of Brooklyn Bridge Park opened in New York City in 2010 and now includes active and passive recreation spaces, restaurants, and a revenue-generating real estate component. Source: HR&A Advisors, Inc. Park Operational Costs per Acre1
  8. 8. HR&A ADVISORS, INC. Space 134 Implementation Conclusions | 8 Operating Costs In order to estimate expenses, HR&A conducted a detailed review of the expense profiles of comparable signature parks across the country. Phase 1 of Space 134 is likely to incur annual operational costs of between $600,000 and $700,000 per acre in 2015 dollars, for a total of between $3 and $3.5 million annually. This figure is benchmarked against the annual operating cost of smaller, highly-programmed parks like Klyde Warren Park or Yerba Buena Gardens which have similar program elements to the proposed Space 134. At full build-out, total annual operational cost may be as much as $9.5 million or higher in today’s dollars. Earned Revenues and Other Funding Sources The long-term sustainability of Space 134 will require significant operating resources, which may mean a public- private partnership and continued City support from discretionary or dedicated funds. There are a range of funding sources which may be available to support the ongoing operations and maintenance of Space 134, including:  Earned Revenue, including active park elements like cafes and spaces for events can support up to 30 percent of operating costs in professionally managed, highly-programmed parks. Although these can generate ongoing revenue, it will be important to balance active elements with non-commercial community-serving park spaces that are open to public at all times. HR&A estimated the revenue capacity for the programming elements based on Melendrez’ preliminary design, which are composed of four primary sources: programs and event spaces, a restaurant, a café, and a food truck court with independent operators. Programming and events are expected to generate the greatest portion of on- site revenue, and could include small or large private events (i.e., ticketed shows, social events and weddings, or corporate events), small or large public events (i.e., fitness, local music, food festivals, markets, or large street fairs), and “mega-events” (i.e., sponsored festivals, major concerts, and events that fill the entire park). The combination of these primary sources of revenue could generate as much as $800,000 annually for Phase 1, a figure that is unlikely to grow significantly through full build-out of the park, as revenue is likely to be generated primarily in the highly-programmed, initial portion.  A Maintenance District, which is authorized by state law to create a particular and distinct benefit, require a majority vote of property owners within the specific district, and would involve new assessments. A maintenance district could raise an estimated total of $600,000 to $1.5 million annually, assuming a modest assessment of $200 per residential unit annually on properties within ¼ mile of the park.  Ongoing Membership Revenues, could support ongoing operations or bolster an endowment during construction to sustain park operations in early years as revenues stabilize. Space 134 could pursue broad support through membership into a “friends of” group, as in the case of the High Line Park in New York, which generates roughly $1.6 million annually from over 10,000 members. HR&A estimates that a membership structure for Space 134 could generate between $50,000 and $70,000 annually per 1,000 members. Sustaining memberships require a sustained value proposition for members, marketing and active engagement with patrons, incurring costs and requiring management capacity. As discussed previously, an aggressive campaign to generate philanthropic contributions during project construction should take advantage of the opportunity to create an operating endowment, with between 20 and 25 percent of fundraising dedicated to an endowment.
