RPVCCA_CC_SR_2013_02_05_02_Border_Issues_Status_ReportCITY OF
MEMORANDUM
RANCHO PALOS VERDES
TO:
FROM:
DATE:
SUBJECT:
REVIEWED:
HONORABLE MAYOR &CITY COUNCIL MEMBERS
CAROLYNN PETRU,A1CP,DEPUTY CITY MANAGER~
FEBRUARY 5,2013
BORDER ISSUES STATUS REPORT .....fI .
CAROLYN LEHR,CITY MANAGER ~
Project Manager:Kit Fox,AICP,Senior Administrative Analyst @
RECOMMENDATION
1)Receive and file the current report on the status of Border Issues;and 2)receive a
presentation regarding the Clearwater Program from the Los Angeles County Sanitation
Districts.
EXECUTIVE SUMMARY
This month's report includes:
• A report on the most-recent meeting of the San Pedro Facility Restoration Advisory
Board (RAB)for the Navy's Defense Fuel Support Point (DFSP)on North Gaffey
Street in Los Angeles (San Pedro);
• A status report on the Draft Environmental Impact Report (DEIR)for the revised
Ponte Vista project in Los Angeles (San Pedro);
• A brief status report on the Brickwalk,LLC mixed-use condominium project in Rolling
Hills Estates;
• A follow-up report on the DEIR for the San Pedro Community Plan Update in Los
Angeles (San Pedro);
•An update on recent issues and events related to the Rancho LPG butane storage
facility in Los Angeles (San Pedro);and,
• A report on the status of the Marymount College San Pedro campus on Palos
Verdes Drive North in Los Angeles (San Pedro).
In addition,Staff of the Los Angeles County Sanitation Districts'will make a presentation of
the Clearwater Program,as requested by Councilman Campbell on December 4,2012.
2-1
MEMORANDUM:Border Issues Status Report
February 5,2013
Page 2
BACKGROUND
The following is the regular bi-monthly report to the City Council on various "Border Issues"
potentially affecting the residents of Rancho Palos Verdes.The complete text of the
current status report is available for review on the City's website at:
http://palosverdes.comlrpv/planning/border issuesl2013120130205 Borderlssues StatusRpt.cfm
DISCUSSION
Current Border Issues
San Pedro Facility Restoration Advisory Board,US Navy/Los Angeles (San Pedro)
The San Pedro Facility Restoration Advisory Board (RAB)held its most recent meeting on
January 17,2013 (see attached cover letter,agenda and attachments).The RAB
continues to deal only with environmental remediation at the active Defense Fuel Support
Point (DFSP)San Pedro,not the former Navy housing sites.Unfortunately,Staff was
unable to attend this most recent meeting.
At the last RAB meeting on June 21,2012,Lomita Planning Commissioner Dan Jones was
appointed as interim RAB Community Co-Chair to replace the late Gil Alberio.The Navy
has begun public outreach efforts to select a permanent Community Co-Chair and new
members for the RAB.An application for new RAB members was distributed just prior to
the January 1i h meeting.Staff will continue to monitor this project in future Border Issues
reports.
Ponte Vista Project at Former Navy Housing Site,Los Angeles (San Pedro)
During December 2012,Staff attended several meetings of the Northwest San Pedro
Neighborhood Council (NWSPNC)to review the plans and Draft EIR (DEIR)for the Ponte
Vista project.On Monday,January 7,2013-the end of the public comment period-Staff
submitted the attached comments on the DEIR to the City of Los Angeles.
Our comments begin by pointing out discrepancies between the 1,135-unit "proposed"
project and the project Alternatives C and D being promoted by the developer in the media
and in public forums.We then cited concerns with respect to the assessment of
aesthetics,geology,hazards,land use,noise,housing/population,public services (schools
and recreation),transportation/traffic and wastewater.
Staff was provided with copies of DEIR comments from several other stakeholder groups,
which are attached to tonight's report.They include:
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MEMORANDUM:Border Issues Status Report
February 5,2013
Page 3
•Northwest San Pedro Neighborhood Council
•"R Neighborhoods R1"
•City of Lomita
•City of Rolling Hills Estates
•Palos Verdes-South Bay Group/Angeles Chapter,Sierra Club
•Barbara and AI Sattler
•Janet Gunter
Shortly after the end of the public comment period,the developer formally announced that
it would pursue the 830-unit proposal described as Alternative C in the DEIR.The Daily
Breeze and PV News also reported on this announcement (see attachments),which came
as no surprise to Staff.Staff will continue to monitor this project in future Border Issues
reports ..
Brickwalk,LLC Mixed-Use Condominiums,Rolling Hills Estates
On December 3,2012,the Rolling Hills Estates Planning Commission continued its
discussion of the Brickwalk,LLC project.It approved the project and gave direction to its
Planning Staff to bring back a resolution for adoption on December 17,2012 (see
attachment).The Rolling Hills Estates City Council is now expected to consider and ratify
the Planning Commission's action on February 12,2013.Staff will continue to monitorthis
project in future Border Issues reports.
San Pedro Community Plan Update,Los Angeles (San Pedro)
On December 12,2012,an open house and public hearing were held for the San Pedro
Community Plan Update (see attached notice).Unfortunately,Staffwas not able to attend.
However,the following day Los Angeles City Councilman Joe Buscaino sent the attached
letter to the Department of City Planning,asking for the proposed land use changes
surrounding the intersection of Western Avenue and 25 th Street to be removed from
consideration in the plan update.Staff has repeatedly raised concerns about the proposed
changes to the density and intensity of future development surrounding this intersection
that would be allowed and encouraged under the proposed update to San Pedro
Community Plan.Staff will continue to monitor this project in future Border Issues reports.
Rancho LPG Butane Storage Facility,Los Angeles (San Pedro)
Following up on the City Council's direction of October 16,2012,Staff has been attempting
to obtain copies of insurance information regarding the Rancho LPG facility.However,as
of the date that this report was completed,legal counsel for the facility operator has not
indicated whether or not such information will be provided to the City.
2-3
MEMORANDUM:Border Issues Status Report
February 5,2013
Page 4
As mentioned in the discussion of the Ponte Vista project above,Janet Gunter submitted
extensive comments in opposition to the project on the basis that the risk of upset posed
by the nearby Rancho LPG facility was not adequately addressed.Also attached to
tonight's report are copies of e-mails and correspondence received regarding the Rancho
LPG facility between December 7,2012 and January 10,2013.These include:
•E-mail from San Pedro Peninsula Homeowners United regarding nuisance
complaints about the Rancho LPG facility,received on December 7,2012;
•E-mail chain regarding 3rd _party review of seismic hazards analysis for the Rancho
LPG facility in the Ponte Vista DEIR,received on January 2,2013;
•E-mail from Janet Gunter regarding insurance and seismic issues for the Rancho
LPG facility,received on January 7,2013;and,
•E':'mail from Janet Gunter asking the State's Local Emergency Planning Committee
to oppose the Ponte Vista project due to issues related to the Rancho LPG facility.
Staff will continue to monitor this project in future Border Issues reports.
Marymount College San Pedro Campus Master Plan,Los Angeles (San Pedro)
On December 3,2012,Staff received the attached response from the Los Angeles
Department of Transportation (LADOT)to our comments on the MND for the Marymount
San Pedro project.Although this response generally addressed most of the issues that we
had raised in our comments of October 17,2012,Staff believed that it still failed to
adequately address potential traffic impacts at Palos Verdes Drive South and Palos Verdes
Drive East.
The public hearing on the parcel map component of the project-consisting of the merger
of the main campus site with adjacent vacated right-of-way of Palos Verdes Drive North-
was scheduled before the City of Los Angeles Advisory Agency on December 12,2012.
Staff attended the hearing,but due to deficiencies in the parcel map application and the
MND,the matter was not heard and no action was taken on the application at that time
(see attached Staff report).
The public hearing was subsequently re-scheduled for January 24,2013.By that time,the
deficiencies identified in the previous Staff report had been corrected.Staff testified before
the hearing officer about bur concerns regarding unresolved impacts at Palos Verdes Drive
South and Palos Verdes Drive East.The hearing officer agreed to take our concerns into
consideration and took the case under advisement for an additional week.However,Staff
believes that it is likely that the hearing officer will ultimately approve the parcel map as
proposed by Marymount College.
The entire Marymount College San Pedro Campus project,which also includes a
conditional use permit (CUP),will require the approval of the Los Angeles City Planning
2-4
MEMORANDUM:Border Issues Status Report
February 5,2013
Page 5
Commission at a subsequent public hearing.Staff anticipates that this hearing will occur in
late February or early March.Staff will continue to monitor this project in future Border
Issues reports.
New Border Issues
There are no new Border Issues on which to report at this time.
Presentation of Clearwater Program
At the December 4,2012,City Council meeting,Councilman Campbell asked Staff if
arrangements could be made for a presentation of the Los Angeles County Sanitation
Districts"(LACSD)Clearwater Program at a future City Council meeting.As was discussed
in the Staff report and late correspondence for the Border Issues Status Report on the
December 4 tIi agenda,the LACSD District No.2 Board of Directors certified the
Environmental Impact Report (EIR)and approved the Master Facilities Plan (MFP)for the
Clearwater Program on November 28,2012.
The Clearwater Program includes the approval of modifications and improvements to the
Districts'treatment and disposal facilities located throughout Los Angeles County,including
the construction of a new 18-foot-diameter,7-mile-long on-shore tunnel that will connect
the existing outfall structure at Royal Palms County Beach in San Pedro to the Districts'
Joint Water Pollution Control Plant (JWPCP)in Carson.The tunnel alignment for the
approved project is the Districts'recommended "Alternative 4,"which will be constructed
hundreds of feet below Western Avenue from Trudie Drive/Capitol Drive to Royal Palms
County Beach.
As requested,LACSD Staff will make a brief presentation of the Clearwater Program to the
City Council at tonight's meeting.
Attachments:
•Cover letter,agenda and notice for San Pedro Facility RAB meeting (received
1/9/13)
•City Staff comments on the Ponte Vista EIR (dated 1/7/13)
•NWSPNC comments on the Ponte Vista EIR (dated 1/7/13)
•"R Neighborhoods R1"comments on the Ponte Vista EIR (dated 1/7/13)
•City of Lomita comments on the Ponte Vista EIR (dated 12/19/12)
•City of RHE comments on the Ponte Vista EIR (dated 1/3/13)
•Sierra Club comments on the Ponte Vista EIR (dated 1/7/13)
•Comments from AI and Barbara Sattler on the Ponte Vista EIR (dated 1/7/13)
•Comments from Janet Gunter on the Ponte Vista EIR (dated 1/7/13)
•Ponte Vista e-mail regarding 830-unit proposal (received 1/18/13)
2-5
MEMORANDUM:Border Issues Status Report
February 5,2013
Page 6
Attachments (cont'd):
•Daily Breeze and PV News articles regarding Ponte Vista project (published 1/15/13
&1/17/13)
•RHE Planning Commission Resolution No.PA-01-07 for Brickwalk,LLC project
(adopted 12/17/12)
•Notice for open house/public hearing for the San Pedro Community Plan Update
(received 12/6/12)
•Letter to Councilman Buscaino regarding San Pedro Community Plan Update
(dated 12/13/12)
•E-mails and correspondence regarding Rancho LPG facility (received 12/7/12 to
1/10/13)
•LADOT response to MND comments for Marymount College San Pedro Campus
(dated 11/30/12)
•Staff report for Marymount College San Pedro Campus (dated 12/12/12)
M:\Border Issues\Staff Reports\20130205_Borderlssues_StaffRpt.doc
2-6
Cover letter,agenda and notice
for San Pedro Facility RAB meeting
2-7
DEPARTMENT OF THE NAVY
NAVAL~PONSSTAnONSEALBEACH
800 SEAL BEACH BOULEVARD
SEAL BEACH.CA 90740-5607
."
Restoration Advisory Board
Community Members
Ladies and Gentlemen:
IN REPLY REFER TO
RECEIVED ~~=0
N4 SW /0001
OIlY OF RANCHO PALOS VERDES 03 Jan 2013
JAN 09 2013
~~rr T01'
CITY CLERK'S OFFICE
SUBJECT:January 17,2013 -DEFENSE FUEL SUPPORT POINT SAN PEDRO
RESTORATION ADVISORY BOARD MEETING
Naval Weapons Station Seal Beach will be holding a Restoration
Advisory Board (RAE)meeting for the Defense Fuel Support Point
(DFSP).San Pedro on Thursday,January 17,2013 from 4:00 to 6:00
PM,at'DFSP San Pedro,Building 100.The enclosed agenda lists
the proposed topics to be discussed and the location/address of
the RAE meeting.
The DFSP San Pedro RAE meets to review the progress and status
of the Installation Restoration Program (IRP)on non-Base
Realignment and Closure (BRAe)DFSP San Pedro sites.The RAE
concerning the BRAC portion of the DFSP San Pedro facility has
been adjourned since those sites received regulatory approval
for closure.,
Applications are being accepted from interested parties for
positions as community RAE members.Community RAE members are
responsible for electing a Community CO-Chairperson.RAE
members are expected to serve a two-year term and attend the
semi-annual RAB meetings.Members who miss three or more
consecutive meetings may be asked to resign.Duties and
responsibilities will include reviewing and commenting on
technical documents and activities associated with the IRP at
DFSP San Pedro.Members will be expected to act as a liaison
for information exchange between the community and the RAB.
If you are interested in the Community Co-Chair role and/or RAE
membership in general,please contact Kellie Freeman at
(714)43S-6230 or via email at:Kellie.Freeman@ch2m.com.
2-8
I
5090
Ser N45W/0001
03 Jan 2013
If you have any questions,you may contact the Navy Remedial
Project Manager,Mr.Grady Gordon,at (619)532-2296 (email:
grady.gordon@navy.mil)orthe Principal Environmental Scientist,
Dr.Margaret Wallerstein at (562)626-7838 (email:
margaret.wallerstein.ctr@navy.mil).
S~C1-~L
Pei-Fen Tamashiro
Installation Restoration Coordinator
By Direction of the Commanding Officer
Enclosure:1.DFSP San Pedro RAE Meeting Agenda
Distribution List:Restoration Advisory Board Members
2
2-9
NAVAL WEAPONS STATION SEAL BEACH
DFSP SAN PEDRO RESTORATION ADVISORY BOARD (RAB)MEETING
31 71 North Gaffey Street,Building 100
San Pedro,California
Thursday,January 17,2013
4:00 pm to 6:00 pm
AGENDA
4:00 PM
4:05 PM
4:20PM
4:30PM
4:40PM
5:10 PM
5:25 PM
5:50 PM
5:55 PM
6:00 PM
Welcome and Introductions
Navy Co-Chair:Mr.Grady Gordon
Interim Community Co-Chair:Mr.Dan Jones
Administrative Items
Co-Chair Election
Distribution/Mailing List
RAB Meeting Time
Public Involvement Overview
Ms.Kellie Freeman,KCH
IR Program Overview
Mr.Grady Gordon
IR Site 32 Remedial Investigation Update
Mr.David Bloom,Tetra Tech Inc.
IR Site 32 Feasibility Study Update
Mr.Eric Johansen
Palos Verdes Blue Butterfly
Dr.Albert Owens,Entomologist
Open Forum for RAB Members and the Public
Next Meeting
Meeting Adjourned
2-10
NAVAL WEAPONS STATION SEAL BEACH
DEFENSE FUEL SUPPORT POINT SAN PEDRO
NOTICE OF JANUARY 2013
RESTORATION ADVISORY BOARD MEETING
WHO:Everyone is welcome
WHEN:Thursday,January 17,2013,at 4:00 PM
WHERE:Defense Fuel Support Point,San Pedro
3171 N.Gaffey Street,Building 100,San Pedro,CA 90731
The Department of the Navy has been conducting environmental investigations at locations within the
Defense Fuel Support Point (DFSP)San Pedro,and at the former Palos Verdes and San Pedro Navy
housing areas.IRP sites within the former Navy housing areas have been addressed through the Navy
Base Reali'gnment and Closure Office's (BRAe)Environmental Restoration Program (ERP)and
environmental sites within the DFSP facility have been addressed as part of the Navy's Installation
Restoration Program (IRP).In the summer of 1994 the Navy established a Restoration Advisory Board
(RAB)for all of the IRP sites.This meeting is OPEN TO THE PUBLIC and is intended to provide an open
forum for the community to attend and participate in all aspects of the investigation and environmental
cleanup activities associated with the Navy's DFSP San Pedro IRP.The meeting will provide information
on the IRP status including the IR Site 32 Remedial Investigation/Feasibility Study (RI/FS).
Environmental response actions are complete at all BRAC sites as these sites have received site closure
from regulatory agencies.
PLEASE NOTE THAT THE NAVY'S DFSP SAN PEDRO RAB WILL CONTINUE TO MEET WITH REGARD TO
ONGOING ENVIRONMENTAL WORK ON THE NON-BRAC SAN PEDRO IRP SITES.
Environmental documents associated with the IRP for DFSP San Pedro are kept at the Information
Repository-San Pedro Public Library,Environmental Impact Statement (EIS)section.These documents
are available for review by the public and other interested parties.
Applications are being accepted for RAB membership and community members will elect the RAB
Community Co-Chair.RAB members are expected to serve a two-year term and attend the semiannual
RAB meetings.Members who miss three or more consecutive meetings may be asked to resign.Duties
and responsibilities will include reviewing and commenting on technical documents and activities
associated with the environmental restoration at the Navy's DFSP San Pedro Facility.Members will be
expected to act as a liaison for information exchange between the community and the RAB.If you are
interested in the co-chair role and/or RAB membership in general,please contact Kellie Freeman,at
(714)435-6230 or via email atKellie.Freeman@ch2m.com.
If you have any questions,feel free to contact:
Mr.Grady Gordon
Environmental Project Manager
Department of the Navy
Naval Facilities Engineering Command,Southwest
(619)532-2296
Dr.Margaret Wallerstein
Principal Environmental Scientist
Naval Weapons Station Seal Beach
562-626-7838
2-11
Restoration Advisory Board Membership Application
Naval Weapons Station Seal Beach
Defense Fuel Support Point San Pedro
Conditions for Membership:
The Naval Weapons Station Seal Beach Commanding Officer must concur with the appointment of
Restoration Advisory Board (RAB)members.Community RAB members elect the Community Co-Chair.
The elected Co-Chair serves a two-year term and attends the semi-annual RAB meetings.Members who
miss three or more consecutive meetings may be asked to resign.Duties and responsibilities will include
reviewing and commenting on technical documents and activities associated with the environmental
restoration at DFSP San Pedro.Members will be expected to be act as a liaison for information
exchange between the community and the RAB.
NAME:_
ADDRESS:_
CITY/STATE/ZIP:_
DAYTIME PHONE:-'--_
EMAIL:_
COMMUNITY AFFILIATION:_
OCCUPATION:~_
Briefly state why you would like to be a member of the RAB.
Are you currently or have you ever been involved with or affected by environmental cleanup activities
associated with DFSP San Pedro?If yes,please explain
Please indicate if you are interested in being considered for the Community Co-Chairperson position on
the RAB by checking the box below:o Yes,I would like to be considered.
Are you willing to serve a two-year term as a member of this RAB?o Yes,I am willing to serve a two-year term as a member of this RAB.
DFSP San Pedro RAB Application Page 1
2-12
.....
By submitting this signed application,you willingly agree to work cooperatively with other members of
the RAB to address community issues related to environmental restoration of the facility.
Privacy Act Statement:The personal information requested on this form is being collected to determine
interest and qualification for RAB membership.The information will be retained on file at the NAVFAC
office.The information will not be disseminated. Providing information on this form is voluntary.
Applicant Signature
Please return your completed application to:
Ms.Kellie Freeman
KCH,Public Involvement Manager
6 Hutton Centre Dr.,#700
Santa Ana,CA 92707
PH 714-435-6230
kellie.freeman@ch2m.com
We ask that you please return your application by January 11,2013.
DFSP San Pedro RAB Application
Date
Page 2
2-13
City Staff comments on the Ponte Vista EIR
2-14
CITYOF
7 January 2013
VIA ELECTRONIC AND U.S.MAIL
Erin StreHch,Planning Assistant
Department of City Planning
Environmental Review Section
200 N.Spring St.,Rm.750
Los Angeles,CA 90012
SUBJECT Comments In Response to the Notice of Availability/Completion of a
Draft Environmental Impact Report for the Proposed Ponte Vista
Project,26900 South Western Avenue (Case No.ENV-2005-4516-EIR)
Dear Ms.Strelich:
The City of Rancho Palos Verdes appreciates the opportunity to comment upon the
Notice of Availability/Completion (NOAlC)for the above-mentioned project.The City
respectfully offers the following comments on the content and analysis of the Draft EIR
(DEIR)for the proposed project:
1)From the outset,the City of Rancho Palos Verdes would like to take this
opportunity to remind the City of Los Angeles that the purpose of an EIR is to
disclose and describe the environmental impacts of a proposed project in a
logical and concise manner so that decision makers are able to make fully-
informed decisions before taking action on the proposed project in question.In
the case of this EIR,however,it is clear that the project proponent has no
intention of building or seeking errtitlements to build the so-called "proposed"
project,but instead intends to pursue Alternative C.as described in Section VI of
the DEIR.Nevertheless.thousands of pages of descriptions,diagrams.analyses
and technical appendices are expended on the "proposed"project in the DEIR,
while fewer than one hundred fifty (150)pages at the back of the DEIR are
devoted to the analysis of all four (4)project alternatives combined.We
appreciate that the project proponent's decision to abandon the "proposed"
project in favor of 830-unit Alternative C or 1,135-unit Alternative D may have
been in response to significant geotechnical issues that were identified on the
site after the initial circulation of the Notice of Preparation (NOP)in October
2010.However,at that point.the project description should have been revised to
address these changed circumstances and the NOP recirculated.Instead.we
are now presented with a DEIR that includes a minutely-detailed analysis of a
30940 HAWTHORNE BLVD./RANCHO PALOS VERDES,CA 90275-5391/(310)544-5205 /FAX (310)544-5291
WWW.PALOSVERDES.COM/RPV
PRINTED ON RECYCLED PAPER
2-15
Erin Strelich
7 January 2013
Page 2
"proposed"project that the project proponent has no interest in pursuing,and
superficial analyses of the "real"project proposal (Le.,Alternative C or D).
Therefore,before we comment in more detail on the DEIR as presented,the City
of Rancho Palos Verdes wishes to go on record as requesting that the DEIR be
completely re-written with either Alternative C or Alternative D as the "proposed"
project-accompanied by appropriately re-written descriptions,diagrams,
analyses and technical appendices-and re-circulated for a new public review
and comment period.
2)The City respectfully takes exception with some of the "important planning
issues"purportedly addressed by the "proposed"project (pp.1-8 to 1-9):
a)The introduction states that the "site's size and relative physical isolation
make it possible to avoid or reduce many of the typical 'adjacency'
impacts that result from infill development."While the proposed project
may be remote from the developed areas to the north and east by virtue of
the adjacent Defense Fuel Support Point San Pedro,no comparable
buffer is provided from the adjacent neighborhoods in San Pedro to the
south or Rancho Palos Verdes to the west.
b)Furthermore,the introduction asserts that the increased residential density
proposedis necessary to meet regional housing needs,and notes that the
project site is located near "the Ports of Los Angeles and Long Beach,
which are among the region's largest employers."However,as far as we
can tell,the "proposed"project includes absolutely no provisions to ensure
that any of the proposed housing units would be made affordable or
accessible to Port or Port-related employees,other than by virtue of mere
physical proximity.
3)The City appreciates that a much more comprehensive assessment of the
aesthetic impacts of the "proposed"project was conducted in the current DEIR
than was the case for the previous 2,300-unit proposal in 2007.This included
the acknowledgement that adverse impacts upon views characterized by man-
made features-such as those that occur in and around Los Angeles Harbor-
are potentially significant.Views of the Harbor area-especially at night-are a
prominent visual feature of Rancho Palos Verdes neighborhoods along Western
Avenue,and the City of Rancho Palos Verdes frequently considers (and
protects)city-light views of the harbor when considering development proposals.
Unfortunately,the DEIR dismisses adverse impacts to views from private
property in the City of Rancho Palos Verdes as less than significant.This
includes views from Green Hills Memorial Park and from homes in the Rolling
2-16
Erin Slrelich
7 January 2013
Page 3
Hills Riviera neighborhood on the west side of Western Avenue.The City of
Rancho Palos Verdes takes this opportunity to formally object to this
assessment.We also offer the following specific comments on Section IV.B
(Aesthetics ):
a)There are repeated references in Section IV.B to homes on "Palondra
Drive"in Rancho Palos Verdes.There is no such street in the City,and
we are unsure what homes the DEI R is referring to.
b)The description of private viewing areas in Rancho Palos Verdes
(pp.IV.B-19 to IV.B-20)identifies two (2)neighborhoods on the west side
of Western Avenue to the south of Green Hills Memorial Park that
overlook the project site.In fact,there is only one (1)residential
neighborhood in this area,which is known as Rolling Hills Riviera.
c)The "before-and-after"photographic simulations included in Section
IV.B-which we find to be crude,at best-should be placed closer to one
another in the DEIR so as to make it easier for readers to compare the
photos and draw their own conclusions.In the current DEIR,these
"before-and-after"images area separated by two (2)dozen or more pages
of text.
4)We were surprised to learn (as,we suspect,was the project proponent)of the
existence of a subsurface fault crossing the subject property,as described in
Section IV.F (Geology &Soils).As mentioned above,we appreciate that this
discovery drove changes in the site plans of the project alternatives so as to
protect future residents,resulting in the designation of a 100-foot-wide seismic
setback zone (Mitigation Measure GEO-1).However,we believe that the
discovery of this issue should have resulted in complete reconsideration of the
description of the "proposed"project and recirculation of the DEIR,as described
above in Comment 1.
5)We have several comments with respect to the assessment of Hazards and
Hazardous Materials in the DEIR (Section IV.H):
a)Section lV.H describes the health risk assessment (HRA)conducted in
relation to toxic air contaminant (TAC)emissions from several industrial
sources near the project site (i.e.,DFSP,ConocoPhillips and the Port of
Los Angeles).However,we were surprised to read that among the sites
that were not included in the HRA was the Rancho LPG facility at North
Gaffey Street and Westmont Drive (p.IV.H-25).This omission is of
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Erin Strelich
7 January 2013
Page 4
particular concern due to recent incidences of TAC emissions (Le.,leaks)
at both ConocoPhillips (September 2012)and Rancho LPG (October
2012),both of which we understand are under investigation by the AQMD.
b)The analysis of off-site releases of hazardous materials notes that an
independent risk-of-upset hazard analysis was performed in relation to the
DFSP and ConocoPhillips,but not Rancho LPG.Given the high level of
public concern about the Rancho LPG facility in recent years,we believe
that it would have been most prudent to include all three (3)of these
facilities in the independent risk-of-upset hazard analysis.
c)The DEIR concludes that the "proposed"project has no impact with
respect to conflicts with adopted emergency response plans,based (at
least in part)upon an assertion that the City of Rancho Palos Verdes has
not designated Western Avenue as an emergency evacuation route along
the frontage of the project site (p.IV.H-41).The DEIR cites an exhibit in
the Safety Element of the Rancho Palos Verdes General Plan (Figure 39,
Disaster Routes)that was not updated after the Eastview area was
annexed by Rancho Palos Verdes in 1983.However,the text
accompanying this exhibit notes that routes depict on Figure 39 are
conceptual and that the designation of evacuation routes is found in the
Emergency Operations Plan (EOP)and Standard Operating Procedures
(SOP),not in the General Plan.Furthermore,the City of Rancho Palos
Verdes is currently updating its General Plan,and expects that Western
Avenue-the major north-south arterial serving the Eastview area of the
City-will be incorporated into the updated version of Figure 39.As such,
the City of Rancho Palos Verdes believes that the "proposed"project is
very likely to have an effect upon emergency response in the Eastview
area ofthe City,and that this-effect should be analyzed in the DEIR.
d)Finally,notwithstanding the discussion on p.IV.H-18 of the DEIR,the City
of Rancho Palos Verdes believes that the project site is within a 2-mile
radius of Torrance Municipal Airport (TOA),so that the potential aircraft
safety hazards posed for future residents should be assessed in the DEIR.
6)The discussion of Land Use/Planning impacts suggests that the "proposed"
project is necessary to meet a variety of perceived housing needs,even though
the existing residential density of the project site would be increased by more
than four (4)times.We do not believe that the DEIR adequately demonstrates
the need for higher-density residential development on this site or in the
surrounding community.In fact,we would point out that existing,unsold higher-
2-18
Erin Strelich
7 January 2013
PageS
density developments located to the south of the project site and in downtown
San Pedro actually demonstrate that there is a glut of this type of housing in the
local market.The City remains concerned that a proposal for residential
densities in excess of eighteen (18)units per acre for this site will be out of
character with the surrounding patterns of development,both in Rancho Palos
Verdes and Los Angeles.
7)The analysis of Noise impacts in the DEIR (Section IV.K)concludes that there
will be significant and unavoidable exterior noise impacts of the "proposed"
project upon certain project residences located along the Western Avenue
frontage of the site.We question if there may be similar,adverse exterior noise
impacts to existing residences on the west side of Western Avenue in Rancho
Palos Verdes that have not been adequately addressed in the DEIR.
8)The City respectfully disagrees that the growth in housing and population directly
attributable to the proposed project would be beneficial to the surrounding
community,and believes that it would be of negligible regional benefit toward
achieving jobs/housing balance.The DEIR purports that the proposed project
would contribute to the alleviation of a "jobs rich/housing poor"condition in the
Los Angeles subregion (p.IV.L-22).However,the "proposed"project includes no
assurances that any of the project's 2,923 new residents would be employed
locally,nor that any of the project's 1,135 new units would be affordable to
current employees of the Port or other nearby institutional or private employers.
9)The discussion of Public Services-Schools impacts concludes that,based upon
LAUSD estimates,sixty-eight (68)children residing in the "proposed"project are
expected to attend Dodson Middle School in the City of Rancho Palos Verdes at
any given time (Table IV.M-8).Although LAUSD may represent the Dodson
campus as being well under capacity,it is the City's and the surrounding
residents'actual experience that the current level of enrollment at Dodson results
in significant noise,traffic and other nuisance impacts (Le.,trash,graffiti,etc.)in
the surrounding Rolling Hills Riviera neighborhood.We suspect that the addition
of even sixty-eight (68)more students to the campus population will have
significant adverse impacts upon the Rolling Hills Riviera neighborhood.
10)The discussion of Public Services-Recreation impacts concludes that the impact
of the "proposed"project will be less than significant as the result of the payment
of Quimby fees to the City of Los Angeles,and the provision of 4.1 acres of
publicly-accessible parks and open space,and 16.5 acres of private parks,
landscaping and recreational amenities.The City of Rancho Palos Verdes
respectfully notes,however,that the nearest public park to the project site is
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Erin Strelich
7 January 2013
Page 6
Rancho Palos Verdes'Eastview Park,located at 1700 Westmont Drive (Figure
IV.M-4).The payment of Quimby fees to Los Angeles will do nothing to offset
impacts to nearby Rancho Palos Verdes park facilities from future project
residents.Furthermore,since Alternatives C and D no longer contain a public
park,we believe that the project's off-site recreational impacts will be significant
and should be more fully assessed in the DEIR.
11)The discussion of Transportation and Traffic impacts (Section IV.N)raises
several issues of concern to the City:
a)Vehicular access to and from Mary Star of Sea High School will be
maintained through the project site,but will be shifted from its current
access point at the Green Hills Drive intersection to the Avenida Aprenda
intersection.A queue analysis needs to be conducted to justify the
appropriate increase to the existing left-turn pockets on Western Avenue
at the Green Hills Drive and Avenida Aprenda intersections.
b)The project is proposing left-turn signal phasing at the intersections of
Western Avenue at Green Hills Drive and Avenida Aprenda as a project
feature.Prior to approval,the applicant must provide justification for
appropriate left-turn phase sequencing to maximize operational benefits
while minimizing safety impacts.
c)On page 55 of the traffic study,the reports states that certain
improvements have been implemented along Western Avenue as a result
of the Western Corridor Improvement Project Plan.To date,none of the
improvements,as recommended by this study,have been implemented.
d)Removal of the raised concrete median at various intersections along
Western Avenue poses a huge safety concern.There is existing evidence
of operational issues at many of these intersections,especially the left-
turn movements.Removing the raised concrete median nose opens the
opportunity for other safety-related concerns.Please provide an
alternative to striping for safety purposes.
e)The City is concerned about the retention of the wide northbound No.2
lanes that invite motorists to create a third travel lane.With the project
distributing and attracting approximately 60%of the project trips from the
north and approximately 30%of project trips from the south along Western
Avenue,there is a potential for many vehicles to attempt to avoid the
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Erin Slrelich
7 January 2013
Page 7
traffic in the striped travel lanes and utilize the wide shoulder area to
create a third lane.This pattern exists today.
12)It is the City's understanding that the conveyance of wastewater from the
"proposed"project will be via a connection to the City of Los·Angeles'sewer
system within the right-of-way of Taper Avenue (p.IV.O-25),not via the former
connection to the Los Angeles County Sanitation Districts'Western Avenue
Pumping Plant (WAPP)in the City of Rancho Palos Verdes.We presume that
this will also be the case in any of the alternatives to the "proposed"project.The
City of Rancho Palos Verdes is concerned that any proposal or alternative that
might continue to utilize the former WAPP connection for this site could place a
burden upon the County sewer system that serves the City's residents.
13)The DEIR identifies significant unavoidable impacts in the areas of operational air
emissions and construction-related air quality,noise and vibration impacts (p.V-
1).Residents in Rancho Palos Verdes'Rolling Hills Riviera neighborhood are
likely to feel the brunt of these impacts,being the nearest single-family residential
neighborhood to the project site.It hardly seems equitable that the City of Los
Angeles will reap the benefits (if any)of the "proposed"project while the
residents of the City of Rancho Palos Verdes will be forced to live with its day-to-
day impacts upon their lives.
14)The discussion of Alternatives to the Proposed Project (Section VI)raises several
issues of concern to the City:
a)As mentioned in Comment 1 above,the City of Rancho Palos Verdes is
concerned that the DEIR primarily analyzes the impacts of a "proposed"
project that the project proponent is not interested in pursuing,and
provides only a cursory assessment of the developer's preferred
proposal(s)in the discussion of alternatives.We believe that this
approach is needlessly confusing and does not serve to improve the
transparency of the development review process for the Ponte Vista
project.
b)With respect to Alternatives A and B,the City of Rancho Palos Verdes is
dismayed to learn that it would be the project proponent's intent to revoke
the access currently proVided to Mary Star of the Sea High School under
these development scenarios.We believe that this simply a mean-spirited
attempt by the project proponent to diminish the feasibility and community
acceptance of these alternatives to the "proposed"project.
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Erin StreUch
7 January 2013
PageS
c)With respect to Alternatives B,C and 0,the City is similarly dismayed to
learn that it would be the project proponent's intent to eliminate the public
park and other publicly-accessible site amenities under these
development scenarios.As mentioned above,we believe that the
elimination of the public park from the "proposed"project will have adverse
impacts upon Rancho Palos Verdes'Eastview Park.
Again,thank you for the opportunity to provide comments on this important project.If
you have any questions or need additional information,please feel free to contact me at
(310)544-5226 or via e-mail atkitf@rpv.com.
Kit Fox,AICP
Senior Administrative Analyst
cc:Mayor Brooks and City Council
Carolyn Lehr,City Manager
Carolynn Petru.Deputy City Manager
Joe Buscaino,Las Angeles City Councilman
Northwest San Pedro Neighborhood Council
M:\Border Issues\Ponle Vista Project\201301 07 _EIRCommenls.doc
2-22
NWSPNC comments on the Ponte Vista EIR
2-23
January 7,2013
Northwest ~aw Pedro Neighborhood Council
"Your Community Voice"
Diana Nave
President
George Thompson
Vice President
Scott Allman
Treasurer
Erin Strelich Katie Marrie
Environmental Review Section Secretary
Department of City Planning
200 N.Spring Street,Room 750
Los Angeles,CA 90012 e{;;":!.'.:;>.;;....
NORTHWEST SAN P§'U;;~COMMENTS ON
ENV·2005·4516 DR~~:t'h?;......P:P~T6¥~J:~PROJECT
:-,::}:~'::.;;?::l-:.~;.~~.
~~~a:~~it~ct~:~~~.~.f.!.•....n.ev.f.1».~."~.~.f..~.~•.~f1.;.•.'~.rt.i.I.Y.m.•.:.•.J~~~~~te~a~~;n d~~Community Plan area anck~J~¢.llIQ%J:Witit:<·}me ~~rieSt,of the Northwest San
Pedro Neighborhood·:;:29~!;Ft~WSP ...·:L;,XY§:~~·G~.J~present approximately
20,0~0 reside.nts and nttm.tJl~4q~~~~;·:;Jft~~q;;f~Wtrnity o~ganizatio~s.At a
SpecIal Meetmg on Janua.,f¥~LKafjY~lli·t>~~B~rfj,,{:by resolutIon,unanImously
adopted the comments coniafRed:;fi,'e1~i;·.5:i;</<)d/·>/
.<::-«>;~<:::;:::::::~<::::~::-::::;<:.:.<.~~;:,;..-:.>.-
The NWSPNC has followed and participated in the review of the project since the
original proposal was submitted by Bisno Development.The current project was
presented by the applicant at our November Board and Community Meeting and
their Traffic Consultant presented the traffic study and proposed mitigations at
our December Board Meeting.Our Planning and Land Use Committee also met
at least three times with their representatives made suggestions during the
development of the traffic study.
Just prior to the release of the DEIR we requested a 90-day comment period.
We remain frustrated and discouraged by the denial of this request,particularly in
light of the fact that the most of the review period was consumed by the
Thanksgiving,Hanukkah,Christmas,and New Year Holiday Season.
Furthermore,it is our contention that the time for review did not comply with the
early warning provision of Charter Section 907,requiring sufficient notice so that
638 S.Beacon Street Box 688 •San Pedro,CA 90731 •(310)-732-4522
www.nwsanpedro.org
1
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Neighborhood Councils will have"...a reasonable opportunity to provide input
before decisions are made".Even more concerning however,is the lack of
sufficient opportunity for the community at large to comment on an environmental
document for a controversial project that will have such a significant impact on
San Pedro,Harbor City and Wilmington.
While this DEIR is an improvement over the document prepared by the previous
developer,it is seriously flawed.Furthermore,the project evaluated does not
appear to be the project that is proposed to be built.This complicates and skews
the review process.
The proposed project does not appear to be a good fit for the community nor for
this geographically unique property.We have problems with the underlying
assumptions and conclusions in the DEIR mainly relating to traffic,social
services,utilities and service systems.Because the analysis is built on faulty
assumptions,it is in effect a "hOija&,>bfJOtirlt$ih6U1d all conclusions based on the
analysis are also faulty.".;~~~~~r~'Z,"'<~tf'o'}~f~>)lyith the lack of amenitiespro~ided 0 n ~ite,an~...'.:?:~.·ft.;"8.f;;t'%."'.~.~................•..~.•.;~....•.:,.'.•..t{.::.::,;.;..~..:·:/.".IFt..".,..;.•ti......•.......•.·•..!!.J:.•.&..•..•.•.~.~•..•'•.7...•.......".'':;'t..~.':·.~.{..:a.Z"~d.ress the su bstantialenvlronmentallmpactsl~~.f1:h r01adt<.ti"fnY·"i>f"/'·<::..l·'.·~.',':f@"f'#.<'p}#y#f.'....,<.'"~;''',•...•,.,.,<"......,,.<.".••#."'.,:~~?f;:.~4;~(,:~i~%dt:%~~/#;)·,~//.:.::W~~~~ffl{·t:>..
Among the fundam~'"?{~~__Ef;...:..:rem~\i laWin ::J]{Nfi~ir::"¥.l~:w·:l:~.'@~..1*~iEf~t;;;;g
1.:h~:~~tti.!!~:t~~~~:~ri~~~:
ten Urban ~~;~igrt~lrrco1>f.'jp Illa'lt"e~i~'st.
2.The DEIR indPrrec~:dd~:ntm~lJ..qh.~"z.:.ject..~~·beini in keeping with the
surrounding nsIQn~.f.'~o.".z:tft.7..'··~(ii·;.:'.'..).D','JI.j.gm~~~;.$l')shortfall in San Pedrof~r single-family··N~t.ti~:~'...::.:~d~:P{efe~ir hou~ing types that will
directly compete wim~·:):U'tiblf.!7Jt>ti!Jlg ...QlI.f.fS Immediately south of the
project and in the former-CrFt~i''Pr~f:a:f~'Tn downtown San Pedro,thereby
undermining a major community effort to revitalize this area,the heart of
our communiy.
3.The proposed project is not a good fit for the location.It is not in a
transited oriented area.The gated community and mix of housing types
are not appropriate.The proposal fails to integrate walking,biking,and
public transit.If built as proposed,residents would need to use their auto
for everything.This over-dependence on cars has Green House Gas,
energy,and health implications and would isolate residents who do not
drive,ego kids,elderly,and the disabled,within a gated subdivision.
Further,the development would not improve the local jobs housing
balance.
638 S.Beacon Street Box 688 •San Pedro,CA 90731 •(310)-732-4522
www.nwsanpedro.org
2
2-25
4.Alternatives B,C,and D ignore the present zoning which includes 15
acres of open space.This is an especially egregious oversight in
alternate B because if claims to be a "no project"alternative,Le.buildable
as a matter of right.In fact,units cannot be built on that portion of the
property zoned as open space.
5.The traffic analysis uses incorrect assumptions about VIC ratios and traffic
generation rates,and proposes mitigations that essentially shift and
increase the traffic burdens onto traffic going and coming from Wilmington,
Harbor City,and Rancho Palos Verdes,that is not related to San Pedro in
any way.Further,none of the proposed Alternatives consider on-site
features to mitigate mitigations such as on-site work centers,increased
open space to address recreation trips,and additional library space.
6.The DEIR uses data that differs markedly from data included in the San
Pedro Community Pla~{,~:R9~~Jlr~;}=m~;;(:k~,?should be consistent.
;<{)~;~~~:"';;'~'.'%',,.:~:,lt ~..'?B:.tf:.6',~::,~;}~~,)-
7.The analYSes•.•.a..'~/.'.'*"iJ·P.·.•.:·~'lr.·el.:'.·:'.""'~"'~"'~:.:.'.:,.e.......•.,.d..,.•.•.z.~.'.•~.t.~..·•.ifg..:.•.:.~.:.I.i.~.:....•·,·:::.:.:.:.:.~.'•.~.:.:;;.•.•.:~t..t.'.·fd.~:.'.•.P.~.L.·::y'•..'•.:·.•·.•~.•:~n.,.....•h,•.0.,....•..u.se Gas Emissions,Hazardous Mat&tJ:a1§l /Ctbo$····.lana~~..:.and Service Systems
are inadequat~P~d~_:.·.....:rnu'sr6e"revl~Prf5:>
8.The DEIR"Wcm :'t_d!~tives.It focuses
almost exclPsivelltlPp@:t§a,!~1:~151','."'.':c~RIe id~rtifying Alternative
C with 8~~utllti;r:ias'~;:'mfi"se":"%p:tlerrei~alternative,and
i nadeqUate~.•.;.",.anll.•i!.':.•.:.~.:..~..~,:.I.•,••,.,,:.s.A;.'.,JJe...•.......•.r,ikJ.·•.....~v ~~z.:.:::ff:.:.·.:~.%.,,3~..••.,~'"......•".u ~.·,.~"W,.,:,.5 de..s,p..•..,.(;lte its having even~~~;~s,:~.vi~m:'~s~.J rI._~:~~ora:;yn~i~~e~i~
exception shG~!d b~;'~\1o{allf . ·..e ap'pij~antJ'F:tbre than ItS share of
un 'lts allowed b~;i;"I·,..¢4;.;··':"{?'\'"..ii'-:::w.Jjfil.·«"';;x·,,«'ti···";/·l;XjjJf'l\i.w</<'x:·,.·:.>",···.,....~~~/.ff':V':?:.,;,,:::::,'(l .;;,.'.";»·;t:i,~..$jt;<?qJjJ>WDJ*,)'~·,'*~,.%~Ef)/
9.The DEIR should a-RaF~~Z~~t')n.~.:~da'itfonal alternative that better
addresses the environmerifgj?impa:etS":6f1ne project while creating an open
an accessible neighborhood that represents the values of San Pedro
community.We suggest a mixed-use neighborhood project alternative
that includes access to Mary Star,traditional single-family homes on
appropriately sized lots that allow reasonable private open spaces for
families that live in these homes,with work centers,commercial space,
senior friendly facilities,a range of public open spaces including a 6-acre
public park that complies with the City Recreation Plan,and a library
extension to meet State Guidelines for library space.
The objective of the EIR is to disclose the significant impacts of proposed
actions,to identify meaningful alternatives and mitigation measures to avoid or
reduce environmental damage,and to enhance public participation in the
planning process.
638 S.Beacon Street Box 688 •San Pedro r CA 90731 •(310)-732-4522
www.nwsanpedro.org
3
2-26
In this case,the DEIR relies on outdated,inaccurate,incomplete,inadequate,
confusing,and often misleading information that does not help the advisory-and
decision-making bodies make an informed decision.A meaningful alternative to
a gated subdivision with no public space would be an open an accessible
neighborhood with public open spaces and amenities,not unlike the many
wonderful neighborhoods in the San Pedro community --sadly,this option was
not evaluated.Ponte Vista may very well be the last of the largest
neighborhoods to be developed in the San Pedro community --the tone set by
this development will resonate in the development of smaller infill and
redevelopment sites.It is no surprise that the people of the community want to
be involved --they want to be engaged in a meaningful way.Rather than simply
react to one scheme or another they want the project designers to help them
shape their vision that is also economically viable and rewarding for the
developer who is taking the risk.It is this collaborative manner that we can move
beyond just another gated subdivision to create a unique place for San Pedro
:~~i::::nes best in!~t,~j~:~~~J~o lie fallow.We support
the City's efforts tQW;;ni'r\mQfe'sc~;:JQj'dav•.·.".;t and to streamline
development revie'A!~i!i~"~,m:WliI,'urre;nftrawe"'p and environmental
~~~Ug~~:~ti~~~~h~6b;:i~\I~tm~i:f:~f ~~.~I~'i""';;'.~;a~~;,~~~~~~~~,sl~~::~~~
better.it]:".fj:!I!:f,II"';"ift:,I,,f;t.Jl[J[.•ZfI!.4t%:i~il ';~t
Please consider t~$potQl'iai~j~f~4fliS!.~!~litL~i:¢Jmrrt~ntson the DEIR in
additi?n to thea~tcff)1ed%~rm'el;lq~t IO!~Q~:~.~ljin t~,:DEIR.Thank you
for this opportunltY\~9 su~mlt'~:~~!t,'I ",.""",,:iPn_~rns,d\,Contact me at 310-
831-1975,if you hav~p.ny.elttQ"s:'<:.":1 '..·.A~:<'·<P
Diana Nave,preSide~4rf~~~i{!'~JS)~Y?!
Northwest San Pedro Neighborhood Council
Enclosure
CC:Councilman Joe Buscaino
Olive Reed,President,Harbor City Neighborhood Council
Cecelia Moreno,President,Wilmington Neighborhood Council
Linda Alexander,President,Central San Pedro Neighborhood Council
June Smith,President,Coastal San Pedro Neighborhood Council
Ponte Vista Development Team
638 S.Beacon Street Box 688 •San Pedro,CA 90731 •(310)-732-4522
www.nwsanpedro.org
4
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NORTHWEST SAN PEDRO NEIGHBORHOOD COUNCIL
COMMENTS ON PONTE VISTA DEIR
SECTION II.PROJECT DESCRIPTION
C.PROJECT CHARACTERISTICS
The DEIR identifies Alternative C,for 830 units,as the "environmentally superior"
alternative yet it almost exclusively analyzes the 1135 unit proposal.The applicant
obviously expects that any impacts of the denser Alternate will apply to the less
dense alternate.This is questionable,especially in terms of project characteristics
and proposed mitigations.The DEIR must be revised to evaluate impacts for 830
units to foreclose any interest from this or any future owner to increase the
intensity back up to 1135 units without triggering another entitlement application.
Similarly,Alternate B is identified as an even less impactful alternative but no real
analysis of it is made.Finally,Alternative D,Revised Site Plan,would develop the
site with the same 1135 units as the Proposed Project,however,"In order to
accommodate the required set backs ...the mix of product types ...would be
altered ...{and}the 2.8 acre public park would not be developed ...."The application
should be amended accordingly.
Also,none of the three Alternatives evaluates the impact of SB 1818 on unit count,
population,schools,traffic,services,etc.Since SB 1818 allows the developer to
increase the number of units as a matter of right at any time after entitlement,
either the applicant needs to show conclusively how SB 1818 does not apply to its
application or it should account for the potential impacts of the legislation on its
project.This is especially important because the applicant has made it clear it is
a speculator and intends to sell the parcels once they are entitled.
Specific Plan Zoning
A Specific Plan is proposed with Low Medium and Medium density zoning.The
DEIR generalizes overall zoning for the entire project,not each individual element.
Each parcel within the development should have a specific zoning density
attached to it.Individual densities would allow a closer examination of how
to create contextual intensities particularly along the edges of the proposed
subdivision.
The proposed zoning is vague.For example,the proposed single-family units are
not the traditional single-family homes that one finds in an R-1 zone.Rather they
are essentially the type of housing found in areas zoned RD 1.5 and higher.
5
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The apartment buildings need to have a specific zoning that is applicable to the
actual size and density of the proposed development.A Medium density by City of
LA codes extends all the way to R-4 zoning which is comparable to the density on
Fitness Drive,the 6-acre parcel between the Commercial Shopping Center and
the Ponte Vista Property.Figure 11-10,Parcel 7 should be zoned specifically for
their proposed density,not the medium density.The apartments should be
capped at R-3 or lower to provide for an appropriate transition from the
development on Fitness Drive to the lower density units directly to the north.
Private Roads
The DEIR (11-17)states"With the exception of the ...road ...providing access ...to
Mary Star of the Sea High School,all other streets on the Project Site would be
private and access would be provided through two gated entrances ...."In order to
better incorporate this project into the surrounding community and provide better
emergency ingress and egress,the roads should be dedicated public roads.The
road areas should not be used in the calculation of units per acre.
Open Space
The DEIR (11-18)states that "approximately 33 percent of the projects post
development acreage would consist of landscaped common areas ...and parks
(excluding roads)..."Open space would include an approximately 2.8 acre
park ...."Since the park has been deleted from the viable alternatives this
statement should be rewritten.
This same section r~ferences the provision of 102 parking spaces for use by park
visitors and other visitors to the site.With the deletion of the public park,it
appears that the public parking spaces have also been deleted.The DEIR should
be corrected to reflect this change.
Figure 11-8 shows a 1-acre mitigation area within the public park.Since the public
park has been deleted,what happens to the mitigation area?
Building Heights
The description of building heights as 40'-48'does not match the two-to three-
story buildings.This is the building height for four-story buildings.Also,the height
calculation should be specific to the individual housing types and their
locations within in the project.
D.CONSTRUCTION CHARACTERISTICS
The DEIR states (11-33)that "the construction of the project is estimated to begin in
2013 and would continue over a five-year period,with completion in 2017."There
are many references to this 5-year time frame throughout the DEIR.Since the
6
2-29
applicant has requested a 15-year Development Agreement,these
references should be changed to indicate a 15-year build-out and the
construction phase impacts addressed accordingly.
Table 11-3 indicates that the construction of the Public Park and the Landscaping
and Streetscape Improvements would be done in the final year of the 5-year build-
out.Completion of a public park and the landscaping and streetscape
improvements on the exterior of the project should be required prior to
occupation of any unit.
P 11-34 states "...construction staging,laydown areas,and all construction
equipment would be positioned on-site and would be moved from area to area on
the Project Site,consistent with the sequence of Project construction."Since the
project anticipated different developers for each area it is not clear how would this
work?The mitigations need to address the actual impacts.
E.PROJECT OBJECTIVES
Project Objective 6,"To develop a project that fiscally benefits the City of LA."Is
not supported.In order to determine if this project fiscally benefits the City of Los
Angeles it would be necessary to do an economic impact analysis of projected
revenues and costs for each of the alternatives.This should include looking at the
property tax,sales revenues that would be within the City of Los Angeles,and long
term costs to the City for services such as Police,Fire,and utilities.This
objective should either be removed or factually supported.
SECTION III.ENVIRONMENTAL SETTING
B.OVERVIEW OF ENVIRONMENTAL SETTING
The Local Setting description (111-3)should be modified to include the approved 76
unit Volunteers of America (VOA)Navy Village which will be located immediately
to the North of the project and will provide housing for homeless veterans and their
families.Additionally,the discussion of the proposed future Marymount College
educational facilities should include an analysis of their planned expansion at this
site into a full four-year college campus with room for 800 residential students,
1500 total students,and 75 full and part-time faculty.
Please add the following City of Los Angeles Projects to Table 111-2 (111-23)
Cumulative Projects and reanalyze cumulative project impacts accordingly.These
projects will generate considerable traffic impacts that were not included in future
traffic and school calculations:
7
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o Southern California International Gateway (SCIG)
o APL Terminal expansion
o Ports O'Call Redevelopment
o Cabrillo Marina Phase II
o USS Iowa
o Los Angeles County Sanitation Districts Clearwater Outfall Project
o Rolling Hills Prep School build out from 250 students to 1,000
students
o VOA Navy Village
o Pacific LA Marine Terminal
o Harbor Highlands Development (under construction)
o City Dock 1
o Port Master Plan update
o Marymount College Expansion on Palos Verdes Drive North
o San Pedro Community Plan update
G.GREENHOUSE GAS EMISSIONS
Background
The State of California has declared that greenhouse gases (GHGs)constitute "a
serious threat to the economic well-being,public health and the environment of
California."(AS 32).It recognizes that allowing them to remain at current levels
will not adequately address the dangers they pose and has established instead the
goal of reducing them to 1990 levels by the year 2020 (AS 32).
The City of Los Angeles has embraced the effort.It adopted "Green L.A.:An
Action Plan to Lead the Nation in Fighting Global Warning"in May 2007,in which it
proclaims that by 2030 it will reduce GHGs from city operations 35 percent below
1990 levels.
8
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Three gases are felt to pose the greatest threat:carbon dioxide,methane and
nitrous oxide.1 The primary cause of GHG pollution is combustion of fossil fuels.2
In California,fossil fuel use is closely related to motor vehicle use.
Emissions
According to the DEIR,this project will not reduce GHG pollution to 1990 levels.
Indeed,it will not decrease GHGs at all.To the contrary,it will increase them.
The site currently generates no GHGs (p.IV G-4).According to the developer's
projections,the proposed project will generate 15,620.55 metric tons of GHGs
each year.3 That is 15,620.55 more metric tons or 17,222 more American "short"
tons of pollutants every year for the foreseeable future than are generated at the
present,172,220 short tons over 10 years,344,440 short tons over 20 years,etc.
This single fact should overshadow all others for anyone considering the project's
impact on this insidious form of pollution.
The DEIR does address the 35 percent reduction that the City of Los Angeles
seeks to achieve.Moreover,it dwells on minimal reductions such as emissions
from landscaping equipment and the fact that the project's structures are designed
with large "contiguous unobstructed roof areas"which can accommodate solar
panels.Large flat "roof areas"can be found on many structures and hardly
constitute a "green"breakthrough.What is more,the proposal does not provide
for the installation of solar panels on any of the project's roofs.
Proposed "Reductions"
Most significantly,the DEIR's claim that the project will reduce GHGs by 14.579
percent is based upon faulty analysis.As already noted,this project will produce
17,222 more tons of polluting gases each year than are being generated now (the
proper baseline).The 14.579 percent is calculated by comparing the estimated
carbon dioxide levels generated if the project were to be "built as usual,"that is
without any GHG reduction measures,(which would never be permitted and is,
therefore,purely illusory)with levels of GHGs generated by the project they
propose.What is more,it will generate more GHGs than if the project were built to
comply with the parcel's existing R-1 and open space zoning.
Missing from the report is any meaningful discussion about GHG generation once
the project is built and occupied.This period will most likely stretch over decades.
1 California Technical Advisory:CEQA and Climate Change,June 19,2008 -hereinafter
"Technical Advisory"
2 Technical Advisory,p.2
3 It is curious that the DEIR uses the metric system at this point.A metric ton weighs
considerably more than the "short ton"most Americans are used to working with -2,205
pounds instead of 2,000.Accordingly,15,620.55 metric tons translates to 17,222 tons of
polluting gases.
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Emissions from Autos
According to the DEIR (Table IV.G-5)fully 74.5 percent of the projected carbon
dioxide emissions (11,593.77 metric tons or 12,782 tons)will be from motor vehicles,
yet there are no proposed measures to reduce these emissions.
One measure available for a developer to mitigate the amount of driving and the
pollution associated with it is to place its project near existing public transportation
corridors and close to employment centers.That has been the model for
development in downtown Los Angeles in recent years.Unfortunately,Ponte
Vista does neither.As discussed elsewhere in this document,bus service along
Western Avenue is infrequent and inconvenient and hardly constitutes a
satisfactory substitute to commuting by car.Any doubts about this statement can
be satisfied simply by trying to take public transportation from the bus stop at
Western Avenue and Westmont Drive to downtown Los Angeles,to one of the
office buildings along Hawthorne Boulevard in Torrance or even to the port area.
What is more,the project is not near any major employment center.4 Nor is that
likely to change.The recently drafted San Pedro Community Plan does not
anticipate adding any major commercial centers in the area during the next 20
years.In short,residents of the proposed project are likely to have to commute
considerable distances by car to work.
As discussed elsewhere in this document,the project contains virtually no
amenities (except the pool and clubhouse)or design considerations that would
lessen the need to use ones auto.In fact,it even contemplates the use of the auto
to get to the clubhouse and pool as shown by the proposed parking plan.
The report does note that the project will provide recharging outlets to those
residents who own electric cars.Although commendable,sales of such vehicles
are miniscule.Absent some technological breakthrough in battery life and the
driving range of these cars,they are likely to remain so.
Responsibility
The applicant tries instead to rationalize away the need to even address the GHG
problem concluding that no single development is likely to have a significant
impact on GHGs (pps.IV G-15 and 27).Since the problem is planet-wide,that is
probably true.Given the Earth's vast size and total population,it might even be
true for a vast open pit mine in Alberta,Canada or in Australia's outback.
However the fact remains that the project will generate substantial amounts of
GHGs each year.Moreover,the applicant's line of reasoning implies that since no
single person,project or business can be held responsible;none need take
responsibility for them.That way of thinking must stop now or there is no chance
4 Despite the fact that the Project is located near the Port of Los Angeles,many of the
Port jobs are a significant distance from this site.Furthermore,the San Pedro Community
Plan Area has a huge deficit in jobs with a job housing ration of 0.44
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of dealing with these pollutants.Only by forcing each project to confront and
address the issue properly will there be any hope of reducing GHGs and the threat
they pose.
The analyses of the green house gas emissions and associated mitigations
are inadequate and must be revised.
See also our comments under Traffic and Transportation.
H.HAZARDOUS MATERIALS
The DEIR is selective about its risk assessments,particularly as regards the
Defense Fuel Support Point (DFSP)and the Rancho LPG Holdings.
The DEIR says that a risk assessment was done for events,spills,fires,etc.at the
DFSP (directly adjacent to the Project),and notes that "Although larger than
medium-sized spills would result in a larger zone of impact if they were to ignite,
potentially encompassing portions of the Project Site,the emergency access
features of the Project coupled with the remote nature of such an extreme event
would result in a less than significant impact to future Project residents."
It is insufficient and negligent to say the emergency management plan is that
fire companies can enter through two access points on Western and through one
access point from Taper through Mary Star of the Sea High School and that the
Project is within a 4-mile drive of several hospitals.
The DEIR says "implementation of the Project Design Features would require that
evacuation and emergency response procedures be established in an emergency
response plan for a fire impacting the Project,and the consequent risk posed to
Project residents would be minimal."It is puzzling that the applicant can conclude
that the consequent risk is minimal before the emergency management plan has
been developed.
With regard to the Rancho LPG facility,the DEIR notes that "to a much lesser
extent there may be some quantifiable risk of upset from other activities such as
product delivery by rail or truck ...Based on the worst-case RMP scenario and with
the more likely releases having a much smaller radius impact than 0.5 miles,there
would be no impact to the project site."This analysis under estimates the
potential impact to the Project Site,endangering the safety of future
residents,with no proposed mitigations.The US DOT report of butane
incidents by Means of Transportation found that there were 751 rail incidents and
13154 truck incidents in 2003 alone.This is far from an insignificant risk.In many
respects,it would be far more accurate to say that "it is just a matter of time"
before a significant incident occurs.
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In addition,Tosco Refining Company's Risk Management Plan for what is now the
Phillips 66 refinery contains a worst-case scenario (Attachment A)for a butane
incident with a 2.3-mile impact,way beyond the Ponte Vista site.An additional
proof that the risk is far from insignificant is shown in the linked video showing a
60,OOO-pound LPG rail tank car being hurled three quarters of a mile once it
caught fire.s
It is insufficient to simply state that the risk is "extremely remote"if the DEIR
admits that a larger than medium-sized spill were to ignite it would potentially
encompass portions of the Project Site.The DEIR must discuss the potential
effects of a larger than "medium-sized spill"and evaluate the hazards to residents,
not just waive the obligation to consider the impacts on the environment.What
else will the Project do to mitigate the effect on residents of a larger than
medium-sized spill?