  9. 9. HR&A ADVISORS, INC. Space 134 Implementation Conclusions | 9  Public Funding will be required to fill any gaps in the annual operational budget that are not covered by the above-mentioned resources. Glendale’s Parks Department budget in the Fiscal Year 2014-2015 was roughly $30 million, of which about $6 million is dedicated to maintaining the City’s almost 300 acres of developed park land. While the amount of public funding required for Space 134 will be contingent upon the management structure, the operation of Space 134 could amount to a significant component of department’s annual budget, and Phase 1 could require between $1 and $1.9 million in annual funding support. However, the economic and fiscal benefits of Space 134 may offset a significant portion of annual expenditures through increased sales, property and other taxes. Best Practices and Next Steps Management and Governance Adopting an effective governance strategy early in the planning process, whether public, private or a combination of the two, will be essential to create a high-quality park and to support continued maintenance, operations and engaging programming. Finding a balance between a completely public or privately-operated approach through a public-private partnership can be especially effective in efficiently managing a park, maximizing earned revenue and reducing the burden on the municipality, while aligning closely with public goals. Often, independent non-profit entities are better equipped to raise funds and market the park elements, while cities are better-equipped to provide operations and maintenance capacity by leveraging its capabilities as 'in kind' support or under a management contract. The range of public-private partnerships can be classified by their position along two spectrums, one being the intensity of partnership and the other, a range of operational funding sources, as demonstrated on the matrix shown above. Space 134’s operational model is Low High Expenses (3,000,000)$ (3,550,000)$ Programming1 (200,000)$ (250,000)$ O&M1 (1,600,000)$ (1,900,000)$ Routine O&M (1,200,000)$ (1,400,000)$ Security (400,000)$ (500,000)$ Management & Admin1 (1,200,000)$ (1,400,000)$ Revenues 1,150,000$ 2,550,000$ Programming and Events2 200,000$ 400,000$ Concessions2 350,000$ 650,000$ Value Capture3 600,000$ 1,500,000$ Funding Gap (to be met through public funding and philanthropy) (1,850,000)$ (1,000,000)$ 1 Based on Klyde Warren Park per acre cost comparables 2 Based on regional facility and event comparables; low (conservative # of events), high (less conservative # of events) 3 Maintenance district, assumes $200/residential unit assessment; low (current units), high (continued res. growth in Glendale) Source: HR&A Advisors, Inc. Expected Expenses/Revenues Space 134 Illustrative Phase 1 Annual Expense and Revenue Summary Line Item
  10. 10. HR&A ADVISORS, INC. Space 134 Implementation Conclusions | 10 likely to evolve over time, initially involving minimal partnership and significant public funding, with later phases leveraging intensive partnerships to approach a self-sustaining funding model. HR&A’s experience has shown that, especially where existing local organizational capacity in the private or non- profit sector is lacking, developing sustainable partnerships can take a significant amount of time, requiring long-term commitment, expertise and clear communication to nurture the required organizational capacity.2 Next Steps: Bolstering Support and Identifying Stakeholders As noted before, it will be important for the City and supporters of Space 134 to continue to bolster early support for the project to develop a fully-integrated project which is more likely to unlock the transformative potential of a cap park. Proactive engagement of Glendale businesses and residents should be targeted toward shaping the project’s “friends of” group of interested local resident and business stakeholders, which may evolve to take on a stronger role in the planning and operation of the park, and will be a critical success factor for Space 134. Key to developing a “friends of” group will be identifying and engaging with existing organizations and community leaders active in Glendale, to build support, excitement, and ownership of Space 134 as an idea. Although fundraising and implementation capacity in partnership with local stakeholders is one of the goals of successful outreach and engagement, it is not the most critical near term objective. The more important objective of early community engagement is to shape the project in a manner that the community and locally elected members welcome it, are willing stand behind it and bring it to the top of their agenda. The City has already started this process, and should continue to engage with community groups further through the planning and design process; in doing so, the City should be transparent about costs, but also clearly articulate the numerous benefits of Space 134. It is important that the implementation strategy for the park is vetted by the community as a whole and has the support of local businesses and residents. A next step after ensuring broad- based support of the idea, may be for the City Council to appoint a focused Stakeholder Task Force to shepherd the implementation process, composed of community and business leaders and key staff members, reporting directly to the Council. This task force would be responsible for developing a series of recommended actions for phased implementation of the park, using staff and consultants as technical resources on an-as needed basis. These recommendations will include concrete actions around many of the ‘next steps’ identified in this memorandum report. They should direct the City towards engagement with the most relevant private and public sector partners, identify ‘seed’ funds and resources to initiate the project and continue technical studies, and identify the most appropriate governance and organizational strategy for Phase I. 2 Bryant Park is a highly-programmed park located in New York City that was renovated in 1992 and includes a lawn, restaurants and extensive seasonal programming. Grand Park is large park in Los Angeles, which was built in 2012 and includes a large lawn, fountains and some seasonal programming. Tongva Park is a large park in Santa Monica, California that includes extensive, highly-designed landscaping and some small recreation areas.

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