Evacuation Routes
According to CEQA Guidelines,the Project would have a significant effect on the
environment if it would "impair implementation of or physically interfere with an
adopted emergency response plan or emergency evacuation plan."The DEIR
erroneously states that there would be no impact with regard to this guideline.
The DEIR asserts "The Safety Element of the General Plan of City of LA pertaining
to response to disaster events does not designate Western Avenue within the
vicinity of the Project as a designated disaster route."Western Avenue only south
of Summerland is designated as a disaster evacuation route.It also states that
Western Avenue is "too far west"for evacuation from the Port and that the City of
Rancho Palos Verdes (RPV)does not consider Western Avenue as an evacuation
route.These assertions are misleading.
Western Avenue north of Summerland is not shown on the evacuation routes map
of the Safety Element of the General Plan of the City of LA,because the map only
shows the portion of Western Avenue that is under the jurisdiction of the City of
Los Angeles.On the map,areas that are not under the City's jurisdiction are in
grey.(See Attachment B)Western Avenue from Summerland to Pacific Coast
Highway is under the jurisdiction of Cal Trans,not the City of Los Angeles.
Western Avenue between Summerland and Palos Verdes Drive North is not
shown as an evacuation route on the City map because it is not "in"the City of LA,
not because Western Avenue is not an essential evacuation route;the DEIR is
doing a selective interpretation of the map,and the result is not credible.
Further,asserting that Western is "too far to the West"for an evacuation route
ignores the fact that San Pedro has only 3 north/south evacuation routes (Gaffey
Street,the 110 Freeway (adjacent to and accessed by Gaffey and Harbor Blvd.),
and Western Avenue.If any of the 2 non-Western-Avenue routes is blocked (note
5 See WWW.YOUTUBE.COMIWATCH?V=XF3WKTWHPIU
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that a portion of North Gaffey Street and a portion of Harbor Blvd.are in
liquefaction zones),Western Avenue may be the only available evacuation route.
San Pedro with the Port operations,storage of hazardous materials,and location
on earthquake,liquefaction,and methane zones,is for more apt to need to
evacuate that any other location in the City of Los Angeles.
The DEIR also misinterprets the Port evacuation plan.Western Avenue may be
too far west for evacuating the Port itself,but it is one of the two,and probably the
main evacuation route for San Pedro and the adjacent cities particularly in the
event of an incident at the Port.
The "entire city of Rancho Palos Verdes,excluding the portion of the City located
east of Western Avenue (approximately 98 acres)is classified as a VHFHSZ [Very
High Fire Hazard Severity Zone by the California Department of Forestry and Fire
Protection]"6 and in 2009 alone 2000 residents of RPV were forced to evacuate
their homes because of wildfires.For the residents of RPV on the west side of
Western,Western Avenue is the only evacuation route available to them.It is not
credible to assert that Western Avenue north of Summerland would not be an
evacuation route for RPV residents.
Anecdotally and based on empirical observation and on comments of emergency
responders at Rancho Palos Verdes Council meetings,congestion on Western
Avenue at the present time can be a significant interference with emergency
responses.It is not unusual to see LA County emergency vehicles going
northbound on the south bound side of this divided highway or vice versa due to
the extreme level of congestion.
San Pedro has really only three viable evacuation routes.One is North Gaffey
Street,which is adjacent to these potential hazardous facilities:Rancho Holdings,
the Defense Fuel Supply Center,and the Phillips 66 Refinery.North Gaffey sits on
earthquake faults and the potential for a fire is great.In addition,the LAFD (and
LAPD)could easily have Gaffey Street blocked due to potential fire and certain
damage from an earthquake as they did when there was a power outage near
Home Depot.
The second principal evacuation route is the 110 Freeway.The City has indicated
that in an emergency,this might be turned into a southbound access way for
emergency vehicles.That leaves Western Avenue as the primary or only avenue
of escape for all 83,000 San Pedro residents,not counting all the Rancho Palos
Verdes residents who would also need Western Avenue for evacuation.Western
Ave.is already clogged during peak hours.It cannot function as an adequate,
viable evacuation route.
The LA City Comptroller Wendy Greuel said in her 2012 report that the Salvation
6 Safety Element of the City of RPV General Plan,adopted June 2010
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Army and the Red Cross are not prepared to handle an evacuation of the City of
Los Angeles.This would particularly apply to an isolated area like San Pedro,
surrounded on three sides by water and with very limited egress routes.In a
disaster,San Pedro could quickly face serious challenges.
Further,the assertion that "traffic will be controlled in the vicinity of the Project"in
the event of a disaster raises a concern that traffic attempting to travel north on
Western Avenue and out of San Pedro and Rancho Palos Verdes will be delayed
while Ponte Vista security attends to Ponte Vista and makes sure it is evacuated
first.This will produce an unacceptable situation and must be addressed in
the DEIR.
The jurisdictional boundary problem cannot be an excuse.The project's impact
on evacuation routes must be reanalyzed and appropriate mitigations
developed.
J.LAND USE &PLANNING
The rezoning request will impair the orderly implementation of Regional
Plans,City's General Plan,and two Community Plans.The DEIR fails to
evaluate conformance with the ten Urban Design Principles and nine
Walkability Checklist items.The gated pattern would physically divide an open,
accessible,and established community.
It is not possible to evaluate the environmental impacts of the project because
insufficient information has been provided.In many cases,no information has
been provided.
The DEIR is legally insufficient and needs to be redone.Alternatively,we
encourage the developer to host a planning and design charrette in the
community.The objective of the charrette is for all stakeholders to come together
and develop a preferred layout that accommodates the developer's desire for
more intense development than what is allowed in the current zoning but also
meets the community's desire to create an inclusive neighborhood that complies
with Community Plans,General Plan,Regional Plans and City's Urban Design and
Walkability criteria.
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REGIONAL PLANS
Regional Transportation Plan
The Regional Transportation Plan (RTP)provides a long-range vision for regional
transportation investments and considers the role of transportation including
economic factors,environmental issues and quality-of-Iife goals.
The DEIR references the 2008 "2012-2035 Regional Transportation Plan (RTP)/
Sustainable Community Strategy (SCS)".This is the old version of the Plan.The
DEIR should have used the current 2012 RTP/SCS,rather than the 2008 version,
especially since the current version is much more thorough in how to address
redl;lcing greenhouse gasses.
The Sustainable Community Strategy [SCS]portion is a new element of the RTP
that demonstrates the integration of land use,transportation strategies and
investments to meet the region's greenhouse gas reduction targets.The key land-
use policies include focusing growth in centers and along major transportation
corridors around existing and planned transit stops,and creating significant areas
of mixed-use development and walkable communities.
The DEIR does not comply with the requirement to address the Regional
Plan because it does not address how the proposed subdivision brings together
land use and transportation strategy to reduce trips and resulting greenhouse
gasses.It does not even attempt to reduce auto-related greenhouse gasses.
Furthermore,the project does not create opportunities for residents to walk to local
destinations nor does it promote bicycling.Why isn't bike parking a compliance
measure?What if anything will the project do to enhance bicycling on Western
Avenue?
The DEIR fails to address the 2004 Compass Blueprint Growth Vision
Report.The Compass Blueprint Growth Vision is a regional consensus to the land
use and transportation challenges facing Southern California now and in the
coming years.The DEIR is required to address the Blueprint.
The Growth Vision is driven by four principles:
1.Mobility -Getting where we want to go
2.Livability -Creating positive communities
3.Prosperity -Long-term health for the region
4.Sustainability -Promoting efficient use of natural resources
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Mobility:The Mobility principle encourages mutually supportive
transportation investments and land use decisions.A key strategy is to
design complete streets that promote walking,biking,and transit use.There
is no discussion at all how the proposed subdivision supports this principle.
Livability:The livability element promotes mixed-use development in
"people-scaled"environment.The proposed project includes only residential
uses only,and then limits access.The document makes a few conclusory
statements on the subject,but they are mere assertions with no facts and no
discussion.
Prosperity:The project includes single-family residences,town homes,
and flats.A range of other uses and building types would better promote
long-term health of the region.The gated nature of the subdivision signals a
disinterest in civic engagement.Mixed use and encouraging civic
engagement are very important to future vitality of a community.Also the
single-family element is illusory;they are not true single-family homes.They
are located on small lots without the yard space that is typical of a San
Pedro single-family home.
Sustainability:Efficient buildings within compact,diverse,and connected
communities encourage walking,biking and transit use,thus reducing
energy consumption,trips and air pollution.The DEIR lacks adequate
consideration of this requirement.For example,although 75%of energy
needs can be addressed with building layout,placement and design,no
specific provisions are made to integrate a multi-modal split or to certify the
project under LEED-ND.
The proposed gated subdivision utterly fails to meet all four principles of the
Compass Plan.The Compass Plan website?features many proposed and built
development as best practices.None are gated subdivisions.
Los Angeles General Plan
The Los Angeles General Plan and its Land Use Framework provide the basis for
land use recommendations in the Community Plans.
The site is located at the southern edge of Wilmington-Harbor City Community
Plan Area and just north of the San Pedro Community.Both community plans are
more recent than the General Plan.Therefore,the community plan's
recommendations are more reflective of the current vision for the site.The
Wilmington-Harbor City Community Plan was last updated in 1999.In August
2012,the Planning Department,working with the San Pedro Neighborhood
7 www.compassblueprint.org
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Councils, released a draft update to the San Pedro Community Plan (SPCP).The
SPCP Plan has the most current vision of the City and the San Pedro Community.
The proposed project does not meet Objective 4.3 of the General Plan
Framework,to conserve scale and character of residential neighborhoods.
According to the Planning Department's prior report,
The Ponte Vista site is ...not identified for higher-density residential land
uses ....is not located within a Neighborhood District,a Community Center,a
•Regional Center,a Downtown Center or a Mixed-Use Boulevard ....the
General Plan Framework does identify downtown San Pedro ...and the area
around the intersection of Avalon Boulevard and Anaheim Street in
Wilmington ...as the Regional Center and Community Centers for the Harbor
area.In addition,these areas are also identified for Mixed-Use Boulevards .
.Denser residential development should be focused at these locations and not
at a location such as the Ponte Vista site that has limited access to services,
facilities,and public transit.It also has not been identified for targeted growth
in the Framework Plan ....8
As discussed extensively elsewhere in these comments,it also does not meet
Objective 3.2 "to provide for the spatial distribution of development that promotes
an improved quality of life by facilitating a reduction of vehicular trips,vehicle miles
traveled,and air pollution.
San Pedro Community Plan (SPCP)
The SPCP states that while Ponte Vista "is located just outside and north of the
San Pedro Community Plan Area,this approximately 60-acre site presents an
opportunity for an integrated mixed use and mixed density neighborhood.Its size
and proximity to San Pedro calls for a development that is physically connected to
the San Pedro community and provides public facilities and amenities that serve
neighboring residents."
Land Use Policy 4.5 states,"new development at Ponte Vista should include a mix
of uses and densities,a range of housing types,neighborhood services and
amenities,compatible with and integrated into the adjacent San Pedro community.
Development of the Ponte Vista site should be:
Designed to provide a mix of housing types for a range of incomes;
•Compatible with a Low Medium density designation;
•Open and accessible to the community,and not developed as a gated
community;and
8 2009 Department of City Planning Recommendation Report CPC 200608043-GPA-ZA-
SP-DA,Ponte Vista Specific Plan,page F-2.
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•Developed with accessible public open space,community facilities and other
public amenities."
The NWSPNC commented during the drafting process for the Community Plan
Update and at the public hearing that it is inappropriate for the Planning
Department to designate the area as Low Medium density in the SPCP Update as
to do so would be a commitment to the designation before the environmental work
had been completed and approved by the City.Since the final version of the plan
has not been released,we do not know if this bullet has been removed.
Nonetheless,the proposed project is in conflict with the three other policies.
Housing Types
A housing typology is a sequenced range of building types,whose design has
evolved based on time-tested practices.These typically follow social and cultural
norms,financial schemes,market preferences,prevailing climate and
technological efficiencies.A variety of housing types can accommodate a range of
incomes and family types.
The proposed project provides a very narrow range of building types.There are a
number of other types and styles that should be considered such as duplex,
triplex,quads,bungalow court,live-work,courtyard housing,hybrid court,and
commercial flex buildings.See the also discussion of the inadequate analysis of
option B and Attachment C that shows some San Pedro Building types.
Great neighborhoods possess both a distinctive public realm and a rich and
complex fabric of buildings designed and built on private land.Public places
depend on the incremental design of individual buildings around them.The more
harmonious the choice of such buildings,the more distinguished the ultimate form
of the place.Conversely,the more random the choice of buildings,the more
residual the urbanism.
Open and Accessible to the Community:
The proposed gated community is not consistent with the most current
vision of the City and the adjacent San Pedro Community for the site.The
problem with gated communities is not the gates but the vicious cycle of attracting
like-minded residents who seek shelter from outsiders and whose physical
seclusion then worsens paranoia against outsiders and threatens the unity of the
community.A homogenous environment diminishes awareness of all that is
different and lessens concern for the two communities beyond the subdivision
walls.
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Open Space and Public Amenities:
Among the key residential neighborhood issues and opportunity areas of the
SPCP is "preserving small neighborhood-serving amenities within residential areas
[which]serves the larger goal of reducing vehicle trips by making walking or
bicycling more viable options for simple conveniences.The proposed plan fails
to include any neighborhood-serving amenities.9
As a valuable community resource,open space on this 61 .S-acre site can provide
visual delight and recreational opportunities while providing ecological and
economic benefits.A range of open spaces close by encourages people to spend
more time outside engaging in physical activity,such as walking,that reduces the
risk of obesity,diabetes,heart and mental illness,while increasing social
connection and a sense of community.
All of the alternatives lack a public park.Some residual parcels are called out as
open space for the residents of the subdivision.This is a monumental missed
opportunity for the Wilmington-Harbor and Northwest San Pedro Communities,but
an even greater loss for the future residents of this subdivision.
Open spaces must be carefully integrated with block,street,building and frontage
standards to work in consort to create a unique place.Open spaces should include
a diverse range of integrated public spaces at the block,neighborhood,and
community level.The individual building types should also specify private open
spaces at the lot and building level.This approach will allow residents access to a
range of public and private open spaces.
Additional Plan Considerations
The NWSPNC requested that the following four bullets be added to the discussion
of the development of the Ponte Vista site in the SPCP:
o Promote home-based offices
o Encourage senior friendly facilities.
o Encourage on site businesses such as a coffee shop or convenience store.
o Through the mitigation process,this development or any single
development should not be allowed to use up all of the development
potential for the surrounding community.
The proposed project does not address any of these.
While not specific to the Ponte Vista site,the SPCP states the "The need for
affordable senior housing and assisted living facilities is a key concern due to
demographic and economic trends and projections.In San Pedro,such facilities
9 Draft San Pedro Community Plan,August 2012,page 37
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would increase the opportunities for those 'empty nest seniors'looking to
downsize from large single-family homes while remaining within the community
and the reach of supportive social,cultural and family networks.,,10 The lack of
any senior housing in this project would be a significant missed opportunity.
Wilmington-Harbor City Community Plan (WHCCP)
The proposed project does not meet the fundamental premises of the
WHCCP.The first premise is limiting residential densities in various
neighborhoods to the prevailing density of development in these neighborhoods.
Although the six acres immediately adjacent to the South is multi-family,this is an
anomaly.This property was zoned commercial with the expectation that it would
be used in such a manner.Unfortunately,the same code allowed the multi-family
structures to be erected in a manner that is not compatible with the surrounding
community.The surrounding neighborhoods are single family R-1,with the
exception of the Gardens that is 13.5 net dwelling units per acre.In fact,according
to a recent study,80%of the land along the Western Avenue corridor
(Summerland to Palos Verdes Drive North)is dedicated to single-family residential
lots.11
Furthermore,the WHCCP (1-54)designates specific areas for Low median density
and this is not one of them. Instead the plan (IV -3.8)policy is to "encourage
reuse of the existing US Navy housing areas ...in a manner that will provide
needed housing ...without adversely impacting the surrounding area."Clearly the
plan did not consider this property suitable for multi-family housing.
The second and third premises are
...the monitoring of population growth and infrastructure
improvements through the City's Annual Report on Growth and
Infrastructure with a report of the City Planning Commission every five
years ...following Plan adoption....If this monitoring finds that
population in the Plan area is occurring faster than projected,and that
infrastructure resource capacities are threatened,particularly critical
resources such as water and sewerage;and that there is not a clear
commitment to at least begin the necessary improvements within
twelve months;then building controls should be put into effect ...until
the land use designations ...and corresponding zoning are revised to
limit development.
The Annual Report on Growth and Infrastructure has not been done.The DEIR (1-
103)states that the "Projects direct plus induced growth" represents about 91 %of
the growth forecasted within the WHCCP area,thus this single project will use
virtually all of the planned for growth.Considering that there have been other
10 Draft San Pedro Community Plan,August 2012,page 37.
11 Western Avenue Corridor Vision,Preliminary Analysis and Ideas,November 14,2012
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residential developments in the 14 years since the WHCCP was developed,
building controls should be put into place until such a study is conducted.
The proposal is not consistent with Objective 1-2 "To locate new housing in a
manner which reduces vehicular trips and makes it accessible to services and
facilities"and Policy 1-2.1 "Locate higher residential densities near commercial
centers and major bus routes where public-service facilities,utilities,and
topography will accommodate this development."As was pointed out in a prior
Planning Department's Report:
The Ponte Vista site is not located within reasonable walking distance to a
transit station,a transit corridor,or a high-activity center.The closest
commercial services are located along the east side of Western Avenue,just
south of the Project site (approximately 500-feet south).However,walking or
.transit is generally not a viable option to access these services since they are
laid out in a linear fashion within strip malls or plaza shopping centers,with
large parking lots in between the sidewalk and the buildings.12
It is also not consistent with the new vision for Western Avenue that calls for wider
sidewalks,transit,and human scaled environment that would encourage walking.
As the largest new development along Western Avenue,Ponte Vista has an
opportunity to set the tone for others to follow as they redevelop their properties.
The proposal is not consistent with Land Use Policy 1-1.5 to "Maintain at least
67%of residential land uses for single family."The DEIR (IV.M-24)Cumulative
residential projects in the City shows 2,195 new residential units of which only 84
(3.8%)are shown as single-family.Approval of this project would exacerbate that
imbalance...
Furthermore,the proposal is not consistent with Policy 1.5.2 to promote
housing in mixed-use projects in transit corridors and pedestrian oriented areas.
The WHCCP only identifies one such area,Anaheim and Avalon.As discussed in
our comments under transportation,Western Avenue in this area is neither a
transit corridor nor a pedestrian oriented area.In fact the project is isolated and
will require the use of a car for virtually any need.See also the discussion of the
lack of public transportation under Traffic and Transportation.
The proposed project does not meet Objective 8-2 and policy 8-2.1 of the
WHCCP which seeks "to increase the community's and the Police Department's
ability to minimize crime and provide security for all residents,buildings,sites,and
open spaces"and to "support and encourage community-based crime prevention
efforts (such as Neighborhood Watch),through regular interaction and
coordination with existing community-based policing,foot and bicycle patrols,
12 Department of City Planning Recommendation Report CPC 200608043-GPA-ZA-SP-
DA,Ponte Vista Specific Plan,page F-3.
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watch programs,and regular communication with neighborhood and civic
organizations."
The proposed gated environment would likely breed fear,erode social stability and
shrink the notion of civic engagement by encouraging residents to retreat from
civic responsibility.It creates an unsafe environment both inside and outside the
gates.13 The appropriate response to reduce crime,poverty and other social
problems,as recommended by the WHCCP,is for the neighborhoods to work
together.The best way to bring security to the streets is to make them delightful
places that people want to walk in.The streets become,in effect,self-policing.
Fences and gates exacerbate the problem.
Chapter IV of the WHCCP identifies recommended actions.For residential
housing,number 11 is to "encourage the development of housing types intended
to meet the special needs of senior citizens and the physically challenged."
Failure to do so in the proposed project is a real missed opportunity.
LA MUNICIPAL ZONING CODE
The current R-1 zoning is a combination of R-1 and open space.According to the
DEIR,this zoning would permit about 385 units.Alternate C for 830 units would
more than double that development intensity,and Alternate 0 would triple the
intensity.This increased intensity would increase demands on existing community
facilities such as schools,libraries,parks and recreational amenities.In an
uncharitable and perverse logic,future residents of this subdivision would be able
to use all San Pedro facilities but San Pedro residents would not be allowed
access to parks and recreational amenities located inside the gated community.
It is not clear what the trigger is for increased intensity at this location.The zoning
conditions,cost of site acquisition,and removal of existing structures are pre-
existing conditions.These are not appropriate factors or justifications for
increased development intensity.This is especially true for the cost of site
acquisition;the fact that the applicant bank loaned the original buyer far more than
the property is worth,is not an appropriate justification for failure to consider
Alternative B.According to the DEIR Alternate B houses would have to sell for
more than $1,000,000.
No support whatever is provided for this claim.However,using the January 2010
"Residential Building Costs"published by the State of California Board of
Equalization 14 the cost of building good quality single family houses is far less than
claimed by the applicant.The 216-page publication provides building cost data for
a variety of residential building types,sizes and quality.The costs include
13 Blakely,E.J.,and M.G.Snyder.(1998)."Separate places:Crime and security in gated
communities."In:M.Felson and R.B.Peiser (eds.),Reducing crime through real estate
development and management,pp.53-70.Washington,D.C.:Urban Land Institute.
14 http://www.boe.ca.gov/proptaxes/pdflah531.pdf
22
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entrepreneurial profit and adjustments for location where the units are to be
constructed.They do not include discounts for multiple units being constructed at
the same time however,which would make the cost even lower.
By way of example,the cost of constructing 385 good quality single-family houses
on 61.5 acres with a land cost of $120 million would be $584,728.31 each,far
lower than the unsupported claim of the applicant.15 .
We chose a quality level 08 home of 2000 square feet.16 There are 10 levels of
construction quality,with 10 being highest.The publication includes descriptions
of each quality level and photos of each type.From observation,San Pedro would
mostly consist of level 06 quality.We used level 08,a much higher quality level.
A description of the characteristics of 08 quality,photos of examples of houses of
that quality,and the cost of construction are attached as Attachment D.Had we
used 06 quality level,the cost per house would be $474,751.31.
Further,the analysis of Alternative B claims there will be no open space even
though 15 acres are zoned open space.It also claims that Mary Star will lose road
access through the property.These assertions are true only if the City allows that
to happen.
URBAN DESIGN PRINCIPLES
In 2009,the City Planning Commission approved Urban Design Principles to
provide guidance on how street,block and open space design can create
desirable and resilient neighborhoods that instill a sense of community.
The ten Urban Design Principles are:
1.Develop inviting and accessible transit areas;
2.Reinforce walkability,bikeability,and wellbeing;
3.Nurture neighborhood character;
4.Bridge the past and future;
5.Produce great green streets;
6.Generate public open space;
7.Stimulate sustainability and innovation;
8.Improve equity and opportunity for all;
9.Emphasize early implementation,simple processes and
maintainable long-term solutions;and
15 385 houses at 2000 sf each,=770,000 s.f.Cost from table $124.11 times 1.10 LA
County adjustment =$136.52 psf.Total construction cost 770,000 X $136.52 =
$105,120,140.Add:Land cost $120,000,000 =$225,120,140 total cost land and
construction,or $584,728.31 per house.
16 The unattached houses in the Taper area,Mount Shasta area,and around Dodson
Middle School are 1350 sf to 2200 s.f.with an average of 1800 sf.We use 2000 sf.
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10.Ensure connections.
The DEIR fails to address or evaluate whether the proposed project complies
with these ten Urban Design Principles.They were adopted by the Planning
Commission and should be addressed in the DEIR.
WALKABILITY CHECKLIST
Streets make up the lion's share of the public realm.It appears that streets in this
subdivision are largely shaped by engineering standards intended to regulate the
flow of traffic and infrastructure.
Streets are important civic spaces where the social and communal life of a
neighborhood takes place.The street design inspires the context.Mobility is a
means,not an end.Streets must be inviting,safe and secure place for walking,
biking and transit for people of all ages,income and physical limitations.Less
driving,reduces energy consumption and greenhouse emissions.Walking and
biking improves overall health of the community.
The proposed site plan shows front-loaded garages with driveways.A front of a
home should face another front and conversely the back should face another
back.In many instances,the front frontages face the side or back of another
home.These basic principles are important because they establish the context for
the street and have a direct impact on walkability.
The City's Walkability Checklist is a guide for consistency with the policies
contained in the General Plan Framework with respect to urban form and
neighborhood design.The purpose of the Walkability Checklist for Entitlement
Review is to guide Planning staff,developers,architects,engineers,and all
community members in creating enhanced pedestrian movement,access,comfort,
and safety.The Checklist provides guidance on nine topics:public sidewalks,
crosswalks,on-street parking,building orientation,on-site parking,landscaping,
building facade,lighting and signage.
The DEIR fails to make a finding of conformance with the policies and
objectives of the General Plan related to the project's walkability.Walkability
conformance is potentially significant due to the exclusive and gated pattern of the
proposed development.
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L.POPULATION AND HOUSING
PLAN FRAMEWORK ELEMENT
Objectives
The DEIR indicates that one of the relevant objectives is:
4.2:Encourage the location of new multi-family housing development
to occur in proximity to transit stations,along some transit corridors,
and within some high activity areas with adequate transitions and
buffers.
The proposed project does not meet this objective.The location of the project
is isolated with extremely limited public transit options as discussed in the
transportation comments.Residents of the proposed development would either
have very long walks (highly unlikely)or drive to everything.
Housing
The DEIR (IV.I-22)states that "The jobs-housing ratio in the City of Los Angeles
Subregion -Le.,the numerical ratio of 1.34 jobs to households -was very close to
the ratio for the SCAG region as a whole in 2010 (1.37)...and is therefore
considered close to "balanced."By adding 490 indirect/induced jobs the Project
would have no impact on the Subregion's 2010 jobs-housing balance By 2017
however,the Subregion is forecasted to add households at a faster rate than
jobs ...such that the Subregion would be considered "housing right/jobs poor"....
By adding 490 indirect/induced jobs ...the Project would have a neutral numerical
impact...."
The premise of this description is flawed leading to a false conclusion.The
description fails to note that the local job/housing balance that is significantly
different than that of the Subregion.According to the draft San Pedro Community
Plan,San Pedro has a jobs/housing balance of 0.44.The addition of 1135
households would therefore further reduce the jobs/housing balance in the area.
This is a significant negative impact and indicates that the project would be
primarily a commuter community.Mitigation measures should include the
creation of jobs on site.
We question the SCAG growth estimates and hence the need for additional
housing since the 2010 census actual population numbers are well below SCAG
2005 estimates and projections.The DEIR (IV.L-9)discusses the SCAG Regional
Housing Needs Assessment that was developed for the period January 1,2006 -
June 30,2014.This is an old document.The new version of this document
should be used.Furthermore,this old version has been shown to have grossly
overestimated the projected growth for Los Angeles in general and San Pedro in
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particular.For example,the SCAG 20005 population estimate for San Pedro was
82,112;however,according to the 2010 census there are only 76,651 persons in
San Pedro,5,461 fewer.If the 2.5%growth forecast from 2010 through 2017
were applied,this would add 1916 to the population of San Pedro by 2017 still
significantly below the 2005 SCAG forecast upon which the housing needs were
developed.Consequently it is in error to conclude that the project will not
induce substantial population growth in an area by proposing new homes.
The justification for multi-family housing types is erroneous.The
surrounding area is not all multi-story,multi-family housing.About 60%of San
Pedro is multi-family;there is a glut of such housing on the market in San Pedro,
some of it immediately south of the project.[While some of the condo projects
built in the last five years are occupied,they are rental units because the
developers cannot sell them].Single-family housing is the housing type in
greatest demand.
Moreover,by building what it proposes,the applicant will undercut and greatly
impact the Community Plan for San Pedro that emphasizes the rebuilding and
renaissance of downtown San Pedro.The creation of a livable,walkable
downtown area has been challenged by a lack of demand for the condos that have
been built there.
M.PUBLIC SERVICES
The City has the obligation and responsibility to provide the necessary services to
enhance our quality of life.The City is already being challenged to do so.Ask any
tax paying citizen who has had to wait for requested police or fire response or who
is witnessing the decay of their neighborhood for lack of tree trimming,street
sweeping,street and sidewalk repair,failing schools and the list goes on.
The Ponte Vista DEIR,with its 4,009 direct and indirect residents,seems to base
its claim that the impact of the preferred plan would be 'less than significant'and
'less than significant with mitigation'on the fact that no new fire or police facilities
would be required.The claim is an attempt to make a case for building as large of
a project as possible without considering the real consequences it will have on the
existing community;it is not just about buildings,it is about impact on the
community including the availability of personnel to respond to called for services
and to participate in proactive crime and fire prevention measures.
This project is being developed in an existing area that currently requires a
comparatively limited number of calls for services,therefore,any increase should
be considered significant.The project area is currently zoned for R-1 and open
space,which would be the ideal 'fit'for the existing neighborhood community and
have a minimum negative impact.This describes Alternate B,which has less of
an environmental impact than Alternate C,the preferred Alternate.
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Admittedly determining the anticipated impact of this project on the existing
community is purely a speculative process generated by infinite unknowns.Calls
for service may result from intentional and accidental human acts and acts of
nature,some minor and others more serious or even catastrophic in nature,but all
significant to those impacted.
What is clear,however,is that the more people,the more buildings,the more
streets,the more cars,etc.,the more significant the demand for police,fire,and
EMT/ambulance services and the higher the probability of an unacceptable level of
service in the Harbor Area.In fact,in a recent editorial the Daily Breeze
(December 31,2012)states "Unacceptably long response times are dogging the
Los Angeles Fire Department and must be addressed immediately.It's a matter of
life and death,as illustrated earlier this month by the case of a 16-year-old boy
who collapsed while playing soccer at Wilmington Middle School."The mitigation
pro~osed in the DEIR relative to first responders is limited to on-site measures.In
reality that's all the developer can do because they do not have the power to hire
more first responders or purchase needed vehicles.
Parking in streets and parking structures vs.private garages,apartment living vs.
single family residences,real park space vs.limited green space,more cars on
already overburdened streets are but a few examples of conditions with the
potential of having a significant impact on calls for services.The current plan is
more conducive to creating a contentious rather than harmonious neighbor.
Another significant fact to consider is that the project is located at the tip of a
peninsula and not adjacent to other L.A.City first responders.Needed assistance,
in extreme emergencies,mayor may not be available from neighboring cities or
the County.Help from L.A.City Fire and Police stations are unspecific miles away
depending on the availability of their first responders at the closest facility.The
Harbor Area is exposed to a much higher level of hazardous sources that could
result in devastating consequences and liability issues than any other part of the
City.The most volatile and closest to the Ponte Vista site is Rancho LPG.The
City can ill afford minimizing and ignoring the vulnerability of Ponte Vista and its
4,009 residents.According to the EPA Guidance to enforce 40 CFR Part 68,if
57,000,000 pounds of butane (roughly one of the refrigerated Rancho tanks)were
released,the blast radius would be 3 miles.
1.FIRE PROTECTION
The analysis of fire protection and proposed mitigations is inadequate.
The DEI R states that all public street fire lane cul-de-sacs shall have the curbs
painted red or be posted "No Parking Any Time"prior to the issuance of a
Certificate of Occupancy or Temporary Certificate of Occupancy for any structures
adjacent to the cul-de-sac.
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The streets in the project are proposed to be private streets,so where will the
"public"street fire lanes be?This contradiction should be fixed.Where will the
guests park?Please state how the no-parking zones and red curbs will be
enforced.What if cars are illegally parked in red zones and in private lanes
making it impossible for emergency vehicles to get through?
The DEIR section on Fire Protection says that the Project is not within the
maximum response distance between residential land uses and a LAFD fire
station.The DEIR says that this will be mitigated by sprinkler systems installed
throughout all structures to be built as part of the Project.This is taken from
LAMC,but requires clarification.
The proposed mitigation states sprinklers will be installed throughout all structures
but does not specify if fire sprinklers will be installed inside every residential unit.
"The US Fire Administration supports the recently adopted changes to the
International Residential code that require residential fire sprinklers in all new
residential construction.It is the position of the U.S.Fire Administration that all
Americans should be protected from death,injury,and property loss resulting from
fire in their residence.All homes should be equipped with both smoke alarms and
residential fire sprinklers.,,17 Please clarify the DEIR and address implications if
sprinklers are not installed in every residential unit.
The DEIR fails to address the anticipated response times for paramedic/EMS
services provided by LAFD.Additionally,Western Avenue is the main access road
for ambulances to the Little Company of Mary Hospital in San Pedro and an
important access road to Kaiser Permanente Hospital in Harbor City.The DEIR
should include mitigations for the longer response time in EMS/paramedic
services.In emergency medical situations every second counts!Proposed
mitigation might include,but should not be limited to,defibrillators on site.Please
address this issue.
The DEIR correctly states that "The LAFD's ability to provide adequate fire
protection and emergency response services ...is also determined by the degree to
which emergency response vehicles can successfully navigate the given access
ways and adjunct circulation system,which is largely dependent on roadway
congestion and intersection level of service (LOS)along the response route."The
DEIR indicates that two of these intersections are currently operating at LOS E or
F,and goes on to state that "None of the intersections that provide direct
emergency access to the Project Site [Western &Green Hills,Western &john
Montgomery]currently operate at LOS E or F during peak community hours."
While it may be true that neither of the intersections that provide direct access
currently operated at those levels on the day they were studied,the conclusion is
misleading.The proposed primary entrance to the facility is at Green Hills Drive
and John Montgomery Drive.When San Pedro has one of its legendary (and
17 Source:US Fire Administration,June 2009
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frequent)lengthy funeral processions (a local custom,or during Christmas
shopping season,or when there is an emergency situation or road repair (not an
infrequent occurrence),Western Avenue backs up for blocks.It is not unusual to
see emergency vehicles trying to go against the traffic on this divided highway.In
addition,what good is it if that intersection is open but Western and Palos Verdes
Drive North or Western and Capitol,are blocked.The additional traffic from the
proposed development will only compound this situation.
The DEIR should also address how additional residents of the Project would
affect availability of EMS services.
Mitigation measure IV.M-9,Project Design Features,discusses the development
of an emergency response plan and indicates that during the development of the
plan the Project Applicant should consult with neighboring land uses.None of
mentioned users includes the residents.Please add the Northwest San Pedro
Neighborhood Council,the Harbor City Neighborhood Council,and the City of
Rancho Palos Verdes to the list.Please also add a requirement that the
emergency response plan should ensure that there would be no adverse
impact on the evacuation of surrounding neighborhoods as a result of any
evacuation of the project area.There is no guarantee of additional police or
firefighters to meet the additional demands.
Additionally,the development of the Emergency Response Plan should be
included Table I-I as either a Compliance Measure or a Required Mitigation
Measure.
2.POLICE PROTECTION
For purposes of analysis of impact on police services and possible need for
additional police officers,it is assumed that the Project would result in a net
addition of 4,009 persons to the Harbor Area.Population increase in an area
typically increases demand for police services.The applicant however,says that
security and design features in the project should help to decrease need for police
services.This mayor not be true.We suggest that the Project be required to
include Anti-Graffiti measures and comply with street lighting guidelines as
if the streets were public streets.
Additionally,the DEIR should examine the impact on police services in the
event that the gated nature of the project is not approved.
3.SCHOOLS
There are several problems with the methodology used for the school impact
analysis.
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The student generation rates used are not consistent with those used by the City
in the DEIR for the San Pedro Community Plan Update.That document says the
LAUSD student generation rates for multi-family residential units are 0.2042
elementary (K-5),0.0988 middle school,and 0.0995 high school.According to the
Community Plan DEIR the "rates vary slightly with single-family,units,but provide
an accurate approximation.,,18 The DEIR projects two different student generation
rates for Taper,a rate of .1705 per du for single family,and .1141 for the condos
and townhomes.The LAUSD generation rates cited in the DEIR for the San Pedro
Community Plan update should be used.Additionally,the students generated by
the approved,but not yet built Harbor Highlands development must be included in
the analysis for Taper and Dodson.
The school enrollments and capacity should both use the total school capacity and
total enrollment.The DEIR incorrectly indicates the school enrollments for
201'1-12.According to LAUSD's website,the 2011-12 enrollment was 626 at
Taper,1819 at Dodson,and 3335 at Narbonne.According to LAUSD,the current
enrollments (12/12)are 629,1863,and 3350 respectively.(See Attachment E).
According to LAUSD,these enrollment figures include both the regular school
students and the magnet school students.Likewise the capacity figures used must
include both the regular and magnet school capacity.The chart below uses the
current student population and capacity data obtained from LAUSD on January 4,
2013.19
Current Ponte Harbor Total Capacity Difference
Students Vista20 Hiahlands
Taper 629 231 27 887 804 83
Dodson 1863 112 13 1988 1892 96
Narbonne 3350 113 O~l 3463 3531 (68)
As can be seen,if the correct,current figures are used,both Taper and
Dodson would be over capacity.This is a significant impact and must be
addressed.
Certainly the cumulative impact of school-related traffic is a major and possibly
unmitigated consequence of any new development on the property.The reality is
that children at all grade levels,particularly the elementary level,DO NOT,for the
most part,walk to school anymore.They are almost exclusively driven,resulting in
18 San Pedro Community Plan DEIR p 4.12-31
19 The Current Students and School Capacity figures were obtained from Bruce Takeguma,
Director,LAUSD,School Management Services (213)241-3344
20 For Ponte Vista and Harbor Highlands the student generation rate from the San Pedro
Community Plan was used.
21 Although Harbor Highlands will generate 13 students,they would go to San Pedro High
School,not Narbonne and therefore are not counted here.
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serious traffic tie-ups at both ends of the school day,as well as many unique trips
in and out of any development.This is particularly true in San Pedro where a
variety of relatives are available to pick up and deliver children to and from school.
Mitigations should be proposed to encourage children to walk to Taper and
Dodson.
Developer fees from SB 50 would be approximately $900,000.We understand that
State law concludes that the contribution meets all CEQA requirements.However,
the adequacy of the contribution to provide increased need for facilities does not
address the impacts on traffic and the need to protect children on the way to and
from school.It would seem useful to use at least a portion of those monies to
improve traffic flow and control around impacted schools,particularly Taper Ave.
Elementary.
Additionally,the discussion of the Port of Los Angeles High School should be
revised to indicate that the school currently has a waiting list and that admission is
by lottery.
The list of high school magnet programs should be revised to include the Teacher
Prep Academy located on the campus of Harbor College and Trinity Lutheran
should be added to the list of Private Schools.
4.PARKS and RECREATION
The City's Public Recreation Plan calls for 10 acres of land per 1,000 persons and
provides that "A minimum of 10 percent of the total land area should be in public
recreation or open space.It also says that Neighborhood Parks should be
provided at a minimum of two acres per 1,000 residents and be five to 10 acres in
size with a service radius of approximately one-half mile."Based on this standard,
a project with an estimated population of 2,923 should contain at least a 6-acre
Neighborhood Park.The Recreation Plan indicates Neighborhood Recreation
Sites typically include facilities for active sports such as softball,basketball,
soccer,and volleybal1.22
Currently 15 acres of the property is zoned open land (parks and recreation).It
seems logical that park space (active and/or passive)should be a top priority.The
DEIR is based on a project description that includes a 2.8-acre public park that
even if it were built would be inadequate.Subsequent to the initial description,the
applicant deleted all public park space from the proposed project.
The applicant claims impacts related to parks and recreational facilities would be
less than significant,as the two swimming pools on the property and what can only
be described as mini-parks or "parklettes"scattered around the property will fulfill
the project's residents'needs for recreation space.While these amenities are
22 See Los Angeles public Recreation Plan page 2 for a complete list.
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commendable,they do not constitute a Neighborhood park and do not satisfy the
requirements of the City's Public Recreation Plan.The theory in the DEIR seems
to be that residents will not use external truly public facilities,with the result there
will be so little additional usage of public parks that impact will be insignificant.
Where will the youth play basketball,football,tennis,and soccer?
The lack of adequate park space is a significant impact.It is insufficient to say
that the project will pay the required Quimby fees.Quimby fees do not provide
land for parks and there is no land available for purchase within the half-mile
service radius.
This development team,as did the team before,predicates its plan on a truly
mystifying lack of interaction between the development and the world surrounding
it.No traffic,no impact on schools,no pressure on recreational facilities-no need
for 'any improvement to infrastructure beyond the bare minimum that might be
expected of a strip mall or a 6-8 home development,on a square footage basis.
The assertion that "there is no existing park area at the Project site"is at best
misleading and should be deleted.Currently 15 acres of the site are zoned for
open space.
5.LIBRARIES
The DEIR is not accurate in its assertion that the current San Pedro library,at
20,000 square feet,is adequate size for the population served,and should be
adequate to meet the needs of the increased population added by the
development.This claim is in conflict with the DEIR for the San Pedro
Community Plan that states "The available public library services in the San
Pedro CPA,in terms of library space and permanent volume collection,are
currently inadequate to meet existing demands from the community's residents
based on state library standards ....of 0.5 square feet per person.,,23 The State of
California Library standard requires 0.5 sq ft of library space per resident.For the
existing population of 76,651 residents (2010 census data),library space
available should 38,325 square feet,nearly double the existing space.Since the
project would add nearly 3,000 additional residents,and it would require at least
1500 square feet of additional space.
The DEIR further asserts that the LAPL is "currently planning to build a new West
San Pedro neighborhood library in the future."While it is true that LAPL has
identified a need for a library in West San Pedro,it is misleading to say that they
are "currently planning."The Community Plan for San Pedro recommends a new
14,500 square foot "West San Pedro"branch library,however,this would only
bring library space in San Pedro to 34,500 square feet,still not meeting State of
California library standards for the population of San Pedro.The San Pedro
23 San Pedro Community Plan DEIR p 4.12-40
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Community Plan acknowledges that no location for a "West San Pedro"library
has been proposed or selected,there is no plan for selecting a site,and there is
no current nor anticipated funding for building said library.The fact that one is
proposed is further indication of the need for additional library services,a need
that will be aggravated by the proposed project.It will have a significant
impact on library services and this impact must be mitigated.
The Ponte Vista project has an opportunity to mitigate this defect by incorporating
a public library into the project.The library should be at least 20,000 square feet
to meet State requirements.The San Pedro Community Plan recommends
integrating libraries into multi-use buildings.For reference consider the
Milwaukee Public Library is moving ahead with development of two multi-use
buildings including libraries:one is a proposed 16,000 square foot library topped
with 92 apartments (plus parking).24
The San Pedro Community Plan also suggests that on-line services and virtual
libraries with computer workstations that provide access to the library's on-line
catalog,extensive information databases,multimedia software for students,and
free Internet searching for the public may lessen the adverse impacts resulting
from a mismatch between available ph¥sical library space and resources and the
community's need for library facilities.,,2
N.TRAFFIC
The entire focus of the traffic impact analysis is on measuring the number of cars
moving at the intersections.While the movement of autos is important it is not
sufficient.As the City has shifted its focus to mobility,so should the analysis in the
DEIR.The DEIR fails to address any measured analysis of walking,biking,or
transit and ignores other design features that could reduce car-usage such as on-
site amenities and provisions for home-offices.
The traffic analysis estimates the impacts on streets and intersections in and
around the project.The analysis looks at the ambient growth rate of existing
traffic,the traffic contributed by other projects,the traffic contributed by the project
itself,and compares this traffic load to existing intersection usage,expressed as
the vehicle counts compared to the intersection capacity [VIC ratio].From this,the
analysis determines the "Level of Service"[LOS]in the existing condition and
compares it to the LOS if the project is built.For those intersections showing
certain increases in the VIC ratio,or a decrease in the LOS,the DEIR proposes
mitigation measures designed to lower the impact so that it is not significant.
24See http://urbanmilwaukee.com/2012/02/28/east-library-redevelopment-advances-at-
city-plan-com mission-renderings/
25 San Pedro Community Plan DEIR p 4.12-40
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We have concerns about how the variables were calculated and the
accuracy of the LOS results obtained,about the way in which mitigation is
determined,and the failure to address how to design the amenities on the
site in order to reduce traffic generation.This should be corrected.
1.IMPROPER CALCULATION OF THE VARIABLES
Improper Use of ITE Traffic Generation Data
The project-generated traffic is underestimated because the applicant used the
midpoint data for each housing type while ignoring project characteristics.
The DEIR uses three different ITE housing classifications to predict trip
generation.It uses the average trip generation figures for each classification.
ITE figures represent thousands of studies and a wide range of reported trip
generation figures.In this case,there is no difference between how often
residents of each different type of unit will need to use their vehicle in this project,
but the analysis contains no discussion of this.Instead,the DEIR simply uses the
mid-point figure.For example,the DEIR indicates that a single-family house will
generate 9.57 trips per day while a three-bedroom condominium right next door
will generate 5.81 trips per day.This makes no sense when residents of the
project will have to drive to every destination,whether to work,school,soccer
practice,the gym,church,or the market.The applicant should have selected a
trip generation rate in the reported range closer to the single-family rate because
the project characteristics are so similar.
Further,each trip generation graph in the ITE Manual includes a wide range of
actual trip generation numbers.To select the mid-point is difficult to justify.26 Had
the developer and the City used more appropriate data points within each
classification,as they are permitted to do,and admonished to do by ITE itself,the
trip-end volume would be 10,862 instead of 7,462.AM peak hour volume would
increase from 571 to 851 and PM peak would increase from 669 to 1146.Using
these calculations,and using normalized traffic counts,would greatly increase the
VIC ratios and lower the LOS ratings at many more intersections among the 56
tested intersections.
The VIC Ratios Used as a Baseline Need to be Normalized
The vehicle counts used in the VIC ratios and the LOS calculations are lower than
normal due to the impact of the economy on "real"traffic generation rates.
26 We suggest that perhaps the traffic problems in other areas of the City and increasingly
in San Pedro,Wilmington and Harbor City,can be attributed to this practice of using mid-
point calculations rather than more realistic data.
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The impact is shown in the DEIR counts in 2010,which are lower than earlier
counts taken by the same consultant in 2005 for the prior project,lower than the
counts taken for the Target Store analysis in 2006 and lower than many of the
counts for the Marymount project on Palos Verdes Drive North in 2011,after the
installation of ATSAC/ATCS.For example,the VIC PM ratios for Western and PV
Dr.North are
2005
2006
2010
2011
1.025
1.078
.851
.872
[Ponte Vista I]
[Target]
[DEIR,present project]
[Marymount]
This difference is noticeable at many of the intersections common to all four
studies.
It is shown in concrete terms,for example,by the reports of the annual TEU 27
counts in the Port of Los Angeles (an indicator of workload for Port workers)that
declined from 8.5 million TEU's in 2006 to 6.7 million TEU's in 2009.It is
beginning to recover but has not reached pre-recession levels.
Our concern about the use of the October 2010 data at the height of the economic
downturn has been discussed with the applicant's representative on several
occasions.Normalized data is used in many,many other areas of planning,such
as employment data,business valuations,and indeed,environmental tests.It is
not possible to properly determine true,likely impacts if baseline data is atypical.
That is a recipe for gridlock.
Failure to Include Data from Other Projects
CEQA requires a DEIR to include traffic generated by other known projects in the
traffic generation estimates,The applicant left out a number of such projects,
many of which impact the studied intersections.We listed them earlier in our
comments.We repeat them here:
o Southern California International Gateway (SCIG)
o APL Terminal expansion
o Ports O'Cal!Redevelopment
o Cabrillo Marina Phase II
o USS Iowa
27 Twenty Foot Equivalent Units,a measure used to normalize cargo counts since not all
containers are the same size.
35
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o Los Angeles County Sanitation Districts Clearwater Outfall Project
o Rolling Hills Prep School build out
o VOA Navy Village
o Pacific LA Marine Terminal
o Harbor Highlands Development (under construction)
o City Dock 1
o Port Master Plan update
o San Pedro Community Plan update
o Marymount College Expansion on PV Drive North
Of particular interest is the Community Plan Update,which forecasts an almost
10%population growth for San Pedro not including Ponte Vista in the next 18
years.
The Ambient Growth Rate of 1%is not Supported by any Documentation
Both the DEIR and the Western Avenue Task Force used a 1%growth rate for
Western Avenue,but CalTrans engineers opined in those meetings that the
growth rate was actually much higher.
Rather than use a number obtained from MTA,as does the DEIR,we suggest that
documentation be provided.
Public Transportation is Not Really Available to the Site
The DEIR (1-133)states that there are 14 buses per hour serving the project
during the morning peak hour.This is misleading and should be corrected.
There are four bus lines that serve the project site,none well.
Metro Bus Line 205 runs from 13th and Gaffey Streets to the Imperial Wilmington
Station at Imperial Highway and Wilmington Avenue in the
WattslWillowbrook Area.The frequency varies from every 20 minutes during the
am peak hour to 1 hour.This bus goes up Western and connects to the Artesia
Transit Station where it is possible to transfer to another bus to go to downtown
Los Angeles.Unfortunately it takes approximately 40 minutes just to get to the
Artesia Transit Station;there is no incentive for future residents to be so
inconvenienced.
Max Line 3 runs from 36th Street and Pacific Ave in San Pedro to LAX Green Line
36
2-59
Station and the Airport Courthouse.It operates northbound to EI Segundo in the
early AM and southbound to San Pedro in the late afternoon.MAX Line 3 does not
operate on major holidays or on weekends.It only makes 4 trips in am,the first at
5:36 and the last at 6:44 am and 4 in pm between the hours of 4:46 and 6:15 pm;
basically 2 buses/hour.This is a viable option if your work is in EI Segundo.
The remaining two lines are operated by RPV and are primarily designed to
transport RPV students to RPV schools.
PV Transit Orange Line runs 2 morning buses along Western from Palos Verdes
Drive North to First Street then to Palos Verdes Drive East ending at Palos Verdes
High School and 3 buses in the afternoon corresponding with school start and stop
times.These lines are designed to carry Palos Verdes students to Palos Verdes
schools,and as such are really not useful to the residents of Ponte Vista.
PV Transit Green Line is also geared primarily to Palos Verdes schools and the
Library.It runs along Western Avenue from First Street to Palos Verdes Drive
North then west along Palos Verdes Drive Road ending at Ridgecrest Elementary
School.
2.COMMENTS CONCERNING PROPOSED TRAFFIC MITIGATIONS
Some Offered Mitigation is Already Proposed by Marymount
Marymount College is required to implement some of these same by mitigations
as part of the approval of its mitigated negative declaration for its project on Palos
Verdes Drive North.It is our understanding that if any of the proposed mitigation
measures are provided by another source (e.g.Marymount College),prior to being
implemented by this Project,an alternate mitigation measure may be required.
We request that in the event that should occur,the applicant be required to consult
with the Northwest San Pedro Neighborhood Council,the Harbor City
Neighborhood Council,and the City of Rancho Palos Verdes on appropriate
mitigation measures.
Other Mitigations Transfer the Traffic Burden to Wilmington and Harbor City
Residents
Quite a bit of the proposed mitigation is designed to increase the overall capacity
at an intersection by addressing other traffic issues and thus could potentially
allow longer turn and through signals for the project traffic.In other words,traffic
from Harbor City,Palos Verdes and Wilmington will be adjusted,possibly
negatively impacted,in order to make more room for Ponte Vista traffic.
The Projected Routing for PM Peak Hour Traffic Does Not Seem to Have a
Basis
37
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We realize that predicting access routing is sometimes an art rather than a
science.However,given the very long PM backups at the 110 Freeway off-ramps
at Sepulveda,Pacific Coast Highway and Anaheim,coupled with the challenge of
making a left turn across Western,it seems likely that in the evening,a large
percentage of commuters will exit at Channel Street and proceed north on Gaffey
to Channel,Capitol,or Westmont and then west to Western to the project
entrances.This assumption is given further credence in that virtually every place
a commuter might want to stop on their way home,be it for groceries,dry
cleaning,or to pick up a child,is off of either Gaffey or that portion of Western that
lies between Channel and Westmont.Further,this commuter traffic will be joined
by those residents who are coming home from downtown San Pedro and the San
Pedro Waterfront and from Long Beach and points south via the 47.An analysis
of all of this traffic should be included.
The Proposed Project Makes No Attempt to Mitigate Project Generated
Traffic Through Project Design or Project Amenities
A significant amount of project-generated traffic will be work related traffic.Other
components will be taking kids to soccer practice,taking children to school,going
to the markets and library,church,etc.Work-related traffic will be especially
heavy,and for greater distances then normal,because the project is not really
responding to local employment needs.28 In other words,they are proposing a
suburban commuter community.
What is striking about the proposed project,and the DEIR,is that it proposes
nothing to mitigate trip generation by providing amenities on-site,such as work
centers,library branch,parks,mini-market,better walking access to local schools,
etc.
OTHER CONCERNS
The DEIR fails to analyze the impact of increased traffic on Western from the
74 driveways and non-signalized intersections on Western between
Summerland and Palos Verdes Drive North.According to a recent study of the
Western Avenue Corridor,there are 111 destinations on Western between
Summerland and Capital Drive.29 These grocery stores,post office,dentist offices,
coffee shops,banks,etc.are accessed through the driveways.These poorly
designed driveways add to the traffic flow problems.For example,the turn lane
into the shopping center nearest the project can only accommodate about 4 cars.
After that,cars begin impeding the flow of traffic on Western.This is a very unique
28 The DEIR for the San Pedro Community Plan Update established that the jobs per
household ratio for San Pedro was 0.44 while the Los Angeles area ratio is 1.35.This
means that for the 1135 households in the project, assuming two working adults,550 will
drive to local jobs and 1700 will drive a longer distance.
29 Western Avenue Corridor Vision Preliminary Analysis and Vision,Nov 14,2012
38
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condition and an analysis should be conducted of the impact of the traffic
generated by the Ponte Vista residents using these driveways.
Additionally,the assertion that 60%of traffic will be going North and 40%south on
Western does not seem credible given that virtually all amenities are located to the
South.
We are concerned about the impact on traffic flow along Western from installing
additional stoplights at Fitness Drive and Peninsula Verde.Consideration should
be given to a "pathway" through Ponte Vista as an alternative to a light at Fitness
Drive.Additional stoplights on Western may cause more traffic congestion,not
less.
Several of the proposed mitigations are subject to approval by other jurisdictions.
The DEIR should address the impact on traffic if these mitigations are not
approved and there should be a procedure in place for developing substitute
mitigations.
Consideration should be given to creating a "walking school bus"and a bicycle
path from the road at the back of the development thru Mary Star to Taper.
The DEIR failed to study the Harbor Freeway Channel Street Off-Ramp and the 47
Freeway Channel Street On-Ramp at Miraflores.The impact of increased traffic at this
intersection must be studied and appropriate mitigations proposed.In addition,the full
intersection including Channel and Gaffey must be re-examined.We are suspicious that
the low LOS shown at that intersection was the result of southbound Gaffey traffic backed
up at Miraflores and therefore not even entering the Channel and Gaffey intersection.An
April 2004 baseline study,for the Port of Los Angeles found this intersection to be at an
as of E during the PM Peak Hour and the Gaffey/Miraflores intersection to be an LOS of
F in the AM Peak hour and D in the PM Peak Hour.30
The DEIR fails to discuss the impact of the additional traffic on the freeway off-
ramps at Pacific Coast Highway and Anaheim and the resulting backup on the 110
freeway.
Mary Star should have vehicular access from both Green Hills Drive and Avenida
Aprenda and the internal roads should be connected at the back of the property.
The DEIR does not appear to account for the impact on traffic of the additional
time required for the approximately 225 additional middle and high school students
pushing the "walk"button to cross Western on their way to and from school,
assuming that the Dodson students walk to school and the High School students
30 Port of Los Angeles Baseline Transportation Study,Meyer,Mohaddes Associates.April
2004
39
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take public transportation.This must be added into the traffic study for that
intersection.
It is unclear if the DEIR properly accounts for the fact that most students from the
Eastview Area of Rancho Palos Verdes immediately west of Western are not
attending Crestwood Elementary,Dodson Junior High,or Narbonne High School.
The attendance in the Palos Verdes School District by Eastview residents is
rumored to be over 90%of the local students for the area.Most students from
Dodson and Crestwood are being bused in;likewise Eastview students are
commuting by car and bus via Western Avenue to Dapplegray Elementary,
Miraleste JHS,and Palos Verdes High School.
The parking plan for both residents and visitors is unclear and needs to be
clarified.
The Proposed Project Consumes All of the Available Infrastructure Space in
the Community Plan
What is the point of having a Local Community Plan if it will be impossible to
provide for projected development?As a matter of policy,we question whether a
single project should be entitled to more than a pro rata amount of available
infrastructure usage,in this case roadway space,at the expense of other future
development as contemplated in the Wilmington Harbor City Community Plan and
the San Pedro Community Plan update.
PUBLIC TRANSPORTATION
The DEI R (1-133)states that there are 14 buses per hour serving the project
during the morning peak hour.This is misleading and should be corrected.
There are 4 bus lines that serve the project site,none well.
Metro Bus Line 205 runs from 13th and Gaffey Streets to the Imperial Wilmington
Station at Imperial Highway and Wilmington Avenue in WattstWillowbrook Area.
The frequency varies from every 20 minutes during the am peak hour to 1 hour.
This bus goes up Western and connects to the Artesia Transit Station where it is
possible to transfer to another bus to go to downtown Los Angeles.Unfortunately
it takes approximately 40 minutes just to get to the Artesia Transit Station;there is
no incentive for future residents to be so inconvenienced.
Max Line 3 runs from 36th Street and Pacific Ave in San Pedro to LAX Green Line
Station and the Airport Courthouse.It operates northbound to EI Segundo in the
early AM and southbound to San Pedro in the late afternoon.MAX Line 3 does not
operate on major holidays or on weekends.It only makes 4 trips in am,the first at
5:36 and the last at 6:44 am and 4 in pm between the hours of 4:46 and 6:15 pm;
basically 2 buses/hour.This is a viable option if your work is in EI Segundo.
The remaining two lines are operated by RPV and are primarily designed to
40
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transport RPV students to RPV schools.
PV Transit Orange Line -runs 2 buses along Western from PV Drive N.to First
then to PV Drive East ending at PV High School in am and 3 in pm timed with
school start and stop times.These lines are designed to carry Palos Verdes
students to Palos Verdes schools,and as such are really not useful to the
residents of Ponte Vista
PV Transit Green Line also primarily geared to PV schools and Library.Runs
along Western from First to PV Drive North then west along PV Drive Road ending
at Ridgecrest Elementary School
O.UTILITIES AND SERVICE SYSTEMS
1.WATER
The DEIR states that the project's water usage will have a "less than significant
impact with mitigation"on the'area's infrastructure and environment (p.VI-142).A
brief examination of the document raises serious questions about that conclusion
and suggests that it is much too optimistic.
The developer estimates that the 1,135-unit project will use 216 acre-feet per year
of water.(p.1-135).That translates to 170 gallons per day per unit.However,
that figure is far below what experience has shown constitutes actual use.The
United States Environmental Protection Agenc:x has found that the average
American household uses 400 gallons per day.1 In Southern California,where
residents may be more sensitive about conserving fresh water,the Los Angeles
Department of Water and Power (LADWPJ reports that the average single-family
residence consumes 359 gallons each day 2
In other words,the developer estimates that Ponte Vista will use less than half the
water that the LADWP finds real households actually use.What is more,the DEIR
offers little explanation -beside mitigation measures such as flush-less urinals in
the project's common areas and low-flow showerheads and "green"appliances in
the residences (p.IV 0-10)-for this very significant discrepancy.Yet these
measures are already widely employed in the community and should therefore be
reflected in the 359-gallon figure the LADWP cites.
The DEI R does make reference to "purple pipe"-that is,plumbing that will use
reclaimed wastewater for irrigation,once a main line of purple pipe is extended to
31 "Water Sense,"an EPA Partnership Program at
www.epa.govlWaterSenselWaterUseToday
32 Los Angeles Department of Water and Power,2010 Urban Water Management Plan
[hereinafter referred to as the "UWMP"],p.43.
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this area.Rather than waiting for reclaimed wastewater to be available the
developer should be required to plumb the units to provide gray water for
irrigation.
Raising further doubts about the reliability of the project's water use estimates is
the DEIR's estimate that the project will add 205,950 gallons per day to the
sewage system.(p.IV 0-25).The report offers no explanation why water usage-
which includes water used for common area irrigation that would not flow into the
sewer lines -would be less than the amounts added to the area's sewer system.
Overshadowing the DEIR's estimates regarding water usage is the fact that the
LADWP projects it will encounter more difficulty obtaining fresh water supplies in
the future.This is so for several reasons including:1)population pressures
throughout the Southwest,2)increasing drought conditions in the area,3)climate
change and 4)legal restrictions on importing water especially from Northern
California and the Colorado River.(UWMP,p.ES-1).Under such circumstances,
it should be imperative that water providers use considerable caution in estimating
their ability to satisfy the area's future water needs.Indeed,in an effort to appear
to be meeting increased future demand,the LADWP is already employing the very
questionable tact of counting "conservation"as a water source.According to its
own estimates,by 2035,9 percent of the water it supplies to Southern California
will be from "conservation."(UWMP,p.19).
Furthermore,the entire state is facing a water crisis 33 .
According to population projections,the state's total population will
increase to 60 million people by the year 2050,an increase of over
56%from the 2000 census numbers.As the state's population
continues to grow,this is putting strain on our existing water supplies,
as well as bringing into question the ability to accommodate this
expected future growth.At the same time,drought and climate
change are reducing the snowpack California depends on to fill its
reservoirs,and the Delta,critical hub of California's water system,
faces multiple risk factors to its fragile levees while continuing to
experience ecosystem decline and plummeting native fish
populations.Continued population growth throughout the Southwest
combined with a persistent drought in the Colorado River basin is
putting increased pressure on the limited resources of the Colorado
River.In addition,Indian reservations,left out of previous water rights
agreements,have begun to exercise their long-held but unused water
rights,putting further strain on the limited resources of the Colorado
River.
Ensuring a water supply to meet the needs of California's existing residents while
providing for future population growth has become a major statewide issue as
33 http://www.aquafornia.com/index.php/californias-water-crisis/
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news stories and research reports highlight the challenges that lie ahead and
legislators debate putting another multi-billion dollar bond measure in front of
voters.More dams,increased conservation,water transfers,desalination and
more -there are many possibilities,each with its benefits and drawbacks.There is
no easy answer;unfortunately,no silver bullet
Freshwater is too important a resource to be the subject of guesswork.Under-
estimating its usage and over-estimating its availability can have cataclysmic
effects upon Southern California.Serious economic dislocation and even health
issues for area citizens are just two.Given the discrepancies between the
developer's estimated water use and the EPA and LADWP's experience about
actual levels of consumption and further questions about the LADWP's ability to
supply water in the not-too-distant future,this project's impact on the area's water
infrastructure needs to be re-analyzed.
2.WASTEWATER
The project should be mandated to capture and recycle storm water and grey
water on-site.
3.ENERGY
Solar or alternate energy such as Bloom Energy Servers should be required.
Currently 39%of the City's energy comes from coal.This is being phased out.The
City's lease for the Navajo power plant expires in 2019 and the City's contract for a
coal generated plant in Utah ends in 2027.DWP has indicated that both plants will
be shut down when the leases expire.In order to replace this loss,DWP is
counting on,among other things,an increase from the current 20%renewable
energy and 1%energy efficiency to 33%renewable energy and 10%energy
efficiency.34 These assumptions mayor may not be accurate.Increased use of
renewable energy is commendable but also costly to consumers.Existing
ratepayers should not have to bear the costs resulting from the increased demand
created by this project.
Another impact that should be analyzed is the increased need for cell transmitters.
No mention of this is made in the DEIR.
PUBLIC HEALTH IMPACTS
Large-scale developments like Ponte Vista have the potential to cause substantial
adverse effects on health of residents,either directly or indirectly.Therefore,the
34 LADWP Presentation on Proposed Rates 2012-2014,Mandates and Reliability
43
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DEIR must discuss "health and safety problems caused by the physical
changes"(CEQA Guidelines Section 15126.2).If the analysis identifies significant
health impacts,the lead agency must adopt feasible mitigations.Important
determinants of public health include the preservation of natural areas,air and
water quality,community noise,housing and transportation patterns,access to
food resources,public services,and economic well-being.
The DEIR fails to evaluate and disclose potential health impacts resulting
from lack of convenient access to daily needs.Proximity to services promotes
increased walking and biking,reduced daily vehicle trips and miles traveled,
increased possibilities for healthful and meaningful work,and increased
interactions among neighbors.Future residents of Ponte Vista should have equal
access to health resources.The more key public and retail services a
neighborhood has,the greater the chance for residents and workers to walk or
bike to access those services,increasing physical activity,social interactions,and
"eyes on the street".Research has found the presence of a grocery store in a
neighborhood predicts higher fruit and vegetable consumption and a reduced
prevalence of overweight and obesity.Neighborhoods with diverse and mixed land
uses could create proximity between residences,employment,and goods and
services,thereby reducing vehicle trips and miles traveled and as a result,
reducing air and noise pollution.This is especially pronounced because of the
difference between the estimates of project completion,Le.five years or fifteen
years,and the resulting impacts on construction related emissions and impacts.
The DEIR fails to address the following Public Health related questions:
o Does Ponte Vista have all of the key public and retail services that
contribute to neighborhood completeness?
o Does the Ponte Vista plan advance neighborhood completeness?
o What mitigations or project design elements would advance neighborhood
completeness?
SOCIAL IMPACTS
"In much of the rest of the world,rich people live in gated communities and drink
bottled water.That's increasingly the case in Los Angeles where I come from.So
that wealthy people in much of the world are insulated from the consequences of
their actions."
Jared Diamond,author,physiologist,evolutionary biologist and bio geographer.
A neighborhood offers the promise of belonging and call for us to recognize our
interdependence.To belong is to be welcome,even if we are strangers.The
sense of belonging is important because it leads us from conversations about
safety and comfort to our relatedness and willingness to be generous and
44
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hospitable.These elements seldom occur in a culture dominated by isolation,and
it correlate,fear.
The proposed narrow range of housing types forestalls the socioeconomic
robustness that accrues to places with a full spectrum of ages and income.The
proposed gated subdivision intentionally restricts access and emphasizes social
control and security over other community values,thereby shrinking the public
sphere and diminishing collective responsibility for the collective safety of society.
A security gate "can provide a refuge from people who are deviant or unusual...
the vigilance necessary to patrol these borders actually heightens residents'
anxiety and sense of isolation,rather than making them feel safer,"says Setha
Low,author of Behind the Gates,Security,and the Pursuit of Happiness in
Fortress America,The irony is that the residents,particularly kids and seniors that
don:t drive,become isolated and trapped behind their own gates --instead of
keeping people out,they shut themselves in.The isolation and loneliness is
increasingly becoming the cause for mental illness.
Gated subdivisions gained popularity with baby boomers.The demographics
have changed.Today,a large cohort of empty nesters and Generation Ys are
increasingly opting out of isolated and gated subdivision to belong in an open,
walkable and urban neighborhood.
The DEIR fails to discuss the social impacts of a limited access exclusive
subdivision.
PROJECT ALTERNATIVES
The DEI R should analyze at least one additional alternative that better addresses
the context of the community and environmental impacts of the project.We
suggest a mixed-use project alternative that includes access to Mary Star,with
true single-family homes on appropriate sized lots,rather than a PUD,work
centers,commercial space,senior friendly facilities,a range of public open spaces
including a 6-acre public park,and a library extension to meet State Guidelines for
library space.
45
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Additionally,given the poor jobs housing balance,it seems remiss that none of the
alternatives included a light industrial park.This is particularly true in light of the
fact that the original re-use plan for this property would have resulted in significant
job creation.35
ATTACHMENTS
Attachment A
Attachment B
Attachment C
Attachment D
Attachment E
Tosco Worst Case Scenario
Critical Facilities and Lifeline Systems in the City of Los
Angeles
San Pedro BUilding Types
Single Family Housing Construction Costs
LAUSD School Enrollments for Taper,Narbonne,and
Dodson
35 According to the Draft EIR for the San Pedro Community Plan,the jobs-housing ratio
for San Pedro is 0.44 while it is 1.3 for Los Angeles as a whole.
46
2-69
ATTACHMENT A
47
2-70
WORST CASE SCENAR.IO
WORST CASE SCENARIO
ASSUMPTiONS POR
'BUTAN~..
•Everything in a refilgerated butane
l"lf lk is reiease"C!instantaneously.
•Safety controls are not con~~der:cd"
•Butane completely vap()ri7f~s
and explodes.
PUnlN·GI1rlN\'f()p~ft$PECnVE
WorstQ$~5(leriatiCl Arnount Rel~d ,."",..,,.' ,.,,,,..,.."..5.,Q.2.2.QQQ Ga 119n;,;
A~,mait(Si~el~e Scenario Ati10untHeleased ..., . ,••....•..,...., " , ,....~,~i\ll.QD~
ALTEftNATEREUSASE
SCENARIO ASSUMPTIONS
fOR BUTANE:
•Rt~lease of 30,000 lbs.in 15 minutes.
•Safety wrTlmls 0rml1tt<'J as designed to
minimize release.
•"f\fpicaJ weather conditions exhrl.
SCENARIO
48
2-71
ATTACHMENT B
49
2-72
SAFETY ELEMENT EXHIBIT H
Critical Facilities &Lifeline Systems
In the City of Los Angeles
Selected Transportation Routes
Selected Disaster Route
so@-State Highway
-"@-Interstate Highway
~FederalHjghway
O Caftrans Freeway Interchange
f!ighpr,mhV
'
or Ca;trIl!l!16tlofitproglam
[Mayinc!udllrailraadcro~sin9)
•CaltransPedestrianCrossing
Selected Emergency Facilities
8 Major Communication Center
EE LA County Maintenance Warehouse
~LA City Maintenance Warehouse
Selected Dependent Care Facilities
X Major Acute Care Hospital {Capacitvgfllatarlhan 500)+Other Major Hospital
A LA County Community eare Facility (Capacitygraatartllan 200)
....MajorJailFacility
Selected Lifeline Facilities
•Gas Compressor Station
6.EtectricalPowerPlant
•WaterTfeatmentPlanl
(>Waste Water Treatment Plant
..Major Transmission Substation
High Voltage Transmission line (Aeriall'owarline)
Undefground Elecflical Transmission line
Major Aqueduct
4 MILES
1.lhi.l m:m i5 inte!llJcd to pmwnlllJe general d~!,U1butioo of lXlmrT1unily ele:nenIHlJlnerable to dalT1aQl1S from aY.lncty of I\alards,In mler
to pre:sr:rw maptlantt.d ImfDrtlnt ~rm~al fat:i!fl1DS and ~fchnes am nm 51KM'fl
:n::r~a:;=5f=~:n~~~aU;~~ghn'i~~~=~~~=r::~:~~c:1 ::~p~:~~:~~b~~~~:~,~~3.,!Ie SIlIncted diuslnr mUll!5 al.so pllMOO 8~an 101 interjurildir:tional mad rilQ:mlt'lletioo .m rebuilding tcllowilYJ aIll.jar disiI5lcr.
4 Th.COflIIilatkmoflelectodlifelinefaoliti.sw1i'1dlleavit)'upooCillifomiaOr.oilionofMinesamGrology.EarthquakeScenarlolle[lO't.l.Spcci81 Pub\r.a1ions60and $S,
5.TllilmapisinteroWlfCfg&nl!fillIBndWlen,lddisanerpianning(lllpl!ll(':l0llIV
Sourro:LA CounlYS;jIetyEIemen1Ti1cllnie:tlAPfK:l\dix.r:ll'.eD.Dec!:mIJcII990&GooeralPI8I1FlalT.ev.ortEiR ."E"::'l'l",,;_I:':::::l_i=::l"'..,j5KIUlMffiRS
~U'~
6/2-73
ATTACHMENT C
51
2-74
2-75
2-76
2-77
2-78
ATTACHMENT D
56
2-79
SINGLE-FAMILY RESIDENTIAL
BUILDING SPECIFICATIONS
"D"CONSTRUCTION
POST 1990 D-6 QUALITY MODERN
Foundation
Reinforced concrete
Floor Structure
Standard wood frame or slab on grade reinforced concrete,vapor barrier,base 4"thick
Walls and Exterior
Framing:Standard wood or steel frame
Sheathing:Line wire and paper,plywood,or particle board
Cover:Wood shingles or low-cost wood siding or masonry trim on front wall;average stucco
sides and rear
Windows:Average quality aluminum or wood;slide or double hung,double glaze
.Front Door:Average Quality metal or wood
Roof
Framing:Standard wood or steel frame
Cover:Wood shingle,light wood shake,good composition shingle,or concrete shake or tile
Overhang:0"to 18",unceiled
Gutters:Average Quality at all eaves
Floor Finishes
Average quality hardwood,carpet,vinyl,or ceramic tile throughout
Interior Finish
Drywall,taped,textured,painted;some wallpaper;average quality paneling
Decorative plant shelves
Ceilings:Standard 8'or vaulted'low-cost fans
Interior Detail
Interior Doors:Average quality wood
Trim:Wood or plastic
Closets:Average amount;low-cost doors
Bath Detail
Number:Two
Floors:Average quality vinyl
Walls:Drywall and enamel
Shower &Tub:Fiberglass or average Quality ceramic tile,with glass doors;twin basin vanities
Kitchen
Base Cabinet:Average cost wood veneer
Wall Cases:Average cost wood veneer
Drain Board:Average cost plastic laminate or vinyl tile
Some island cabinets without fixtures
Plumbing
Galvanized,plastic,or copper pipe;7 average-cost fixtures;washer outlet;water heater
Special Features
Average quality sliding glass or French doors;average quality built-in oven,range,microwave,
dishwasher,garbage disposer,range hood and fan;utility room/closet
Electrical
Cable wiring;average quality fixtures;some bedroom ceiling fixtures
AH 531.21-Single-Family Residential Modem Type 5
57
January 2010
2-80
SINGLE-FAMILY RESIDENTIAL
BUILDING SPECIFICATIONS
"D"CONSTRUCTION
POST 1990 D-8 QUALITY MODERN
Foundation
Reinforced concrete
Floor Structure
Standard woodframe or slab on grade reinforced concrete,vapor barrier,base 4"thick
Walls and Exterior
Framing:Standard wood or steel frame
Sheathing:Line wire and paper,plywood,or particle board
Cover:Good wood siding,masonry,or stucco
Windows:Vinyl framed wood or aluminum;divided light;slide or double hung,double glaze
Front Doors:Single or double Qood aualitv decorative wood or metal:Qlass trim;side glass panels
Roof
'Framing:Standard wood or steel frame
Cover:Heavy wood shake,concrete shake,tile,or high definition composition roof
Overhang:0"to 24",ceiled or unceiled
Gutters:Good quality at all eaves
Floor Finishes
Terrazzo,mission,or quarry tile in entry;good hardwood,carpet,vinyl,slate,or quarry tile throughout
Interior Finish
Drywall with good texture and paint;custom decorative woodwork and molding;rounded comers;some
good wallpaper,vinyl wall cover,or veneer paneling
CeilinQs:Standard 9'to II',vaulted,crown moldinQ,coffered,or arched;Qood aualitv fans
Interior Detail
Interior Doors:Good quality wood
Trim:Good quality wood
Decorative plant shelves and art niches
Closets:Good wood and mirrored doors;some walk-ins
Bath Detail
Number:2 1/2 to 3
Floors:Good quality ceramic tile or vinyl tile
Walls:Drywall and enamel;good wallpaper and ceramic tile
Shower &Tub:Good acrylic or porcelain;good ceramic tile trim,with glass doors;glass block
Twin basin vanities and comoartmentalized bath
Kitchen
Base Cabinet:Good hardwood veneer
Wall Cases:Good hardwood veneer;under cabinet lighting
Drain Board:Good ceramic tile,cultured marble,granite,or Conan
Island cabinets with fixtures
Plumbing
Galvanized,plastic,or copper pipe;10 good fixtures;washer outlet;two water heaters
Special Features
Multiple sliding glass or French doors;good quality built-in double oven,range,dishwasher,garbage
disposer,range hood and fan,microwave,compactor,and wet bar;utility room with laundry sink;
pre-wired for security;walk-in pantry;hot water recirculator;fireplace
Electrical
Cable wiring;good quality fixtures;bedroom ceiling fixtures;recessed lighting
AH 53 1.2 I-Single-Family Residential Modern Type 9
58
January 2010
2-81
SINGLE-FAMILY RESIDENTIAL
MODERN TYPE
SQUARE FOOT AREA COST TABLES
"D"CONSTRUCTION -SHAPE B
CH~$s ········\'tOQ .....<8QO··'···9.0·0·.1Qoo 110Q ...1200···1300 ..HOG>1$O()·····1600·.·1700
0-5 77.49 74.26 71.47 69.30 67.41 65.83 64.54 63.30 62.24 61.32 60.51
0-5.5 85.22 81.62 78.64 76.27 74.12 72.35 71.01 69.62 68.51 67.50 66.60
0-6 98.18 94.12 90.55 87.86 85.45 83.39 81.84 80.29 79.02 77.80 76.73
0-6.5 109.07 104.50 100.51 97.53 94.86 92.61 90.83 89.04 87.70 86.34 85.23
0-7 121.05 115.97 111.65 108.27 105.34 102.86 100.91 98.89 97.26 95.88 94.65
0-7.5 140.45 134.63 129.57 125.70 122.31 119.35 117.13 114.77 113.02 111.24 109.80
0-8 164.28 157.41 151.61 147.00 142.99 139.64 136.94 134.26 132.13 130.15 128.39
0-8.5 188.26 180.41 173.73 168.49 163.82 160.01 156.94 153.84 151.36 149.15 147.15
0-9 256.51 245.78 236.67 229.55 223.21 218.03 213.80 209.57 206.22 203.18 200.47
0-9.5 367.08 351.62 338.72 328.40 319.39 311.94 305.85 299.88 295.11 290.75 286.84
0-10 422.12 404.37 389.50 377.68 367.31 358.80 351.77 344.84 339.37 334.37 329.81
"D"CONSTRUCTION -SHAPE B
¢la$s.·········>jSOO >2000··~2().0 2400 <2$00 i~800 ··~()oO 3200 /'3.400.·3$00 •.......4000:-:,".;.....'
0-5 59.74 58.48 57.53 56.66 55.88 55.21 54.68 54.14 53.70 53.32 52.73
0-5.5 65.70 64.36 63.30 62.24 61.42 60.77 60.12 59.59 59.09 58.67 57.99
0-6 75.78 74.12 72.93 71.81 70.88 70.02 69.27 68.63 68.07 67.56 66.85
0-6.5 84.12 82.37 81.01 79.71 78.64 77.76 76.91 76.21 75.59 74.99 74.23
0-7 93.40 91.36 89.94 88.50 87.28 86.27 85.43 84.56 83.95 83.33 82.43
0-7.5 108.38 106.06 104.37 102.78 101.32 100.16 99.15 98.16 97.37 96.67 95.61
0-8 126.83 124.11 122.09 120.21 118.51 117.12 116.02 114.87 113.92 113.08 111.87
0-8.5 145.25 142.22 139.92 137.76 135.86 134.26 132.92 131.62 130.55 129.55 128.20
0-9 197.92 193.77 190.69 187.66 185.06 182.88 181.06 179.32 177.86 176.48 174.66
0-9.5 283.25 277.19 272.71 268.59 264.86 261.66 259.14 256.56 254.51 252.55 249.97
0-10 325.72 318.78 313.65 308.84 304.52 300.91 297.96 295.09 292.67 290.45 287.41
"D"CONSTRUCTION -SHAPE B
Class»4200.'"4400 >4~o.O ;5000
0-6 66.26 65.72 65.27 64.61
0-6.5 73.57 72.97 72.47 71.74
0-7 81.69 81.05 80,48 79.67
0-7.5 94.74 93.99 93.32 92.40
0-8 110.88 109.99 109.22 108.13
0-8.5 127.23 125.65 124.69 123.82
0-9 173.10 171.71 170.51 168.80
0-9.5 247.70 246.84 245.12 242.66
0-10 284.83 282.54 281.66 278.85
AH 531.21-Single-Family Residential Modern Type
59 15 January 2010
2-82
SINGLE-FAMILY RESIDENTIAL
MODERN -POST 1990
D-6QUALITY
AH 531.21-Single-Family Residential Modern Type 21
60
January 2010
2-83
SINGLE-FAMILY RESIDENTIAL
MODERN -POST 1990
D-8 QUALITY
AH 53 1.2 I-Single-Family Residential Modern Type 25
61
January 2010
2-84
ATTACHMENT E
62
2-85
School Profile
TAPEREL
1824 Taper Ave
San Pedro,Ca 90731
Office:310-832-3056
Fax:310-548-4485
(ONote:This profile includes magnet center information.)
Student Racial &Ethnic History
63
2
-
8
6
School Profile
DODSONMS
28014 Montereina Dr
Rancho Palos Verdes,Ca 90275
Office:310-241-1900
Fax:310-832-4709
("Note:This profile includes magnet center information.)
Student Racial &Ethnic History
64
2
-
8
7
School Profile
NARBONNESH
24300 S Western Ave
Harbor City,Ca 90710
Office:310-257-7100
Fax:310-326-1805
('Note:This profile includes magnet center information.)
Student Racial &Ethnic History
65
2
-
8
8
"R Neighborhoods R1"comments on the Ponte Vista EIR
2-89
January 7,2013
.EXi_~_~tr:~!ic_h ------{Field Code Changed
Environmental Review Section '------"'---------'
Department of City Planning
200 N.Spring Street,Room 750
Los Angeles,CA 90012
R NEIGHBORHOODS R1 COMMENTS ON
ENV·2005-4516 DRAFT EIR COMMENTS: PONTE VISTA PROJECT
26900 S.WESTERN AVE,SAN PEDRO
Thank you for the opportunity to respond to the Draft EIR for the proposed Ponte
Vista project.
We represent approximately 15,000 residents and many homeowner groups who
believe a single family home development should be constructed at Ponte Vista.
Our proposed project is included in our comments.,that were adopted by our
steering committee on January 2,2013.
First,like others,we are frustrated and discouraged by the denial of a 90 day
review period.We do not appreciate that the 60 day review period was over the
Thanksgiving,Hanukkah,Christmas,and New Year holiday season.This was
also not fair to the community at large on a project that everyone in San Pedro,
Harbor City and Wilmington regards as a controversial project.The DEIR does
little to allay our concerns because the proposed project complies with almost
none of the guidelines and pfans that it says it does.
The proposed project and its smaller alternative do not appear to be a good fit for
the community.There are problems with the underlying assumptions and
conclusions in the DEIR,mainly relating to traffic,social services,utilities and
service systems.Because the analysis is built on faulty assumptions,it is in
effect a "house of cards,"and all conclusions based 00 the analysis are also
faulty.We also are concerned with the lack of amenities provided on site,and
the lack of any attempt to address the substantial environmental impacts through
project design.
Among the fundamental deficiencies in the DEIR are the following:
a Contrary to what is presented in the DEIR,the rezoning request will impair
the orderly implementation of Regional Plans,City's General Plan,and
two Community Plans.Additionally it fails to evaluate Public health and
Socal Impacts and conformance with the ten Urban Design Principles and
the Walkability Checklist.
2-90
o The DEIR incorrectly identifies the project as being in keeping with the
surrounding neighborhoods.In fact,it ignores the shortfall in San Pedro
for single-family homes,and instead proposes housing types that will
directly compete with unsold housing units immediately south of the
project and also in downtown San Pedro in the former CRA project area.
o The proposed project is not a good fit for the location.The gated
community and mix of housing types are not appropriate,it is not in a
transited oriented area,and its development would not improve the local
jobs housing balance.
o Alternatives B,C,and 0 ignore the present zoning which includes 15
acres of open space.This is an especially egregious oversight in
alternate B because if claims to be a "no project"alternative,Le.buildable
as a matter of right.In fact,units cannot be built on that portion of the
property zoned as open space.
o The traffic analysis uses incorrect assumptions about VIC ratios and traffic
generation rates,and proposes mitigations that essentially shift and
increase the traffic burdens onto traffic going and coming from Wilmington,
Harbor City,and Rancho Palos Verdes,that is not related to San Pedro in
any way.Further,the DEIR and the proposed Alternatives,all of them,fail
to consider traffic mitigations such as on-site work centers,increased
open space to address recreation trips,and additional library space.
o The DEIR uses data that differs markedly from data included in the San
Pedro Community Plan Update EIR.The two should be consistent.
o The analyses and proposed mitigations for Greenhouse Gas Emissions,
Hazardous Materials,Public Services,and Utilities and Service Systems
are inadequate and flawed.They must be revised.
o The DEIR should analyze at least one additional alternative that better
addresses the environmental impacts of the project.We suggest a project
alternative that includes access to Mary Star,true single-family homes
rather than a PUD,with work centers,commercial space,a public park
that complies with the City Recreation Plan,and a library extension to
meet State Guidelines for library space.
Our specific comments are attached hereto.Thank you for this opportunity to
submit our comments and concerns.
Nancy Castiglione,
For R Neighborhoods R!
2-91
CC:Councilman Joe Buscaino
Olive Reed,President,Harbor City Neighborhood Council
Cecelia Moreno,President,Wilmington Neighborhood Council
Linda Alexander,President,Central San Pedro Neighborhood Council
June Smith,President,Coastal San Pedro Neighborhood Council
Ponte Vista Development Team
2-92
R NEIGHBORHOODS R1
PONTE VISTA DEIR COMMENTS
An additional alternative should be studied.
CEQA requires the consideration of a reasonable number of alternatives and that
the alternatives address the significant impacts determined as a result of the
environmental analysis.
The DEIR really suggest only two alternatives,one for 1135 units and the other
for 830 units.There are two purported additional alternatives,one being the
mandatory "no project"alternative and the other a variation of the "no project'
alternative,Le.a single family alternative it clams it can build as a matter of right.
All three of the build options identify significant environmental impacts,
particularly traffic,and all three ignore the 15 acre Open Space zoning that exists
on the property.All three make no attempt to mitigate traffic impacts through on-
site improvements such as changes in design and providing amenities.
For those reasons,and others detailed in following pages,we suggest an
additional alternative be studied that has the following characteristics.
1.Increase the number of units from the present 245 to 291 single family units
on R-1 zoning.
2.Retain the 15 acre open space zoning and develop as a public park,to meet
City guidelines for park space and to address recreation oriented traffic.
3.Provide public street access to Mary Star High School and construct an open
project with public streets throughout the project.
4.To reduce work trip oriented traffic,provide as part of each housing unit,and
also as an amenity in the project,work centers that will appeal to work-from-
home residents.On-site work centers could include tele-conferencing
capabilities for example,and meeting rooms.Work centers could also be
suitable for after-school study centers and similar uses,and for a branch library.
5.Include some on-site convenience shop[s],to lessen car trips for occasional
small item purchases,and a coffee shop for local convenience.
Reasons to support the additional alternative
1.The surrounding area includes single family homes.Other than the
apartments immediately to the south of the project site and the Gardens,the
1
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surrounding areas are all single family homes.It is incorrect to say that the
proposed 1135 or 830 unit developments conform to he surrounding area.
2.No single family homes have been built in San Pedro for thirty years.They
are the housing of need in San Pedro.
3.San Pedro generally,its political and community leadership,and the
Community Plan Update,all recognize the need to renovate downtown San
Pedro.A large number of condo units have been built in downtown San Pedro
and indeed,immediately south of the project site,that remain unsold and are
now being leased.It is a mistake to construct even more such units that will
compete with the redevelopment of downtown and undermine its resurgence.
4.The DEIR does not address the environmental impacts of additional units that
could,be built by parcel developers as a matter of right through S81818 density
bonuses.The owner,who openly says it will sell the parcels rather than develop
them itself,claims it can eliminate the possibility of density bonuses,but nothing
tit has said so far is convincing.However,S81818 does not apply to single-
family developments.An R1 development would avoid the possibility of
unevaluated environmental consequences.
5.All three development proposals ignore the Open Space zoning that applies to
15 acres of the property.They say it is a "cartographic error"but in life we don't
get to ignore zoning maps simply because we don't like them.Further,City and
State guidelines provide that recreation and park space should be provided to
accommodate additional residents in an area.On-site recreation facilities would
also lessen the traffic impacts of the project.
6.Single family developments generate an average of 9.57 trip-ends per day.In
a typical household that would mean four per day for work related driving in a
household with two workers.A development emphasizing work-at-home facilities
would appeal to families that could do at least part of their work at home,or in the
project site itself.The failure to even consider these amenities in design of the
project is a deficiency.
7.There are many errors in the way traffic impacts have been computed,but it is
clear that a 291 unit development would have lower impacts than a 1135,830 or
385 unit development.
A 291 unit SFR development is economically feasible.
Our recommended unit count is a pro-rata number based on the Alternate 8 385
unit proposal but taking into account that 15 acres are zoned Open Space.
2
2-94
The owner has said that building singe-family houses would mean "$1,000,000
dollar homes"but provided no support for the assertion.We investigated the
claim.
First,we assumed the $120,000,000 cost of the land even though it was that high
due to the bid contest and because the developer was counting on City
acquiescence in a zone change allowing 2230 units.Everyone knows,including
the bank that owns it now,that it is not worth nearly that much.Nevertheless we
have used that figure in computing the cost.
Next,we consulted the California Board of Equalization "Building Construction
Handbook",2010,a detailed compilation of building costs throughout the state.
The Handbook determines construction costs including profit for more than ten
different grades of construction quality,certain other characteristics,and provides
an aqjustment for location by county.For the 216 page version of the 2010
document,see http://www.boe.ca.gov/proptaxes/pdf/ah531.pdf.
For purposes of computation we analyzed the single family unattached houses in
the Taper area,Mount Shasta area,and around Dodson Middle School.They
run from 1350 sf to 2200 sJ.with an average of 1800 sf.We use a larger size,
2000 sJ.even though it would cost more to build than an 1800 sJ.house.
Next,we used a 08 construction type with a cost adjustment for Los Angeles
County,of $136.52 psf.The description of the 08 modern construction type
along with s sampler of houses built to that specification are inserted as the
following three pages.Please note that the characteristics of a 08 level home
are quite a bit aboveJhe level of the surrounding homes.
The computation is as follows:$124.11 X 1.10 X 2000 sf X 291 houses +
$120,000,000 land cost =$199,455,222 total cost.Divided by 291 homes,cost
per home inclUding profit:
$685,413.
3
2-95
SINGLf>FAMII.Y IU;SlOENTIAI.
MODERN .POST 1990
D-8QUAU'IY
4
JallWlf)'lOIU
2-96
SINGl.£:.FAMILY RESID£:NTIAL
BUILOING SPECIFICATIONS
"I)"CONSTIUJC'l'!ON
Slllndllrd wood III Jib,d frame
Sh"'Ilclllj.ll:i~:UIh!Wklllllldpapllt,plyw(l(.d.or Pllltkk~rd
CO\'cr:Gu,;uj ,~'(>tj>d siding.Ulll$Onry,or litrK'l/O
Willdl'>wt;Vill)!1 frauK'4 wOild or aluillillulll;dividlld liWJl;dide or double hung,dllublc glall:
Roof
Framing,Swndntd wood Ilr llIfcl fmlll(
C\wer:Heavy woodsllllkll.lIlllIlIrlllll $l!l.:ikl/,tile,<>1 high dclinitfi:1U l/N~!it>n toof
O·to 24~,t'CiI~d Of lIJlUilcd
Intenor Finisb
Dry...'aU witlljlllM tllX1ll.re aodpaillt;('U$lll'lll ~l/l'>llltjv",woodwllrk and nlllltflllg;mmrdM ,1)mcr$l;~ll'm",
g<aOO wallpapef.tinyl willi ('OV(>J,<>1 \'Cfioorpai'1&ling
InlerlorlWlllil
lnknllr l:><xl1't;(j;w";!qU'llily wood
TtIJlI:G<aJd quaUty w<aJd
!n",r.rali""plalll shdvc~aod art nkll,'1I
BatbDl/tail
Numb<KC :2 1/2 11);I
l'lOOlli;Dood qua'lily cel'.llnk tile (If villyl tile
Walls;Dl)?walllllld i.mamel:111)M wallpaj:>el aod tlltamw lile
Showllt &:Tuh,Dood ilerylic lllroteelain;llood <':<.'l'lllllie IHe lrim,wilh Il!U$~dI'>l>l$;glu&'1Il1<>ek
Kitchen
B(IJkj Cabinet:(}<aJd hllWdwood VetI<N1
Wail CIllim:(}<aJd haldwr'lld Vlli'1&llt;under ...aMn!!1 lighting
Dmin~:G....rd cerwllie tile,eullUred IMr""',granite,Of Corlan
f'luwhlnj;
_,''_''_01lh'~~~?,plasUc,()j CtlPjltr P!P!;HI gc'lld flx':.l!.~~~f.wr lllld:!~ilel.ll~"'__"'__"""''''''l
S,tecial £"calllr('$
Multiple $lhlillll g)Ma or Frcnch do_:gaod rlualhy built·'n dllllhie l>Wn.ClInge,dish"'\\l$llew,
4'*])II$el,mill!"OOod@nd fall,miclllwnc,C<'lllplldof,aod wei hat;utilit)!fOl>ill \Viih 1@u:ll:dty.,
Electrical
Cable wiril'lg;llc'lld qll.\,lily n:mlf<'::l;iJ.<;.,;lr_cellilll!flXtllfe<;relli.'llscd IightilllJ
5
2-97
SINGl.E·FAMILY RESlDEN'rlAL
MODERNTI'P£
SQUARE FOOT AREA COST TABUS
"n"CONSTRtlCnON •SHAlf£B
"n"CONSTRllCTlON •SHAPE B
6
2-98
As for our additional comments,we generally adopt the comments of Northwest
San Pedro Neighborhood Council to the extent they do not conflict with our
position herein.With some changes,they are as follows:
C.PROJECT CHARACTERISTICS
The DEIR identifies Alternative C,for 830 units,as the "environmentally superior"
alternative yet it almost exclusively analyzes the 1135 unit proposal.The
applicant obviously expects that any impacts of the denser Alternate will apply to
the less dense alternate.This is questionable,especially in terms of project
characteristics and proposed mitigations.The DEIR must be revised to evaluate
impacts for 830 units to foreclose any interest from this or any future owner to
increase the intensity back up to 1135 units without triggering another entitlement
application.
Similarly,Alternate B is identified as an even less impactful alternative but no real
analysis of it is made.Finally,Alternative 0,Revised Site Plan,would develop
the site with the same 1135 units as the Proposed Project,however,"In order to
altered ...{and}the 2.8 acre public park would not be developed ...."The
application should be amended accordingly.
Also,none of the three Alternatives evaluates the impact of SB 1818 on unit
count,population,schools,traffic,services,etc.Since SB 1818 allows the
developer to increase the number of units as a matter of right at any time after
entitlement,either the applicant needs to show conclusively how SB 1818 does
not apply to its application or it should account for the potential impacts of the
legislation on its project.This is especially important because the applicant has
made it clear it is a speculator and intends to sell the parcels once they are
entitled.
Specific Plan Zoning
A Specific Plan is proposed with Low Medium and Medium density zoning.The
DEIR generalizes overall zoning for the entire project,not each individual
element.Each parcel within the development should have a specific zoning
density attached to it.Individual densities would allow a closer
examination of how to create contextual intensities particularly along the
edges of the proposed subdivision.
The proposed zoning is vague.For example,the proposed single-family units
are not the traditional single-family homes that one finds in an R-1 zone.Rather
they are essentially the type of housing found in areas zoned RD 1.5 and higher.
The apartment buildings need to have a specific zoning that is applicable to the
actual size and density of the proposed development.A Medium density by City
of LA codes extends all the way to R-4 zoning which is comparable to the density
7
2-99
on Fitness Drive,the 6-acre parcel between the Commercial Shopping Center
and the Ponte Vista Property.Figure 11-10,Parcel 7 should be zoned specifically
for their proposed density,not the medium density.The apartments should be
capped at R-3 or lower to provide for an appropriate transition from the
development on Fitness Drive to the lower density units directly to the north.
Private Roads
The DEIR (11-17)states"With the exception of the ...road ...providing access ...to
Mary Star of the Sea High School,all other streets on the Project Site would be
private and access would be provided through two gated entrances ...."In order
to better incorporate this project into the surrounding community and provide
better emergency ingress and egress,the roads should be dedicated public
roads.The road areas should not be used in the calculation of units per acre.
Open Space
The DEIR (11-18)states that "approximately 33 percent of the projects post
development acreage would consist of landscaped common areas ...and parks
(excluding roads)..."Open space would include an approximately 2.8 acre
park ...."Since the park has been deleted from the viable alternatives this
statement should be rewritten.
This same section references the provision of 102 parking spaces for use by park
visitors and other visitors to the site.With the deletion of the public park,it
appears that the public parking spaces have also been deleted.The DEIR
should be corrected to reflect this change.
Figure 11-8 shows a 1-acre mitigation area within the public park.Since the
public park has been deleted,what happens to the mitigation area?
Building Heights
The description of building heights as 40'-48'does not match the two-to three-
story buildings.This is the building height for four-story buildings.Also,the
height calculation should be specific to the individual housing types and
their locations within in the project.
D.CONSTRUCTION CHARACTERISTICS
The DEIR states (11-33)that "the construction of the project is estimated to begin
in 2013 and would continue over a five-year period,with completion in 2017."
There are many references to this 5-year time frame throughout the DEIR.
Since the applicant has requested a 1S-year Development Agreement,
these references should be changed to indicate a 1S-year build-out and the
construction phase impacts addressed accordingly.
8
2-100
Table 11-3 indicates that the construction of the Public Park and the Landscaping
and Streetscape Improvements would be done in the final year of the 5-year
build-out.Completion of a public park and the landscaping and streetscape
improvements on the exterior of the project should be required prior to
occupation of any unit.
P 11-34 states "...construction staging,laydown areas,and all construction
equipment would be positioned on-site and would be moved from area to area on
the Project Site,consistent with the sequence of Project construction."Since the
project anticipated different developers for each area it is not clear how would
this work?The mitigations need to address the actual impacts.
E.PROJECT OBJECTIVES
Proje'ct Objective 6,"To develop a project that fiscally benefits the City of LA."Is
not supported.In order to determine if this project fiscally benefits the City of Los
Angeles it would be necessary to do an economic impact analysis of projected
revenues and costs for each of the alternatives.This should include looking at
the property tax,sales revenues that would be within the City of Los Angeles,
and long term costs to the City for services such as Police,Fire,and utilities.
This objective should either be removed or factually supported.
SECTION III.ENVIRONMENTAL SETTING
B.OVERVIEW OF ENVIRONMENTAL SETTING
The Local Setting description (111-3)should be modified to include the approved
76 unit Volunteers of America (VOA)Navy Village which will be located
immediately to the North of the project and will provide housing for homeless
veterans and their families.Additionally,the discussion of the proposed future
Marymount College educational facilities should include an analysis of their
planned expansion at this site into a full four-year college campus with room for
800 residential students,1500 total students,and 75 full and part-time faculty.
Please add the following City of Los Angeles Projects to Table 111-2 (111-23)
Cumulative Projects and reanalyze cumulative project impacts accordingly.
These projects will generate considerable traffic impacts that were not included in
future traffic and school calculations:
Southern California International Gateway (SCIG)
APL Terminal expansion
9
2-101
Ports O'Call Redevelopment
Cabrillo Marina Phase II
USS Iowa
Los Angeles County Sanitation Districts Clearwater Outfall Project
Rolling Hills Prep School build out from 250 students to 1,000
students
VOA Navy Village
Pacific LA Marine Terminal
Harbor Highlands Development (under construction)
City Dock 1
Port Master Plan update
Marymount College Expansion on Palos Verdes Drive North
San Pedro Community Plan update
G.GREENHOUSE GAS EMISSIONS
Background
The State of California has declared that greenhouse gases (GHGs)constitute "a
serious threat to the economic well-being,public health and the environment of
California."(AS 32).It recognizes that allowing them to remain at current levels
will not adequately address the dangers they pose and has established instead
the goal of reducing them to 1990 levels by the year 2020 (AS 32).
The City of Los Angeles has embraced the effort.It adopted "Green L.A.:An
Action Plan to Lead the Nation in Fighting Global Warning"in May 2007,in which
it proclaims that by 2030 it will reduce GHGs from city operations 35 percent
below 1990 levels.
Three gases are felt to pose the greatest threat:carbon dioxide,methane and
nitrous oxide.1 The primary cause of GHG pollution is combustion offossil fuels.2
In California,fossil fuel use is closely related to motor vehicle use.
1 California Technical Advisory:CEQA and Climate Change,June 19,2008 -
hereinafter "Technical Advisory"
2 Technical Advisory,p.2
10
2-102
Emissions
According to the DEIR,this project will not reduce GHG pollution to 1990 levels.
Indeed,it will not decrease GHGs at all.To the contrary,it will increase them.
The site currently generates no GHGs (p.IV G-4).According to the developer's
projections,the proposed project will generate 15,620.55 metric tons of GHGs
each year.3 That is 15,620.55 more metric tons or 17,222 more American "short"
tons of pollutants every year for the foreseeable future than are generated at the
present,172,220 short tons over 10 years,344,440 short tons over 20 years,etc.
This single fact should overshadow all others for anyone considering the
project's impact on this insidious form of pollution.
The DEIR does address the 35 percent reduction that the City of Los Angeles
seek~to achieve.Moreover,it dwells on minimal reductions such as emissions
from landscaping equipment and the fact that the project's structures are
designed with large "contiguous unobstructed roof areas"which can
accommodate solar panels.Large flat "roof areas"can be found on many
structures and hardly constitute a "green"breakthrough.What is more,the
proposal does not provide for the installation of solar panels on any of the
project's roofs.
Proposed "Reductions"
Most significantly,the DEIR's claim that the project will reduce GHGs by 14.579
percent is based upon faulty analysis.As already noted,this project will produce
17,222 more tons of polluting gases each year than are being generated now
(the proper baseline).The 14.579 percent is calculated by comparing the
estimated carbon dioxide levels generated if the project were to be "built as
usual,"that is without any GHG reduction measures,(which would never be
permitted and is,therefore,purely illusory)with levels of GHGs generated by the
project they propose.What is more,it will generate more GHGs than if the
project were built to comply with the parcel's existing R-1 and open space
zoning.
Missing from the report is any meaningful discussion about GHG generation
once the project is built and occupied.This period will most likely stretch over
decades.
3 It is curious that the DEIR uses the metric system at this point.A metric ton weighs
considerably more than the "short ton"most Americans are used to working with -2,205
pounds instead of 2,000.Accordingly,15,620.55 metric tons translates to 17,222 tons of
polluting gases.
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Emissions from Autos
According to the DEIR (Table IV.G-5)fully 74.5 percent of the projected carbon
dioxide emissions (11,593.77 metric tons or 12,782 tons)will be from motor vehicles,
yet there are no proposed measures to reduce these emissions.
One measure available for a developer to mitigate the amount of driving and the
pollution associated with it is to place its project near existing public
transportation corridors and close to employment centers.That has been the
model for development in downtown Los Angeles in recent years.Unfortunately,
Ponte Vista does neither.As discussed elsewhere in this document,bus service
along Western Avenue is infrequent and inconvenient and hardly constitutes a
satisfactory substitute to commuting by car.Any doubts about this statement can
be satisfied simply by trying to take public transportation from the bus stop at
Western Avenue and Westmont Drive to downtown Los Angeles,to one of the
office buildings along Hawthorne Boulevard in Torrance or even to the port area.
What is more,the project is not near any major employment center.4 Nor is that
likely to change.The recently drafted San Pedro Community Plan does not
anticipate adding any major commercial centers in the area during the next 20
years.In short,residents of the proposed project are likely to have to commute
considerable distances by car to work.
As discussed elsewhere in this document,the project contains virtually no
amenities (except the pool and clubhouse)or design considerations that would
lessen the need to use ones auto.In fact,it even contemplates the use of the
auto to get to the clubhouse and pool as shown by the proposed parking plan.
The report does note that the project will provide recharging outlets to those
residents who own electric cars.Although commendable,sales of such vehicles
are miniscule.Absent some technological breakthrough in battery life and the
driving range of these cars,they are likely to remain so.
Responsibility
The applicant tries instead to rationalize away the need to even address the
GHG problem concluding that no single development is likely to have a
significant impact on GHGs (pps.IV G-15 and 27).Since the problem is planet-
wide,that is probably true.Given the Earth's vast size and total population,it
might even be true for a vast open pit mine in Alberta,Canada or in Australia's
outback.However the fact remains that the project will generate substantial
amounts of GHGs each year.Moreover,the applicant's line of reasoning implies
that since no single person,project or business can be held responsible;none
4 Despite the fact that the Project is located near the Port of Los Angeles,many of the
Port jobs are a significant distance from this site.Furthermore,the San Pedro
Community Plan Area has a huge deficit in jobs with a job housing ration of 0.44
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need take responsibility for them.That way of thinking must stop now or there is
no chance of dealing with these pollutants.Only by forcing each project to
confront and address the issue properly will there be any hope of reducing GHGs
and the threat they pose.
The analyses of the green house gas emissions and associated mitigations
are inadequate and must be revised.
See also our comments under Traffic and Transportation.
H.HAZARDOUS MATERIALS
The DEIR is selective about its risk assessments,particularly as regards the
Defense Fuel Support Point (DFSP)and the Rancho LPG Holdings.
The DEIR says that a risk assessment was done for events,spills,fires,etc.at
the DFSP (directly adjacent to the Project),and notes that "Although larger than
medium-sized spills would result in a larger zone of impact if they were to ignite,
potentially encompassing portions of the Project Site,the emergency access
features of the Project coupled with the remote nature of such an extreme event
would result in a less than significant impact to future Project residents."
It is insufficient and negligent to say the emergency management plan is that
fire companies can enter through two access points on Western and through one
access point from Taper through Mary Star of the Sea High School and that the
Project is within a 4-mile drive of several hospitals.
The DEIR says "implementation of the Project Design Features would require
that evacuation and emergency response procedures be established in an
emergency response plan for a fire impacting the Project,and the consequent
risk posed to Project residents would be minimaL"It is puzzling that the applicant
can conclude that the consequent risk.is minimal before the emergency
management plan has been developed.
With regard to the Rancho LPG facility,the DEIR notes that "to a much lesser
extent there may be some quantifiable risk of upset from other activities such as
product delivery by rail or truck ...Based on the worst-case RMP scenario and
with the more likely releases having a much smaller radius impact than 0.5 miles,
there would be no impact to the project site."This analysis under estimates
the potential impact to the Project Site,endangering the safety of future
residents,with no proposed mitigations.The US DOT report of butane
incidents by Means of Transportation found that there were 751 rail incidents and
13154 truck incidents in 2003 alone.This is far from an insignificant risk.In
many respects,it would be far more accurate to say that "it is just a matter of
time"before a significant incident occurs.
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In addition,Tosco Refining Company's Risk Management Plan for what is now
the Phillips 66 refinery contains a worst-case scenario (Attachment A)for a
butane incident with a 2.3-mile impact,way beyond the Ponte Vista site.An
additional proof that the risk is far from insignificant is shown in the linked video
showing a 60,000-pound LPG rail tank car being hurled three quarters of a mile
once it caught fire.
It is insufficient to simply state that the risk is "extremely remote"if the DEIR
admits that a larger than medium-sized spill were to ignite it would potentially
encompass portions of the Project Site.The DEIR must discuss the potential
effects of a larger than "medium-sized spill"and evaluate the hazards to
residents,not just waive the obligation to consider the impacts on the
environment.What else will the Project do to mitigate the effect on
residents of a larger than medium-sized spill?
Evacuation Routes
According to CEQA Guidelines,the Project would have a significant effect on the
environment if it would "impair implementation of or physically interfere with an
adopted emergency response plan or emergency evacuation plan."The DEIR
erroneously states that there would be no impact with regard to this guideline.
The DEIR asserts "The Safety Element of the General Plan of City of LA
pertaining to response to disaster events does not designate Western Avenue
within the vicinity of the Project as a designated disaster route."Western Avenue
only south of Summerland is designated as a disaster evacuation route.It also
states that Western Avenue is "too far west"for evacuation from the Port and that
the City of Rancho Palos Verdes (RPV)does not consider Western Avenue as
an evacuation route.These assertions are misleading.
Western Avenue north of Summerland is not shown on the evacuation routes
map of the Safety Element of the General.Plan of the City of LA,because the
map only shows the portion of Western Avenue that is under the jurisdiction of
the City of Los Angeles.On the map,areas that are not under the City's
jurisdiction are in grey.(See Attachment B)Western Avenue from Summerland
to Pacific Coast Highway is under the jurisdiction of Cal Trans,not the City of Los
Angeles.Western Avenue between Summerland and Palos Verdes Drive North
is not shown as an evacuation route on the City map because it is not "in"the
City of LA,not because Western Avenue is not an essential evacuation route;
the DEIR is doing a selective interpretation of the map,and the result is not
credible.
Further,asserting that Western is "too far to the West"for an evacuation route
ignores the fact that San Pedro has only 3 north/south evacuation routes (Gaffey
Street,the 110 Freeway (adjacent to and accessed by Gaffey and Harbor Blvd.),
5 See WWW.YOUTUBE.COMIWATCH?V=XF3WKTWHPIU
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and Western Avenue.If any of the 2 non-Western-Avenue routes is blocked
(note that a portion of North Gaffey Street and a portion of Harbor Blvd.are in
liquefaction zones),Western Avenue may be the only available evacuation route.
San Pedro with the Port operations,storage of hazardous materials,and location
on earthquake,liquefaction,and methane zones,is for more apt to need to
evacuate that any other location in the City of Los Angeles.
The DEIR also misinterprets the Port evacuation plan.Western Avenue may be
too far west for evacuating the Port itself,but it is one of the two,and probably
the main evacuation route for San Pedro and the adjacent cities particularly in
the event of an incident at the Port.
The "entire city of Rancho Palos Verdes,excluding the portion of the City located
east of Western Avenue (approximately 98 acres)is classified as a VHFHSZ
[Very.High Fire Hazard Severity Zone by the California Department of Forestry
and Fire Protection]"6 and in 2009 alone 2000 residents of RPV were forced to
evacuate their homes because of wildfires.For the residents of RPV on the west
side of Western,Western Avenue is the only evacuation route available to them.
It is not credible to assert that Western Avenue north of Summerland would not
be an evacuation route for RPV residents.
Anecdotally and based on empirical observation and on comments of emergency
responders at Rancho Palos Verdes Council meetings,congestion on Western
Avenue at the present time can be a significant interference with emergency
responses.It is not unusual to see LA County emergency vehicles going
northbound on the south bound side of this divided highway or vice versa due to
the extreme level ofcongestion.
San Pedro has really only three viable evacuation routes.One is North Gaffey
Street,which is adjacent to these potential hazardous facilities:Rancho Holdings,
the Defense Fuel Supply Center,and the Phillips 66 Refinery.North Gaffey sits
on earthquake faults and the potential for a fire is great.In addition,the LAFD
(and LAPD)could easily have Gaffey Street blocked due to potential fire and
certain damage from an earthquake as they did when there was a power outage
near Home Depot.
The second principal evacuation route is the 110 Freeway.The City has
indicated that in an emergency,this might be turned into a southbound access
way for emergency vehicles.That leaves Western Avenue as the primary or only
avenue of escape for all 83,000 San Pedro residents,not counting all the Rancho
Palos Verdes residents who would also need Western Avenue for evacuation.
Western Ave.is already clogged during peak hours.It cannot function as an
adequate,viable evacuation route.
6 Safety Element of the City of RPV General Plan,adopted June 2010
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The LA City Comptroller Wendy Greuel said in her 2012 report that the Salvation
Army and the Red Cross are not prepared to handle an evacuation of the City of
Los Angeles.This would particularly apply to an isolated area like San Pedro,
surrounded on three sides by water and with very limited egress routes.In a
disaster,San Pedro could quickly face serious challenges.
Further,the assertion that "traffic will be controlled in the vicinity of the Project"in
the event of a disaster raises a concern that traffic attempting to travel north on
Western Avenue and out of San Pedro and Rancho Palos Verdes will be delayed
while Ponte Vista security attends to Ponte Vista and makes sure it is evacuated
first.This will produce an unacceptable situation and must be addressed in
the DEIR.
The jurisdictional boundary problem cannot be an excuse.The project's impact
on ~vacuation routes must be reanalyzed and appropriate mitigations
developed.
J.LAND USE &PLANNING
The rezoning request will impair the orderly implementation of Regional
Plans,City's General Plan,and two Community Plans.The DEIR fails to
evaluate conformance with the ten Urban Design Principles and nine
Walkability Checklist items.The gated pattern would physically divide an open,
accessible,and established community.
It is not possible to evaluate the environmental impacts of the project because
insufficient information has been provided.In many cases,no information has
been provided.
The DEIR is legally insufficient and needs to be redone.Alternatively,we
encourage the developer to host a planning and design charrette in the
community.The objective of the charrette is for all stakeholders to come
together and develop a preferred layout 'that accommodates the developer's
desire for more intense development than what is allowed in the current zoning
but also meets the community's desire to create an inclusive neighborhood that
complies with Community Plans,General Plan,Regional Plans and City's Urban
Design and Walkability criteria.
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REGIONAL PLANS
Regional Transportation Plan
The Regional Transportation Plan (RTP)provides a long-range vision for regional
transportation investments and considers the role of transportation including
economic factors,environmental issues and quality-of-life goals.
The DEIR references the 2008 "2012-2035 Regional Transportation Plan (RTP)/
Sustainable Community Strategy (SCS)".This is the old version of the Plan.
The DEIR should have used the current 2012 RTP/SCS,rather than the 2008
version,especially since the current version is much more thorough in how to
address reducing greenhouse gasses.
The Sustainable Community Strategy [SCS]portion is a new element of the RTP
that demonstrates the integration of land use,transportation strategies and
investments to meet the region's greenhouse gas reduction targets.The key
land-use policies include focusing growth in centers and along major
transportation corridors around existing and planned transit stops,and creating
significant areas of mixed-use development and walkable communities.
The DEIR does not comply with the requirement to address the Regional
Plan because it does not address how the proposed subdivision brings together
land use and transportation strategy to reduce trips and resulting greenhouse
gasses.It does not even attempt to reduce auto-related greenhouse gasses.
Furthermore,the project does not create opportunities for residents to walk to
local destinations nor does it promote bicycling.Why isn't bike parking a
compliance measure?What if anything will the project do to enhance bicycling on
Western Avenue?
The DEIR fails to address the 2004 Compass Blueprint Growth Vision
Report.The Compass Blueprint Growth Vision is a regional consensus to the
land use and transportation challenges facing Southern California now and in the
coming years.The DEIR is required to address the Blueprint.
The Growth Vision is driven by four principles:
1.Mobility -Getting where we want to go
2.Livability -Creating positive communities
3.Prosperity -Long-term health for the region
4.Sustainability -Promoting efficient use of natural resources
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Mobility:The Mobility principle encourages mutually supportive
transportation investments and land use decisions.A key strategy is to
design complete streets that promote walking,biking,and transit use.
There is no discussion at all how the proposed subdivision supports this
principle.
Livability:The livability element promotes mixed-use development in
"people-scaled"environment.The proposed project includes only
residential uses only,and then limits access.The document makes a few
conclusory statements on the subject,but they are mere assertions with no
facts and no discussion.
Prosperity:The project includes single-family residences,townhomes,
and flats.A range of other uses and building types would better promote
.long-term health of the region.The gated nature of the subdivision signals
a disinterest in civic engagement.Mixed use and encouraging civic
engagement are very important to future vitality of a community.Also the
single-family element is illusory;they are not true single-family homes.
They are located on small lots without the yard space that is typical of a
San Pedro single-family home.
Sustainability:Efficient buildings within compact,diverse,and connected
communities encourage walking,biking and transit use,thus reducing
energy consumption,trips and air pollution.The DEIR lacks adequate
consideration of this requirement.For example,although 75%of energy
needs can be addressed with building layout,placement and design,no
specific provisions are made to integrate a multi-modal split or to certify the
project under LEED-ND.
The proposed gated subdivision utterly fails to meet all four principles of
the Compass Plan.The Compass Plan website?features many proposed and
built development as best practices.None are gated subdivisions.
los Angeles General Plan
The Los Angeles General Plan and its Land Use Framework provide the basis for
land use recommendations in the Community Plans.
The site is located at the southern edge of Wilmington-Harbor City Community
Plan Area and just north of the San Pedro Community.Both community plans are
more recent than the General Plan.Therefore,the community plan's
recommendations are more reflective of the current vision for the site.The
Wilmington-Harbor City Community Plan was last updated in 1999.In August
2012,the Planning Department,working with the San Pedro Neighborhood
7 www.compassblueprint.org
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Councils,released a draft update to the San Pedro Community Plan (SPCP).
The SPCP Plan has the most current vision of the City and the San Pedro
Community.
The proposed project does not meet Objective 4.3 of the General Plan
Framework,to conserve scale and character of residential neighborhoods.
According to the Planning Department's prior report,
The Ponte Vista site is ...not identified for higher-density residential land
uses ....is not located within a Neighborhood District,a Community Center,a
Regional Center,a Downtown Center or a Mixed-Use Boulevard ....the
General Plan Framework does identify downtown San Pedro ...and the area
around the intersection of Avalon Boulevard and Anaheim Street in
Wilmington ...as the Regional Center and Community Centers for the Harbor
area.In addition,these areas are also identified for Mixed-Use Boulevards.
Denser residential development should be focused at these locations and
not at a location such as the Ponte Vista site that has limited access to
services,facilities,and public transit.It also has not been identified for
targeted growth in the Framework Plan ....8
As discussed extensively elsewhere in these comments,it also does not meet
Objective 3.2 "to provide for the spatial distribution of development that promotes
an improved quality of life by facilitating a reduction of vehicular trips,vehicle
miles traveled,and air pollution.
San Pedro Community Plan (SPCP)
The SPCP states that while Ponte Vista "is located just outside and north of the
San Pedro Community Plan Area,this approximately 60-acre site presents an
opportunity for an integrated mixed use and mixed density neighborhood.Its size
and proximity to San Pedro calls for a development that is physically connected
to the San Pedro community and provides public facilities and amenities that
serve neighboring residents."
Land Use Policy 4.5 states,"new development at Ponte Vista should include a
mix of uses and densities,a range of housing types,neighborhood services and
amenities,compatible with and integrated into the adjacent San Pedro
community.Development of the Ponte Vista site should be:
•Designed to provide a mix of housing types for a range of incomes;
•Compatible with a Low Medium density designation;
8 2009 Department of City Planning Recommendation Report CPC 200608043-GPA-ZA-
SP-DA,Ponte Vista Specific Plan,page F-2.
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•Open and accessible to the community,and not developed as a gated
community;and
•Developed with accessible public open space,community facilities and other
public amenities."
The NWSPNC commented during the drafting process for the Community Plan
Update and at the public hearing that it is inappropriate for the Planning
Department to designate the area as Low Medium density in the SPCP Update
as to do so would be a commitment to the designation before the environmental
work had been completed and approved by the City.Since the final version of
the plan has not been released,we do not know if this bullet has been removed.
Nonetheless,the proposed project is in conflict with the three other
policies.
H~using Types
A housing typology is a sequenced range of building types,whose design has
evolved based on time-tested practices.These typically follow social and cultural
norms,financial schemes,market preferences,prevailing climate and
technological efficiencies.A variety of housing types can accommodate a range
of incomes and family types.
The proposed project provides a very narrow range of building types.There are
a number of other types and styles that should be considered such as duplex,
triplex,quads,bungalow court,live-work,courtyard housing,hybrid court,and
commercial flex buildings.See the also discussion of the inadequate analysis of
option B and Attachment C that shows some San Pedro Building types.
Great neighborhoods possess both a distinctive public realm and a rich and
complex fabric of buildings designed and built on private land.Public places
depend on the incremental design of individual buildings around them.The more
harmonious the choice of such buildings,.the more distinguished the ultimate
form of the place.Conversely,the more random the choice of buildings,the more
residual the urbanism.
Open and Accessible to the Community:
The proposed gated community is not consistent with the most current
vision of the City and the adjacent San Pedro Community for the site.The
problem with gated communities is not the gates but the vicious cycle of
attracting like-minded residents who seek shelter from outsiders and whose
physical seclusion then worsens paranoia against outsiders and threatens the
unity of the community.A homogenous environment diminishes awareness of all
that is different and lessens concern for the two communities beyond the
subdivision walls.
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Open Space and Public Amenities:
Among the key residential neighborhood issues and opportunity areas of the
SPCP is "preserving small neighborhood-serving amenities within residential
areas [which]serves the larger goal of reducing vehicle trips by making walking
or bicycling more viable options for simple conveniences.The proposed plan
fails to include any neighborhood-serving amenities.9
As a valuable community resource,open space on this 61.5-acre site can
provide visual delight and recreational opportunities while providing ecological
and economic benefits.A range of open spaces close by encourages people to
spend more time outside engaging in physical activity,such as walking,that
reduces the risk of obesity,diabetes,heart and mental illness,while increasing
socia!connection and a sense of community.
All of the alternatives lack a public park.Some residual parcels are called out as
open space for the residents of the subdivision.This is a monumental missed
opportunity for the Wilmington-Harbor and Northwest San Pedro Communities,
but an even greater loss for the future residents of this subdivision.
Open spaces must be carefully integrated with block,street,building and
frontage standards to work in consort to create a unique place.Open spaces
should include a diverse range of integrated public spaces at the block,
neighborhood,and community level.The individual building types should also
specify private open spaces at the lot and building level.This approach will allow
residents access to a range of public and private open spaces.
Additional Plan Considerations
The NWSPNC requested that the following four bullets be added to the
discussion of the development of the Ponte Vista site in the SPCP:
o Promote home-based offices
o Encourage senior friendly facilities.
o Encourage on site businesses such as a coffee shop or convenience
store.
o Through the mitigation process,this development or any single
development should not be allowed to use up all of the development
potential for the surrounding community.
The proposed project does not address any of these.
While not specific to the Ponte Vista site,the SPCP states the ''The need for
affordable senior housing and assisted living facilities is a key concern due to
9 Draft San Pedro Community Plan,August 2012,page 37
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demographic and economic trends and projections.In San Pedro,such facilities
would increase the opportunities for those 'empty nest seniors'looking to
downsize from large single-family homes while remaining within the community
and the reach of supportive social,cultural and family networks.,,1o The lack of
any senior housing in this project would be a significant missed
opportunity.
Wilmington-Harbor City Community Plan (WHCCP)
The proposed project does not meet the fundamental premises of the
WHCCP.The first premise is limiting residential densities in various
neighborhoods to the prevailing density of development in these neighborhoods.
Although the six acres immediately adjacent to the South is multi-family,this is
an anomaly.This property was zoned commercial with the expectation that it
woul<;i be used in such a manner.Unfortunately,the same code allowed the
multi-family structures to be erected in a manner that is not compatible with the
surrounding community.The surrounding neighborhoods are single family R-1,
with the exception of the Gardens that is 13.5 net dwelling units per acre.In fact,
according to a recent study,80%of the land along the Western Avenue corridor
(Summerland to Palos Verdes Drive North)is dedicated to single-family
residential lots.11
Furthermore,the WHCCP (1-54)designates specific areas for Low median
density and this is not one of them.Instead the plan (IV -3.8)policy is to
"encourage reuse of the existing US Navy housing areas ...in a manner that will
provide needed housing ...without adversely impacting the surrounding area."
Clearly the plan did not consider this property suitable for multi-family housing.
The second and third premises are
...the monitoring of population growth and infrastructure
improvements through the City's Annual Report on Growth and
Infrastructure with a report of the City Planning Commission every
five years ...following Plan adoption ....If this monitoring finds that
population in the Plan area is occurring faster than projected,and
that infrastructure resource capacities are threatened,particularly
critical resources such as water and sewerage;and that there is not
a clear commitment to at least begin the necessary improvements
within twelve months;then building controls should be put into
effect...until the land use designations ...and corresponding zoning
are revised to limit development.
The Annual Report on Growth and Infrastructure has not been done.The DEIR
(1-103)states that the "Projects direct plus induced growth"represents about
10 Draft San Pedro Community Plan,August 2012,page 37.
11 Western Avenue Corridor Vision,Preliminary Analysis and Ideas,November 14,2012
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91 %of the growth forecasted within the WHCCP area,thus this single project will
use virtually all of the planned for growth.Considering that there have been other
residential developments in the 14 years since the WHCCP was developed,
building controls should be put into place until such a study is conducted.
The proposal is not consistent with Objective 1-2 "To locate new housing in a
manner which reduces vehicular trips and makes it accessible to services and
facilities"and Policy 1-2.1 "Locate higher residential densities near commercial
centers and major bus routes where public-service facilities,utilities,and
topography will accommodate this development."As was pointed out in a prior
Planning Department's Report:
The Ponte Vista site is not located within reasonable walking distance to a
transit station,a transit corridor,or a high-activity center.The closest
~ommercial services are located along the east side of Western Avenue,
just south of the Project site (approximately 500-feet south).However,
walking or transit is generally not a viable option to access these services
since they are laid out in a linear fashion within strip malls or plaza shopping
centers,with large parking lots in between the sidewalk and the buildings.12
It is also not consistent with the new vision for Western Avenue that calls for
wider sidewalks,transit,and human scaled environment that would encourage
walking.As the largest new development along Western Avenue,Ponte Vista
has an opportunity to set the tone for others to follow as they redevelop their
properties.
The proposal is not consistent with Land Use Policy 1-1.5 to "Maintain at
least 67%of residential land uses for single family."The DEIR (IV.M-24)
Cumulative residential projects in the City shows 2,195 new residential units of
which only 84 (3.8%)are shown as single-family.Approval of this project would
exacerbate that imbalance.
Furthermore,the proposal is not consistent with Policy 1.5.2 to promote
housing in mixed-use projects in transit corridors and pedestrian oriented areas.
The WHCCP only identifies one such area,Anaheim and Avalon.As discussed
in our comments under transportation,Western Avenue in this area is neither a
transit corridor nor a pedestrian oriented area.In fact the project is isolated and
will require the use of a car for virtually any need.See also the discussion of the
lack of public transportation under Traffic and Transportation.
The proposed project does not meet Objective 8-2 and policy 8-2.1 of the
WHCCP which seeks "to increase the community's and the Police Department's
ability to minimize crime and provide security for all residents,buildings,sites,
and open spaces"and to "support and encourage community-based crime
12 Department of City Planning Recommendation Report CPC 200608043-GPA-ZA-SP-
DA,Ponte Vista Specific Plan,page F-3.
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prevention efforts (such as Neighborhood Watch),through regular interaction and
coordination with existing community-based policing,foot and bicycle patrols,
watch programs,and regular communication with neighborhood and civic
organizations."
The proposed gated environment would likely breed fear,erode social stability
and shrink the notion of civic engagement by encouraging residents to retreat
from civic responsibility.It creates an unsafe environment both inside and
outside the gates.13 The appropriate response to reduce crime,poverty and other
social problems,as recommended by the WHCCP,is for the neighborhoods to
work together.The best way to bring security to the streets is to make them
delightful places that people want to walk in.The streets become,in effect,self-
policing. Fences and gates exacerbate the problem.
Chapter IV of the WHCCP identifies recommended actions.For residential
housi'ng,number 11 is to "encourage the development of housing types intended
to meet the special needs of senior citizens and the physically challenged."
Failure to do so in the proposed project is a real missed opportunity.
LA MUNICIPAL ZONING CODE
The current R-1 zoning is a combination of R-1 and open space.According to
the DEIR,this zoning would permit about 385 units.Alternate C for 830 units
would more than double that development intensity,and Alternate 0 would triple
the intensity.This increased intensity would increase demands on existing
community facilities such as schools, libraries,parks and recreational amenities.
In an uncharitable and perverse logic,future residents of this subdivision would
be able to use all San Pedro facilities but San Pedro residents would not be
allowed access to parks and recreational amenities located inside the gated
community.
It is not clear what the trigger is for increased intensity at this location.The
zoning conditions,cost of site acquisition,and removal of existing structures are
pre-existing conditions.These are not appropriate factors or justifications for
increased development intensity.This is especially true for the cost of site
acquisition;the fact that the applicant bank loaned the original buyer far more
than the property is worth,is not an appropriate justification for failure to consider
Alternative B.According to the DEIR Alternate B houses would have to sell for
more than $1,000,000.
No support whatever is provided for this claim.However,using the January 2010
"Residential Building Costs"published by the State of California Board of
13 Blakely,E.J.,and M.G.Snyder.(1998)."Separate places:Crime and security in gated
communities."In:M.Felson and R.B.Peiser (eds.),Reducing crime through real estate
development and management,pp.53-70.Washington,D.C.:Urban Land Institute.
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Equalization 14 the cost of building good quality single family houses is far less
than claimed by the applicant.The 216-page publication provides building cost
data for a variety of residential building types,sizes and quality.The costs
include entrepreneurial profit and adjustments for location where the units are to
be constructed.They do not include discounts for multiple units being
constructed at the same time however,which would make the cost even lower.
By way of example,the cost of constructing 385 good quality single-family
houses on 61.5 acres with a land cost of $120 million would be $584,728.31
each,far lower than the unsupported claim of the applicant.15 .
We chose a quality level 08 home of 2000 square feet.16 There are 10 levels of
construction quality,with 10 being highest.The publication includes descriptions
of each quality level and photos of each type.From observation,San Pedro
would mostly consist of level 06 quality.We used level 08,a much higher
quality level.A description of the characteristics of 08 quality,photos of
examples of houses of that quality,and the cost of construction are attached as
Attachment D.Had we used 06 quality level,the cost per house would be
$474,751.31.
Further,the analysis of Alternative B claims there will be no open space even
though 15 acres are zoned open space.It also claims that Mary Star will lose
road access through the property.These assertions are true only if the City
allows that to happen.
URBAN DESIGN PRINCIPLES
In 2009,the City Planning Commission approved Urban Design Principles to
provide guidance on how street,block and open space design can create
desirable and resilient neighborhoods that instill a sense of community.
The ten Urban Design Principles are:
1.Develop inviting and accessible transit areas;
2.Reinforce walkability,bikeability,and wellbeing;
3.Nurture neighborhood character;
4.Bridge the past and future;
5.Produce great green streets;
14 http://www.boe.ca.gov/proptaxes/pdf/ah531.pdf
15 385 houses at 2000 sf each,=770,000 sJ.Cost from table $124.11 times 1.10 LA
County adjustment =$136.52 psf.Total construction cost 770,000 X $136.52 =
$105,120,140.Add:Land cost $120,000,000 =$225,120,140 total cost land and
construction,or $584,728.31 per house.
16 The unattached houses in the Taper area,Mount Shasta area,and around Dodson
Middle School are 1350 sf to 2200 sJ.with an average of 1800 sf.We use 2000 sf.
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6.Generate public open space;
7.Stimulate sustainability and innovation;
8.Improve equity and opportunity for all;
9.Emphasize early implementation,simple processes and
maintainable long-term solutions;and
10.Ensure connections.
The DEIR fails to address or evaluate whether the proposed project
complies with these ten Urban Design Principles.They were adopted by the
Planning Commission and should be addressed in the DEIR.
WALKABILITY CHECKLIST
Streets make up the lion's share of the public realm.It appears that streets in this
subdivision are largely shaped by engineering standards intended to regulate the
flow of traffic and infrastructure.
Streets are important civic spaces where the social and communal life of a
neighborhood takes place.The street design inspires the context.Mobility is a
means,not an end.Streets must be inviting,safe and secure place for walking,
biking and transit for people of all ages,income and physical limitations.Less
driving,reduces energy consumption and greenhouse emissions.Walking and
biking improves overall health of the community.
The proposed site plan shows front-loaded garages with driveways.A front of a
home should face another front and conversely the back should face another
back.In many instr,mces,the front frontages face the side or back of another
home.These basic principles are important because they establish the context
for the street and have a direct impact on walkability.
The City's Walkability Checklist is a guide for consistency with the policies
contained in the General Plan Framewo.rk with respect to urban form and
neighborhood design.The purpose of the Walkability Checklist for Entitlement
Review is to guide Planning staff,developers,architects,engineers,and all
community members in creating enhanced pedestrian movement,access,
comfort,and safety.The Checklist provides guidance on nine topics:public
sidewalks,crosswalks,on-street parking,building orientation, on-site parking,
landscaping,building facade,lighting and signage.
The DEIR fails to make a finding of conformance with the policies and
objectives of the General Plan related to the project's walkability.
Walkability conformance is potentially significant due to the exclusive and gated
pattern of the proposed development.
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L.POPULATION AND HOUSING
PLAN FRAMEWORK ELEMENT
Objectives
The DEIR indicates that one of the relevant objectives is:
4.2:Encourage the location of new multi-family housing development
to occur in proximity to transit stations,along some transit corridors,
and within some high activity areas with adequate transitions and
buffers.
The proposed project does not meet this objective.The location of the
project is isolated with extremely limited public transit options as discussed in the
transportation comments.Residents of the proposed development would either
have very long walks (highly unlikely)or drive to everything.
Housing
The DEIR (IV.I-22)states that "The jobs-housing ratio in the City of Los Angeles
Subregion -i.e.,the numerical ratio of 1.34 jobs to households -was very close
to the ratio for the SCAG region as a whole in 2010 (1.37)...and is therefore
considered close to "balanced."By adding 490 indirect/induced jobs ...the
Project would have no impact on the Subregion's 2010 jobs-housing balance ....
By 2017 however,the Subregion is forecasted to add households at a faster rate
than jobs ...such that the Subregion would be considered "housing right/jobs
poor"....By adding 490 indirect/induced jobs ...the Project would have a neutral
numerical impact...."
The premise of this description is flawe~leading to a false conclusion.The
description fails to note that the local job/housing balance that is significantly
different than that of the Subregion.According to the draft San Pedro
Community Plan,San Pedro has a jobs/housing balance of 0.44.The addition of
1135 households would therefore further reduce the jobs/housing balance in the
area.This is a significant negative impact and indicates that the project would
be primarily a commuter community.Mitigation measures should include the
creation of jobs on site.
We question the SCAG growth estimates and hence the need for additional
housing since the 2010 census actual population numbers are well below SCAG
2005 estimates and projections.The DEIR (IV.L-9)discusses the SCAG
Regional Housing Needs Assessment that was developed for the period January
1,2006 -June 30,2014.This is an old document. The new version of this
document should be used.Furthermore,this old version has been shown to
have grossly overestimated the projected growth for Los Angeles in general and
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San Pedro in particular.For example,the SCAG 20005 population estimate for
San Pedro was 82,112;however,according to the 2010 census there are only
76,651 persons in San Pedro,5,461 fewer.If the 2.5%growth forecast from
2010 through 2017 were applied,this would add 1916 to the population of San
Pedro by 2017 still significantly below the 2005 SCAG forecast upon which the
housing needs were developed.Consequently it is in error to conclude that
the project will not induce substantial population growth in an area by
proposing new homes.
The justification for multi-family housing types is erroneous.The
surrounding area is not all multi-story,multi-family housing.About 60%of San
Pedro is multi-family;there is a glut of such housing on the market in San Pedro,
some of it immediately south of the project.[While some of the condo projects
built in the last five years are occupied,they are rental units because the
develppers cannot sell them].Single-family housing is the housing type in
greatest demand.
Moreover,by building what it proposes,the applicant will undercut and greatly
impact the Community Plan for San Pedro that emphasizes the rebuilding and
renaissance of downtown San Pedro.The creation of a livable,walkable
downtown area has been challenged by a lack of demand for the condos that
have been built there.
M.PUBLIC SERVICES
The City has the obligation and responsibility to provide the necessary services
to enhance our quality of life.The City is already being challenged to do so.Ask
any tax paying citizen who has had to wait for requested police or fire response
or who is witnessing the decay of their neighborhood for lack of tree trimming,
street sweeping,street and sidewalk repair,failing schools and the list goes on.
The Ponte Vista DEIR,with its 4,009 direct and indirect residents,seems to base
its claim that the impact of the preferred plan would be 'less than significant'and
'less than significant with mitigation'on the fact that no new fire or police facilities
would be required.The claim is an attempt to make a case for building as large
of a project as possible without considering the real consequences it will have on
the existing community;it is not just about buildings,it is about impact on the
community including the availability of personnel to respond to called for services
and to participate in proactive crime and fire prevention measures.
This project is being developed in an existing area that currently requires a
comparatively limited number of calls for services,therefore,any increase should
be considered significant.The project area is currently zoned for R-1 and open
space,which would be the ideal 'fit'for the existing neighborhood community and
have a minimum negative impact.This describes Alternate B,which has less of
an environmental impact than Alternate C,the preferred Alternate.
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Admittedly determining the anticipated impact of this project on the existing
community is purely a speculative process generated by infinite unknowns.Calls
for service may result from intentional and accidental human acts and acts of
nature,some minor and others more serious or even catastrophic in nature,but
all significant to those impacted.
What is clear,however,is that the more people,the more buildings,the more
streets,the more cars,etc.,the more significant the demand for police,fire,and
EMT/ambulance services and the higher the probability of an unacceptable level
of service in the Harbor Area.In fact,in a recent editorial the Daily Breeze
(December 31,2012)states "Unacceptably long response times are dogging the
Los Angeles Fire Department and must be addressed immediately.It's a matter
of life and death,as illustrated earlier this month by the case of a 16-year-old boy
who yollapsed while playing soccer at Wilmington Middle School."The mitigation
proposed in the DEIR relative to first responders is limited to on-site measures.
In reality that's all the developer can do because they do not have the power to
hire more first responders or purchase needed vehicles.
Parking in streets and parking structures vs.private garages,apartment living vs.
single family residences,real park space vs.limited green space,more cars on
already overburdened streets are but a few examples of conditions with the
potential of having a significant impact on calls for services.The current plan is
more conducive to creating a contentious rather than harmonious neighbor.
Another significant fact to consider is that the project is located at the tip of a
peninsula and not adjacent to other L.A.City first responders.Needed
assistance,in extreme emergencies,mayor may not be available from
neighboring cities or the County.Help from L.A.City Fire and Police stations are
unspecific miles away depending on the availability of their first responders at the
closest facility.The Harbor Area is exposed to a much higher level of hazardous
sources that could result in devastating consequences and liability issues than
any other part of the City.The most volatile and closest to the Ponte Vista site is
Rancho LPG.The City can ill afford minimizing and ignoring the vulnerability of
Ponte Vista and its 4,009 residents.According to the EPA Guidance to enforce
40 CFR Part 68,if 57,000,000 pounds of butane (roughly one of the refrigerated
Rancho tanks)were released,the blast radius would be 3 miles.
1.FIRE PROTECTION
The analysis of fire protection and proposed mitigations is inadequate.
The DEIR states that all public street fire lane cul-de-sacs shall have the curbs
painted red or be posted "No Parking Any Time"prior to the issuance of a
Certificate of Occupancy or Temporary Certificate of Occupancy for any
structures adjacent to the cul-de-sac.
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The streets in the project are proposed to be private streets,so where will the
"public"street fire lanes be?This contradiction should be fixed.Where will the
guests park?Please state how the no-parking zones and red curbs will be
enforced.What if cars are illegally parked in red zones and in private lanes
making it impossible for emergency vehicles to get through?
The DEIR section on Fire Protection says that the Project is not within the
maximum response distance between residential land uses and a LAFD fire
station.The DEIR says that this will be mitigated by sprinkler systems installed
throughout all structures to be built as part of the Project.This is taken from
LAMC,but requires clarification.
The proposed mitigation states sprinklers will be installed throughout all
structures but does not specify if fire sprinklers will be installed inside every
resid~ntial unit."The US Fire Administration supports the recently adopted
changes to the International Residential code that require residential fire
sprinklers in all new residential construction.It is the position of the U.S.Fire
Administration that all Americans should be protected from death,injury,and
property loss resulting from fire in their residence.All homes should be equipped
with both smoke alarms and residential fire sprinklers.,,17 Please clarify the DEIR
and address implications if sprinklers are not installed in every residential unit.
The DEIR fails to address the anticipated response times for paramedic/EMS
services provided by LAFD.Additionally,Western Avenue is the main access
road for ambulances to the Little Company of Mary Hospital in San Pedro and an
important access road to Kaiser Permanente Hospital in Harbor City.The DEIR
should include mitigations for the longer response time in EMS/paramedic
services.In emergency medical situations every second counts!Proposed
mitigation might include,but should not be limited to,defibrillators on site.
Please address this issue.
The DEIR correctly states that "The LAFD's ability to provide adequate fire
protection and emergency response services ...is also determined by the degree
to which emergency response vehicles can successfully navigate the given
access ways and adjunct circulation system,which is largely dependent on
roadway congestion and intersection level of service (LOS)along the response
route."The DEIR indicates that two of these intersections are currently operating
at LOS E or F,and goes on to state that "None of the intersections that provide
direct emergency access to the Project Site [Western &Green Hills,Western &
john Montgomery]currently operate at LOS E or F during peak community
hours."While it may be true that neither of the intersections that provide direct
access currently operated at those levels on the day they were studied,the
conclusion is misleading.The proposed primary entrance to the facility is at
Green Hills Drive and John Montgomery Drive.When San Pedro has one of its
17 Source:US Fire Administration,June 2009
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legendary (and frequent)lengthy funeral processions (a local custom,or during
Christmas shopping season,or when there is an emergency situation or road
repair (not an infrequent occurrence),Western Avenue backs up for blocks.It is
not unusual to see emergency vehicles trying to go against the traffic on this
divided highway.In addition,what good is it if that intersection is open but
Western and Palos Verdes Drive North or Western and Capitol,are blocked.The
additional traffic from the proposed development will only compound this
situation.
The DEIR should also address how additional residents of the Project
would affect availability of EMS services.
Mitigation measure IV.M-9,Project Design Features,discusses the development
of an emergency response plan and indicates that during the development of the
plan ~he Project Applicant should consult with neighboring land uses.None of
mentioned users includes the residents.Please add the Northwest San Pedro
Neighborhood Council,the Harbor City Neighborhood Council,and the City of
Rancho Palos Verdes to the list.Please also add a requirement that the
emergency response plan should ensure that there would be no adverse
impact on the evacuation of surrounding neighborhoods as a result of any
evacuation of the project area.There is no guarantee of additional police
or firefighters to meet the additional demands.
Additionally,the development of the Emergency Response Plan should be
included Table I-I as either a Compliance Measure or a Required Mitigation
Measure.
2.POLICE PROTECTION
For purposes of analysis of impact on police services and possible need for
additional police officers,it is assumed that the Project would result in a net
addition of 4,009 persons to the Harbor Area.Population increase in an area
typically increases demand for police services.The applicant however,says that
security and design features in the project should help to decrease need for
police services.This mayor not be true.We suggest that the Project be
required to include Anti-Graffiti measures and comply with street lighting
guidelines as if the streets were public streets.
Additionally,the DEIR should examine the impact on police services in the
event that the gated nature of the project is not approved.
3.SCHOOLS
There are several problems with the methodology used for the school impact
analysis.
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The student generation rates used are not consistent with those used by the City
in the DEIR for the San Pedro Community Plan Update.That document says the
LAUSD student generation rates for multi-family residential units are 0.2042
elementary (K-5),0.0988 middle school,and 0.0995 high school.According to
the Community Plan DEIR the "rates vary slightly with single-family,units,but
provide an accurate approximation.,,18 The DEIR projects two different student
generation rates for Taper,a rate of .1705 per du for single family,and .1141 for
the condos and townhomes.The LAUSD generation rates cited in the DEIR for
the San Pedro Community Plan update should be used.Additionally,the
students generated by the approved,but not yet built Harbor Highlands
development must be includ,ed in the analysis for Taper and Dodson.
The school enrollments and capacity should both use the total school capacity
and enrollment.The DEIR incorrectly indicates the school enrollments for
2011 7 12.According to LAUSD's website,the 2011-12 enrollment was 626 at
Taper,1819 at Dodson,and 3335 at Narbonne.More current enrollments show
them at 629,1863,and 3350 respectively.(See Attachment E).According to
LAUSD,these enrollment figures include both the regular school students and
the magnet school students.Likewise the capacity figures used must include
both the regular and magnet school capacity.The chart below uses the current
student population and capacity data obtained from LAUSD on January 4,
2013.19
Current Ponte Harbor Total Capacity Difference
Students Vista20 Highlands
Taper 629 231 27 887 804 83
Dodson 1863 112 13 1988 1892 96
Narbonne 3350 113 0'1 3463 3531 (68)
As can be seen,if the correct,current figures are used,both Taper and
Dodson would be over capacity.This is a significant impact and must be
addressed.
Certainly the cumulative impact of school-related traffic is a major and possibly
unmitigated consequence of any new development on the property.The reality
is that children at all grade levels,particularly the elementary level,DO NOT,for
the most part,walk to school anymore.They are almost exclusively driven,
18 San Pedro Community PlanDEIR p 4.12-31
19 The Current Students and School Capacity figures were obtained from Bruce
Takeguma,Director,LAUSD,School Management Services (213)241-3344
20 For Ponte Vista and Harbor Highlands the student generation rate from the San Pedro
Community Plan was used.
21 Although Harbor Highlands will generate 13 students,they would go to San Pedro
High School,not Narbonne and therefore are not counted here.
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resulting in serious traffic tie-ups at both ends of the school day,as well as many
unique trips in and out of any development.This is particularly true in San Pedro
where a variety of relatives are available to pick up and deliver children to and
from school.Mitigations should be proposed to encourage children to walk to
Taper and Dodson.
Developer fees from SB 50 would be approximately $900,000.We understand
that State law concludes that the contribution meets all CEQA requirements.
However,the adequacy of the contribution to provide increased need for facilities
does not address the impacts on traffic and the need to protect children on the
way to and from school.It would seem useful to use at least a portion of those
monies to improve traffic flow and control around impacted schools,particularly
Taper Ave.Elementary.
Additionally,the discussion of the Port of Los Angeles High School should be
revised to indicate that the school currently has a waiting list and that admission
is by lottery.
The list of high school magnet programs should be revised to include the
Teacher Prep Academy located on the campus of Harbor College and Trinity
Lutheran should be added to the list of Private Schools.
4.PARKS and RECREATION
The City's Public Recreation Plan calls for 10 acres of land per 1,000 persons
and provides that "A minimum of 10 percent of the total land area should be in
public recreation or open space.It also says that Neighborhood Parks should be
provided at a minimum of two acres per 1,000 residents and be five to 10 acres
in size with a service radius of approximately one-half mile."Based on this
standard,a project with an estimated population of 2,923 should contain at least
a 6-acre Neighborhood Park.The Recreation Plan indicates Neighborhood
Recreation Sites typically include facilities for active sports such as softball,
basketball,soccer,and volleybal1.22
Currently 15 acres of the property is zoned open land (parks and recreation).It
seems logical that park space (active and/or passive)should be a top priority.
The DEIR is based on a project description that includes a 2.8-acre public park
that even if it were built would be inadequate.Subsequent to the initial
description,the applicant deleted all public park space from the proposed project.
The applicant claims impacts related to parks and recreational facilities would be
less than significant,as the two swimming pools on the property and what can
only be described as mini-parks or "parklettes"scattered around the property will
fulfill the project's residents'needs for recreation space.While these amenities
22 See Los Angeles public Recreation Plan page 2 for a complete list.
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are commendable,they do not constitute a Neighborhood park and do not satisfy
the requirements of the City's Public Recreation Plan.The theory in the DEIR
seems to be that residents will not use external truly public facilities,with the
result there will be so little additional usage of public parks that impact will be
insignificant.Where will the youth play basketball,football,tennis,and soccer?
The lack of adequate park space is a significant impact.It is insufficient to
say that the project will pay the required Quimby fees.Quimby fees do not
provide land for parks and there is no land available for purchase within the half-
mile service radius.
This development team,as did the team before,predicates its plan on a truly
mystifying lack of interaction between the development and the world
surrounding it.No traffic,no impact on schools,no pressure on recreational
facilities-no need for any improvement to infrastructure beyond the bare
minimum that might be expected of a strip mall or a 6-8 home development,on a
square footage basis.
The assertion that "there is no existing park area at the Project site"is at best
misleading and should be deleted.Currently 15 acres of the site are zoned for
open space.
5.LIBRARIES
The DEIR is not accurate in its assertion that the current San Pedro library,at
20,000 square feet,is adequate size for the population served,and should be
adequate to meet the needs of the increased population added by the
development.This claim is in conflict with the DEIR for the San Pedro
Community Plan that states "The available public library services in the San
Pedro CPA,in terms of library space and permanent volume collection,are
currently inadequate to meet existing demands from the community's residents
based on state library standards ....of 0.5.square feet per person.,,23 The State
of California Library standard requires 0.5 sq ft of library space per resident.For
the existing population of 76,651 residents (2010 census data),library space
available should 38,325 square feet,nearly double the existing space.Since
the project would add nearly 3,000 additional residents,and it would require at
least 1500 square feet of additional space.
The DEIR further asserts that the LAPL is "currently planning to build a new
West San Pedro neighborhood library in the future."While it is true that LAPL
has identified a need for a library in West San Pedro,it is misleading to say that
they are "currently planning."The Community Plan for San Pedro recommends
a new 14,500 square foot "West San Pedro"branch library,however,this would
only bring library space in San Pedro to 34,500 square feet,still not meeting
23 San Pedro Community Plan DEIR p 4.12-40
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State of California library standards for the population of San Pedro.The San
Pedro Community Plan acknowledges that no location for a 'West San Pedro"
library has been proposed or selected,there is no plan for selecting a site,and
there is no current nor anticipated funding for building said library.The fact that
one is proposed is further indication of the need for additional library services,a
need that will be aggravated by the proposed project.It will have a significant
impact on library services and this impact must be mitigated.
The Ponte Vista project has an opportunity to mitigate this defect by
incorporating a public library into the project.The library should be at least
20,000 square feet to meet State requirements.The San Pedro Community Plan
recommends integrating libraries into multi-use buildings.For reference
consider the Milwaukee Public Library is moving ahead with development of two
multi-use buildings including libraries:one is a proposed 16,000 square foot
libra!)'topped with 92 apartments (plus parking).24
The San Pedro Community Plan also suggests that on-line services and virtual
libraries with computer workstations that provide access to the library's on-line
catalog,extensive information databases,multimedia software for students,and
free Internet searching for the public may lessen the adverse impacts resulting
from a mismatch between available physical library space and resources and
the community's need for library facilities.,,25
N.TRAFFIC
The entire focus of the traffic impact analysis is on measuring the number of cars
moving at the intersections.While the movement of autos is important it is not
sufficient.As the City has shifted its focus to mobility,so should the analysis in
the DEIR.The DEIR fails to address any measured analysis of walking,biking,
or transit and ignores other design features that could reduce car-usage such as
on-site amenities and provisions for home-offices.
The traffic analysis estimates the impacts on streets and intersections in and
around the project.The analysis looks at the ambient growth rate of existing
traffic,the traffic contributed by other projects,the traffic contributed by the
project itself,and compares this traffic load to existing intersection usage,
expressed as the vehicle counts compared to the intersection capacity [VIC
ratio].From this,the analysis determines the "Level of Service"[LOS]in the
existing condition and compares it to the LOS if the project is built.For those
intersections showing certain increases in the VIC ratio,or a decrease in the
LOS,the DEIR proposes mitigation measures designed to lower the impact so
that it is not significant.
24See http://urbanmilwaukee.com/2012/02/28/east-library-redevelopment-advances-at-
city-plan-com mission-renderings/
25 San Pedro Community Plan DEIR p 4.12-40
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We have concerns about how the variables were calculated and the
accuracy of the LOS results obtained,about the way in which mitigation is
determined,and the failure to address how to design the amenities on the
site in order to reduce traffic generation.This should be corrected.
1.IMPROPER CALCULATION OF THE VARIABLES
Improper Use of ITE Traffic Generation Data
The project-generated traffic is underestimated because the applicant used the
midpoint data for each housing type while ignoring project characteristics.
The DEIR uses three different ITE housing classifications to predict trip
generation.It uses the average trip generation figures for each classification.
ITE figures represent thousands of studies and a wide range of reported trip
generation figures.In this case,there is no difference between how often
residents of each different type of unit will need to use their vehicle in this project,
but the analysis contains no discussion of this.Instead,the DEIR simply uses
-the mid-point figure.For example,the DEIR indicates that a single-family house
will generate 9.57 trips per day while a three-bedroom condominium right next
door will generate 5.81 trips per day.This makes no sense when residents of the
project will have to drive to every destination,whether to work,school,soccer
practice,the gym,church,or the market.The applicant should have selected a
trip generation rate in the reported range closer to the single-family rate because
the project characteristics are so similar.
Further,each trip generation graph in the ITE Manual includes a wide range of
actual trip generation numbers.To select the mid-point is difficult to justify.26
Had the developer and the City used more appropriate data points within each
classification,as they are permitted to do,.and admonished to do by ITE itself,
the trip-end volume would be 10,862 instead of 7,462.AM peak hour volume
would increase from 571 to 851 and PM peak would increase from 669 to 1146.
Using these calculations,and using normalized traffic counts,would greatly
increase the VIC ratios and lower the LOS ratings at many more intersections
among the 56 tested intersections.
The VIC Ratios Used as a Baseline Need to be Normalized
The vehicle counts used in the VIC ratios and the LOS calculations are lower
than normal due to the impact of the economy on "real"traffic generation rates.
26 We suggest that perhaps the traffic problems in other areas ofthe City and
increasingly in San Pedro,Wilmington and Harbor City,can be attributed to this practice
of using mid-point calculations rather than more realistic data.
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The impact is shown in the DEIR counts in 2010,which are lower than earlier
counts taken by the same consultant in 2005 for the prior project,lower than the
counts taken for the Target Store analysis in 2006 and lower than many of the
counts for the Marymount project on Palos Verdes Drive North in 2011,after the
installation of ATSAC/ATCS.For example,the VIC PM ratios for Western and
PV Dr.North are
2005
2006
2010
2011
1.025
1.078
.851
.872
[Ponte Vista I]
[Target]
[DEIR,present project]
[Marymount]
This difference is noticeable at many of the intersections common to all four
studies.
It is shown in concrete terms,for example,by the reports of the annual TEU 27
counts in the Port of Los Angeles (an indicator of workload for Port workers)that
declined from 8.5 million TEU's in 2006 to 6.7 million TEU's in 2009.It is
beginning to recover but has not reached pre-recession levels.
Our concern about the use of the October 2010 data at the height of the
economic downturn has been discussed with the applicant's representative on
several occasions.Normalized data is used in many,many other areas of
planning,such as employment data,business valuations,and indeed,
environmental tests.It is not possible to properly determine true,likely impacts if
baseline data is atypical.That is a recipe for gridlock.
Failure to Include Data from Other Projects
CEQA requires a DEIR to include traffic generated by other known projects in the
traffic generation estimates,The applicant left out a number of such projects,
many of which impact the studied intersections.We listed them earlier in our
comments.We repeat them here:
Southern California International Gateway (SCIG)
APL Terminal expansion
Ports O'Call Redevelopment
Cabrillo Marina Phase II
USS Iowa
27 Twenty Foot Equivalent Units,a measure used to normalize cargo counts since not all
containers are the same size.
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Los Angeles County Sanitation Districts Clearwater Outfall Project
Rolling Hills Prep School build out
VOA Navy Village
Pacific LA Marine Terminal
Harbor Highlands Development (under construction)
City Dock 1
Port Master Plan update
San Pedro Community Plan update
Marymount College Expansion on PV Drive North
Of particular interest is the Community Plan Update,which forecasts an almost
10%population growth for San Pedro not including Ponte Vista in the next 18
years.
The Ambient Growth Rate of 1%is not Supported by any Documentation
Both the DEIR and the Western Avenue Task Force used a 1%growth rate for
Western Avenue,but CalTrans engineers opined in those meetings that the
growth rate was actually much higher.
Rather than use a number obtained from MTA,as does the DEIR,we suggest
that documentation be provided.
Public Transportation is Not Really Available to the Site
The DEIR (1-133)states that there are 14 buses per hour serving the project
during the morning peak hour.This is misleading and should be corrected.
There are four bus lines that serve the project site,none well.
Metro Bus Line 205 runs from 13th and Gaffey Streets to the Imperial
Wilmington Station at Imperial Highway and Wilmington Avenue in the
WattslWillowbrook Area.The frequency varies from every 20 minutes during the
am peak hour to 1 hour.This bus goes up Western and connects to the Artesia
Transit Station where it is possible to transfer to another bus to go to downtown
Los Angeles.Unfortunately it takes approximately 40 minutes just to get to the
Artesia Transit Station;there is no incentive for future residents to be so
inconvenienced.
Max Line 3 runs from 36th Street and Pacific Ave in San Pedro to LAX Green
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Line Station and the Airport Courthouse.It operates northbound to EI Segundo in
the early AM and southbound to San Pedro in the late afternoon.MAX Line 3
does not operate on major holidays or on weekends.It only makes 4 trips in am,
the first at 5:36 and the last at 6:44 am and 4 in pm between the hours of 4:46
and 6:15 pm;basically 2 buses/hour.This is a viable option if your work is in El
Segundo.
The remaining two lines are operated by RPV and are primarily designed to
transport RPV students to RPV schools.
PV Transit Orange Line runs 2 morning buses along Western from Palos
Verdes Drive North to First Street then to Palos Verdes Drive East ending at
Palos Verdes High School and 3 buses in the afternoon corresponding with
school start and stop times.These lines are designed to carry Palos Verdes
students to Palos Verdes schools,and as such are really not useful to the
residents of Ponte Vista.
PV Transit Green Line is also geared primarily to Palos Verdes schools and the
Library.It runs along Western Avenue from First Street to Palos Verdes Drive
North then west along Palos Verdes Drive Road ending at Ridgecrest
Elementary School.
2.COMMENTS CONCERNING PROPOSED TRAFFIC MITIGATIONS
Some Offered Mitigation is Already Proposed by Marymount
Marymount College is required to implement some of these same by mitigations
as part of the approval of its mitigated negative declaration for its project on
Palos Verdes Drive North.It is our understanding that if any of the proposed
mitigation measures are provided by another source (e.g.Marymount College),
prior to being implemented by this Project,an alternate mitigation measure may
be required.We request that in the even.t that should occur,the applicant be
required to consult with the Northwest San Pedro Neighborhood Council,the
Harbor City Neighborhood Council,and the City of Rancho Palos Verdes on
appropriate mitigation measures.
Other Mitigations Transfer the Traffic Burden to Wilmington and Harbor
City Residents
Quite a bit of the proposed mitigation is designed to increase the overall capacity
at an intersection by addressing other traffic issues and thus could potentially
allow longer turn and through signals for the project traffic.In other words,traffic
from Harbor City,Palos Verdes and Wilmington will be adjusted,possibly
negatively impacted,in order to make more room for Ponte Vista traffic.
The Projected Routing for PM Peak Hour Traffic Does Not Seem to Have a
Basis
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We realize that predicting access routing is sometimes an art rather than a
science.However,given the very long PM backups at the 110 Freeway off-
ramps at Sepulveda,Pacific Coast Highway and Anaheim,coupled with the
challenge of making a left turn across Western,it seems likely that in the
evening,a large percentage of commuters will exit at Channel Street and
proceed north on Gaffey to Channel,Capitol,or Westmont and then west to
Western to the project entrances.This assumption is given further credence in
that virtually every place a commuter might want to stop on their way home,be it
for groceries,dry cleaning,or to pick up a child,is off of either Gaffey or that
portion of Western that lies between Channel and Westmont.Further,this
commuter traffic will be joined by those residents who are coming home from
downtown San Pedro and the San Pedro Waterfront and from Long Beach and
points south via the 47.An analysis of all of this traffic should be included.
The Proposed Project Makes No Attempt to Mitigate Project Generated
Traffic Through Project Design or Project Amenities
A significant amount of project-generated traffic will be work related traffic.Other
components will be taking kids to soccer practice,taking children to school,going
to the markets and library,church,etc.Work-related traffic will be especially
heavy,and for greater distances then normal,because the project is not really
responding to local employment needs.28 In other words,they are proposing a
suburban commuter community.
What is striking about the proposed project,and the DEIR,is that it proposes
nothing to mitigate trip generation by providing amenities on-site,such as work
centers,library branch,parks,mini-market,better walking access to local
schools,etc.
OTHER CONCERNS
The DEIR fails to analyze the impact of increased traffic on Western from
the 74 driveways and non-signalized intersections on Western between
Summerland and Palos Verdes Drive North.According to a recent study of the
Western Avenue Corridor,there are 111 destinations on Western between
Summerland and Capital Drive.29 These grocery stores,post office,dentist
offices,coffee shops,banks,etc.are accessed through the driveways.These
poorly designed driveways add to the traffic flow problems.For example,the
turn lane into the shopping center nearest the project can only accommodate
28 The DEIR for the San Pedro Community Plan Update established that the jobs per
household ratio for San Pedro was 0.44 while the Los Angeles area ratio is 1.35.This
means that for the 1135 households in the project,assuming two working adults,550 will
drive to local jobs and 1700 will drive a longer distance.
29 Western Avenue Corridor Vision Preliminary Analysis and Vision,Nov 14,2012
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about 4 cars.After that,cars begin impeding the flow of traffic on Western.This
is a very unique condition and an analysis should be conducted of the impact of
the traffic generated by the Ponte Vista residents using these driveways.
Additionally,the assertion that 60%of traffic will be going North and 40%south
on Western does not seem credible given that virtually all amenities are located
to the South.
We are concerned about the impact on traffic flow along Western from installing
additional stoplights at Fitness Drive and Peninsula Verde.Consideration should
be given to a "pathway"through Ponte Vista as an alternative to a light at Fitness
Drive.Additional stoplights on Western may cause more traffic congestion,not
less.
Several of the proposed mitigations are subject to approval by other jurisdictions.
The 'DEIR should address the impact on traffic if these mitigations are not
approved and there should be a procedure in place for developing substitute
mitigations.
Consideration should be given to creating a "walking school bus"and a bicycle
path from the road at the back of the development thru Mary Star to Taper.
The DEIR failed to study the Harbor Freeway Channel Street Off-Ramp and the 47
Freeway Channel Street On-Ramp at Miraflores.The impact of increased traffic at this
intersection must be studied and appropriate mitigations proposed.In addition,the full
intersection including Channel and Gaffey must be re-examined.We are suspicious that
the low LOS shown .at that intersection was the result of southbound Gaffey traffic
backed up at Miraflores and therefore not even entering the Channel and Gaffey
intersection.An April 2004 baseline study,for the Port of Los Angeles found this
intersection to be at an OS of E during the PM Peak Hour and the GaffeylMiraflores
intersection to be an LOS ofF in the AM Peak hour and D in the PM Peak Hour.30
The DEIR fails to discuss the impact of the additional traffic on the freeway off-
ramps at Pacific Coast Highway and Anaheim and the resulting backup on the
11 0 freeway.
Mary Star should have vehicular access from both Green Hills Drive and Avenida
Aprenda and the internal roads should be connected at the back of the property.
The DEI R does not appear to account for the impact on traffic of the additional
time required for the approximately 225 additional middle and high school
studen~s pushing the "walk"button to cross Western on their way to and from
school,assuming that the Dodson students walk to school and the High School
30 Port of Los Angeles Baseline Transportation Study,Meyer,Mohaddes Associates.
April 2004
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students take public transportation.This must be added into the traffic study for
that intersection.
It is unclear if the DEIR properly accounts for the fact that most students from the
Eastview Area of Rancho Palos Verdes immediately west of Western are not
attending Crestwood Elementary,Dodson Junior High,or Narbonne High School.
The attendance in the Palos Verdes School District by Eastview residents is
rumored to be over 90%of the local students for the area.Most students from
Dodson and Crestwood are being bused in;likewise Eastview students are
commuting by car and bus via Western Avenue to Dapplegray Elementary,
Miraleste JHS,and Palos Verdes High School.
The parking plan for both residents and visitors is unclear and needs to be
clarified.
The Proposed Project Consumes All of the Available Infrastructure Space
in the Community Plan
What is the point of having a Local Community Plan if it will be impossible to
provide for projected development?As a matter of policy,we question whether a
single project should be entitled to more than a pro rata amount of available
infrastructure usage,in this case roadway space,at the expense of other future
development as contemplated in the Wilmington Harbor City Community Plan
and the San Pedro Community Plan update.
PUBLIC TRANSPORTATION
The DEIR (1-133)states that there are 14 buses per hour serving the project
during the morning peak hour.This is misleading and should be corrected.
There are 4 bus lines that serve the project site,none well.
Metro Bus Line 205 runs from 13th and Gaffey Streets to the Imperial
Wilmington Station at Imperial Highway and Wilmington Avenue in
Watts/Willowbrook Area.The frequency varies from every 20 minutes during the
am peak hour to 1 hour.This bus goes up Western and connects to the Artesia
Transit Station where it is possible to transfer to another bus to go to downtown
Los Angeles.Unfortunately it takes approximately 40 minutes just to get to the
Artesia Transit Station;there is no incentive for future residents to be so
inconvenienced.
Max Line 3 runs from 36th Street and Pacific Ave in San Pedro to LAX Green
Line Station and the Airport Courthouse.It operates northbound to EI Segundo in
the early AM and southbound to San Pedro in the late afternoon.MAX Line 3
does not operate on major holidays or on weekends.It only makes 4 trips in am,
the first at 5:36 and the last at 6:44 am and 4 in pm between the hours of 4:46
and 6:15 pm;basically 2 buses/hour.This is a viable option if your work is in EI
Segundo.
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The remaining two lines are operated by RPV and are primarily designed to
transport RPV students to RPV schools.
PV Transit Orange Line -runs 2 buses along Western from PV Drive N.to First
then to PV Drive East ending at PV High School in am and 3 in pm timed with
school start and stop times.These lines are designed to carry Palos Verdes
students to Palos Verdes schools,and as such are really not useful to the
residents of Ponte Vista
PV Transit Green Line also primarily geared to PV schools and Library.Runs
along Western from First to PV Drive North then west along PV Drive Road
ending at Ridgecrest Elementary School
O.UTILITIES AND SERVICE SYSTEMS
1.WATER
The DEIR states that the project's water usage will have a "less than significant
impact with mitigation"on the area's infrastructure and environment (p.VI-142).
A brief examination of the document raises serious questions about that
conclusion and suggests that it is much too optimistic.
The developer estimates that the 1,135-unit project will use 216 acre-feet per
year of water.(p.1-135).That translates to 170 gallons per day per unit.
However,that figure is far below what experience has shown constitutes actual
use.The United States Environmental Protection Agency has found that the
average American household uses 400 gallons per day.31 In Southern California,
where residents may be more sensitive about conserving fresh water,the Los
Angeles Department of Water and Power (LADWP)reports that the average
single-family residence consumes 359 gallons each dal2
In other words,the developer estimates that Ponte Vista will use less than half
the water that the LADWP finds real households actually use.What is more,the
DEIR offers little explanation -beside mitigation measures such as flush-less
urinals in the project's common areas and low-flow showerheads and "green"
appliances in the residences (p.IV 0-10)-for this very significant discrepancy.
Yet these measures are already widely employed in the community and should
therefore be reflected in the 359-gallon figure the LADWP cites.
The DEIR does make reference to "purple pipe"-that is,plumbing that will
capture and conserve gray water -in the project's units (p.IV 0-11).As
31 "Water Sense,"an EPA Partnership Program at
www.epa.govlWaterSenselWaterUseToday
32 Los Angeles Department of Water and Power,2010 Urban Water Management Plan
[hereinafter referred to as the "UWMP"],p.43.
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commendable as this might be,the report goes on to suggest that the
infrastructure needed to collect and reuse such water is not in place.Moreover,
there is no mention when,if ever,it will be.
Raising further doubts about the reliability of the project's water use estimates is
the DEIR's estimate that the project will add 205,950 gallons per day to the
sewage system.(p.IV 0-25).The report offers no explanation why water usage
-which includes water used for common area irrigation that would not flow into
the sewer lines -would be less than the amounts added to the area's sewer
system.
Overshadowing the DEIR's estimates regarding water usage is the fact that the
LADWP projects it will encounter more difficulty obtaining fresh water supplies in
the future.This is so for several reasons including:1)population pressures
throughout the Southwest,2)increasing drought conditions in the area,3)
climate change and 4)legal restrictions on importing water especially from
Northern California and the Colorado River.(UWMP,p.ES-1).Under such
circumstances,it should be imperative that water providers use considerable
caution in estimating their ability to satisfy the area's future water needs.Indeed,
in an effort to appear to be meeting increased future demand,the LADWP is
already employing the very questionable tact of counting "conservation"as a
water source.According to its own estimates,by 2035,9 percent of the water it
supplies to Southern California will be from "conservation."(UWMP,p.19).
Freshwater is too important a resource to be the subject of guesswork.Under-
estimating its usage and over-estimating its availability can have cataclysmic
effects upon Southern California.Serious economic dislocation and even health
issues for area citizens are just two.Given the discrepancies between the
developer's estimated water use and the EPA and LADWP's experience about
actual levels of consumption and further questions about the LADWP's ability to
supply water in the not-too-distant future,this project's impact on the area's water
infrastructure needs to be re-analyzed.
2.WASTEWATER
The project should be mandated to capture and recycle storm water and grey
water on-site.
3.ENERGY
Solar or alternate energy such as Bloom Energy Servers should be required.
Currently 39%of the City's energy comes from coal.This is being phased out.
The City's lease for the Navajo power plant expires in 2019 and the City's
contract for a coal generated plant in Utah ends in 2027.DWP has indicated that
both plants will be shut down when the leases expire.In order to replace this
loss,DWP is counting on,among other things,an increase from the current 20%
renewable energy and 1%energy efficiency to 33%renewable energy and 10%
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energyefficiency.33 These assumptions mayor may not be accurate.Increased
use of renewable energy is commendable but also costly to consumers.Existing
ratepayers should not have to bear the costs resulting from the increased
demand created by this project.
Another impact that should be analyzed is the increased need for cell
transmitters.No mention of this is made in the DEIR.
PUBLIC HEALTH IMPACTS
Large-scale developments like Ponte Vista have the potential to cause
substantial adverse effects on health of residents,either directly or indirectly.
Therefore,the DEIR must discuss "health and safety problems caused by the
physical changes"(CEQA Guidelines Section 15126.2).If the analysis identifies
significant health impacts,the lead agency must adopt feasible mitigations.
Important determinants of public health include the preservation of natural areas,
air and water quality,community noise,housing and transportation patterns,
access to food resources,public services,and economic well-being.
The DEIR fails to evaluate and disclose potential health impacts resulting
from lack of convenient access to daily needs.Proximity to services promotes
increased walking and biking,reduced daily vehicle trips and miles traveled,
increased possibilities for healthful and meaningful work,and increased
interactions among neighbors.Future residents of Ponte Vista should have
equal access to health resources.The more key public and retail services a
neighborhood has,the greater the chance for residents and workers to walk or
bike to access those services,increasing physical activity,social interactions,
and "eyes on the street".Research has found the presence of a grocery store in
a neighborhood predicts higher fruit and vegetable consumption and a reduced
prevalence of overweight and obesity.Neighborhoods with diverse and mixed
land uses could create proximity between residences,employment,and goods
and services,thereby reducing vehicle trip,s and miles traveled and as a result,
reducing air and noise pollution.This is especially pronounced because of the
difference between the estimates of project completion,i.e.five years or fifteen
years,and the resulting impacts on construction related emissions and impacts.
The DEIR fails to address the following Public Health related questions:
o Does Ponte Vista have all of the key public and retail services that
contribute to neighborhood completeness?
o Does the Ponte Vista plan advance neighborhood completeness?
o What mitigations or project design elements would advance neighborhood
completeness?
SOCIAL IMPACTS
33 LADWP Presentation on Proposed Rates 2012-2014,Mandates and Reliability
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"In much of the rest of the world,rich people live in gated communities and drink
bottled water.That's increasingly the case in Los Angeles where I come from.So
that wealthy people in much of the world are insulated from the consequences of
their actions."
Jared Diamond,author,physiologist,evolutionary biologist and bio geographer.
A neighborhood offers the promise of belonging and call for us to recognize our
interdependence.To belong is to be welcome,even if we are strangers.The
sense of belonging is important because it leads us from conversations about
safety and comfort to our relatedness and willingness to be generous and
hospitable.These elements seldom occur in a culture dominated by isolation,
and it correlate,fear.
The proposed narrow range of housing types forestalls the socioeconomic
robustness that accrues to places with a full spectrum of ages and income.The
proposed gated subdivision intentionally restricts access and emphasizes social
control and security over other community values,thereby shrinking the public
sphere and diminishing collective responsibility for the collective safety of society.
A security gate "can provide a refuge from people who are deviant or unusual...
the vigilance necessary to patrol these borders actually heightens residents'
anxiety and sense of isolation,rather than making them feel safer,"says Setha
Low,author of Behind the Gates,Security,and the Pursuit of Happiness in
Fortress America,The irony is that the residents,particularly kids and seniors
that don't drive,become isolated and trapped behind their own gates --instead of
keeping people out;they shut themselves in.The isolation and loneliness is
increasingly becoming the cause for mental illness.
Gated subdivisions gained popularity with baby boomers.The demographics
have changed.Today,a large cohort of empty nesters and Generation Ys are
increasingly opting out of isolated and gated subdivision to belong in an open,
walkable and urban neighborhood.
The DEIR fails to discuss the social impacts of a limited access exclusive
subdivision.
PROJECT ALTERNATIVES
The DEIR should analyze at least one additional alternative that better addresses
the context of the community and environmental impacts of the project.We
suggest a mixed-use project alternative that includes access to Mary Star,with
true single-family homes on appropriate sized lots,rather than a PUD,work
centers,commercial space,senior friendly facilities,a range of public open
spaces including a 6-acre public park,and a library extension to meet State
Guidelines for library space.
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Additionally,given the poor jobs housing balance,it seems remiss that none of
the alternatives included a light industrial park.This is particularly true in light of
the fact that the original re-use plan for this property would have resulted in
significant job creation.34
ATTACHMENTS
Attachment A Tasca Worst Case Scenario
Attachment B Critical Facilities and Lifeline Systems in the City of Los
Angeles
Attachment C LAUSD School Enrollments for Taper,Narbonne,and
Dodson
34 According to the Draft EIR for the San Pedro Community Plan,the jobs-housing ratio
for San Pedro is 0.44 while it is 1.3 for Los Angeles as a whole.
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City of Lomita comments on the Ponte Vista EIR
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...
CITY COUNCIL
MARGARET ESlRADA
JIMGAZELEY
HENRY SANCHEZ JR.
MICHAEL G.SAVIDAN
BEN TRAINA
December 19,2012
ADMINISTRATION
MICHAEL ROCK
CITY MANAGER
JAN,O 2 20f3
COMMUNITY DEVELOPMENT
Los Angeles Department of City Planning DEPARTMENT
200 N.Spring Street,Room 750
Los Angeles,CA 90012
Attn:Erin Strelich,Planning Assistant (Email-erin.strelich@lacity.org)
Subject:Ponte Vista DEIR -Case No.ENV-2005-4516-EIR (26900 Western Avenue)
To Whom It May Concern:
Thank you for the opportunity to provide comment on the aforementioned project.
The Project proposes a Specific Plan (proposed density is approximately 18 units per acre),
General Plan Amendment,Zone Change,and Vesting Tentative Tract Map for the subdivision,
construction,and operation ofa 1,135-unit residential development.The Project's residential
units would be comprised ofsingle-family,duplex,townhome,flat,and apartment units ranging
in size from 600 to approximately 2,800 square feet,within buildings constructed over and/or
adjacent to residential parking garages.Up to 392 ofthe 1,135 units may be rental units.
The Project would also provide an access road from Western Avenue to the off-site,private
Mary Star ofthe Sea High School.The Project site is approximately 61.5 acres.The Project
would incorporate large internal open space and recreational areas,including an approximately
2.8-acre park,1.3-acre community clubhouse and pool/recreation area and an approximately 0.7-
acre open space and trail network.Additional'recreational amenities would be distributed
throughout the site.The Project would involve the demolition and removal of all existing
improvements on the site,which include 245 vacant residential units,a 2,161-square foot
community center,and a 3,454-square foot retail convenience facility which were constructed in
approximately 1962 by the U.S.Navy for the purpose ofhousing and accommodating personnel
stationed at the Long Beach Naval Shipyard.The site (formerly known as "San Pedro Housing")
was closed in the late 19908.
The City of Lomita opposes the Ponte Vista project based on the following issues:
R-l Zoning Should be Maintained
The site should maintain and be developed under the existing R-l zoning.The approval of a
specific plan would allow densities over 20 units per acre which is more in line with medium-
high density residential.
CITY HALL OFFICES •P.O.BOX 339·24300 NARBONNE AVENUE,LOMITA·CALIFORNIA 90717
(310)325-7110 •FAX (310)325-4024 •www.lomita.com/cityhall
2-141
...
Density
Using the current project description,the project's density was calculated utilizing the entire 61.5
acre site (18 units per gross acre).The net density is actually over 20 units per acre.We still
question the basis for calculating the density in this manner since it will yield a lower gross
acreage per unit over the entire site rather than on only the actual net residential acreage (i.e.,the
areas covered by open space and private streets are being allowed to count as residential land
when determining the units per acre).This can mislead the public into thinking that the proposed
density is lower than what it actually is.Many jurisdictions calculate permissible density based
on the net residential acreage (not the entire site that includes streets and open space).Even at
the lower density level,the proposed project and the various alternatives would still be
requesting amendments to the general plan,zoning and a specific plan request to increase the
permissible density above what is normally allowed under a single family residential zone.This
level of density is not appropriate for the surrounding community and will have substantial
enviro~ental impacts (e.g.,traffic,noise,aesthetics and air quality)that cannot be mitigated
adequately.
Construction-Related Vehicle Trips
Due to the number of residential units and the length of expected construction time,the City of
Lomita has concern with the number of large construction vehicles entering and exiting the site
particularly during grading and demolition activities.A number ofthese vehicles particularly the
off-site load hauling vehicles may need to go through the City of Lomita to get to its final
destination.For this reason,we request that the following 2 proposed mitigation measures be
amended as follows:
NO-6 All construGtion truck traffic shall be restricted to truck routes approved by the City ofLos
Angeles Department ofBuilding and Safety,which shall avoid residential areas and other
sensitive receptors to the extent feasible.Prior to the commencement of construction at the
project site,a meeting shall be held with the surrounding cities (including the City of
Lomita).The purpose of the meeting will be to designate truck routes for off-site load
hauling vehicles and other construction-related vehicles.
NO-7 Two weeks prior to the commencement of construction at the Project Site,notification
shall be provided to the immediate surrounding cities,off-site residential,school,and memorial
park properties that discloses the construction schedule,including the various types of activities
and equipment that would be occurring throughout the duration ofthe construction period.
Transportation and Traffic
The Transportation and Traffic section ofthe DEIR is based on the Traffic Impact Study,Ponte
Vista at San Pedro,City of Los Angeles,California,March 2012 prepared by Linscott,Law &
Greenspan Engineers (LL&G).As stated on page IV.N-61,the project at full build out would
generate 7,382 vehicle trips per day.
The City believes that the reliance ofexisting condition traffic data in the DEIR from 201 0 (more
than 2 years old)may not accurately show the true impact ofthe project on traffic.The increase
in the number of residential units will create a substantial impact on surrounding roadways
2
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..
including Western Avenue.The vehicle trips will also create a negative impact on other
intersections within the City ofLomita along Pacific Coast Highway,Palos Verdes Drive North,
Crenshaw Boulevard,Narbonne Avenue and Lomita Boulevard.A project with a lower density
(7-10 units per acre as opposed to 20+units per acre)would be more appropriate for the subject
site.
Intersection Analysis
The analysis of study intersections within the City of Lomita included the following
intersections:
A.Arlington Avenue (Narbonne Avenue)/Lomita Boulevard (#8)
B..Narbonne AvenueIPacific Coast Highway (#9)
C.Western Avenue!Palos Verdes Drive North (#15)
D.Crenshaw BoulevardlLomita Boulevard (#5)is adjacent to the City border
Page I.V.N-3 (and throughout the document)Map No.9 should be corrected to read Narbonne
Avenue/Lomita Boulevard.Arlington Avenue is located within the City of Torrance north of
240th Street.The City also believes that that the intersection of 262nd Street and Western should
have also been included as one ofthe study intersections.
Table IV.N-6 provides the existing (2010)summary ofthe Vehicle Capacity (V/C)and Level of
Service (LOS)analysis conducted on the City's 4 study intersections.
•The intersection of Crenshaw BI.lLomita Bl.in the PM peak period currently operates at
LOSE.
•The intersection of Narbonne Ave.lLomita Bl.in the PM peak period currently operates
at LOS E.
•The intersection of Western Ave.IPalos Verdes Drive North in the AM and PM peak
period currently operates at LOS E and LOS D respectively.
•The City's general concern is that many of these intersections already operate at below
acceptable standards and any incremental increase from a 1,135 unit development will
make existing conditions that much worse.
•Of particular concern is the intersection of Western Ave.IPalos Verdes Drive North
which under the 2017 analysis would operate at LOS F for both the AM and PM peak
periods.Although the DEIR states that with the proposed mitigation measure (Trans -5)
the impact to this intersection would be less than significant,there is no specific analysis
in the Transportation/Traffic section that analyzes/confirms this.
•The overall impact of this development on Pacific Coast Highway for some intersections
adjacent to and outside of Lomita is problematic.In particular,the intersection of
Crenshaw Bl.IPacific Coast Highway (in the p.m.peak period)and Western
AvenueIPacific Coast Highway (during all study period including Saturdays)will cause
significant residual traffic increases to Pacific Coast Highway within Lomita that will
negatively impact LOS.
•Many of the proposed transportation mitigation measures require improvements in
jurisdictions of neighboring cities and Caltrans.Have these agencies been consulted?
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The City of Lomita has not received any connnunication from the developer,traffic
consultant or environmental consultant on the feasibility of mitigation measure Trans-5
relative to restriping and other modifications proposed at PV Drive North and Western
Avenue.
Should the City of Los Angeles approve the project,the City of Lomita would prefer
Alternative C which proposes 830 residential units at a density of 19.5 units per acre.This
would be a reduction of 305 residential units from the proposed project.
Ifyou have any questions,you may contact Gary Sugano,Assistant City Manager at (310)325-
7110,extension 121.
Sincerely,
Margaret Estrada
Mayor
City ofLomita
CC:City Council
Michael Rock,City Manager
Honorable Joe Buscaino,Council District 15,200N.Spring Street,Room 425,Los
Angeles,CA 90012
Nancy Castiglione,26248 Alta Vista Avenue,LomitalHarbor City,CA 90710
Ruth Herbert,26824 Via Desmonde, Lomita,CA 90717
City ofRancho Palos Verdes,City Council and Joel Rojas,Planning Director
City ofRolling Hills Estates,City Council and David Wahba,Planning Director
4
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City of RHE comments on the Ponte Vista EIR
2-145
FM.l\'K V.ZERUl'iY,,\:-i
Mayor
JUDY MITCHELL
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JOHN C.ADDLEt.lAl'l
COUllcil .\f~mb"
SUSAN SEAMANS
Council Mmlber
STEVEN ZUCKER..'vlAN
COImol Member
nOUGL'\S R.PRICHARD
Cil\,."'Jlmtlg~r
CITY OF
ROLLING HILLS ESTATES
4045 PALOS VERDES DRIVE NORTH •ROLLING HILLS ESTATES.CA 9027-1
TELEPHONE 310.377.1577 FAX 310.377.4468
www.ci.Rolling-HiIIs-Eslates.ca.us
RECEIVED
JAN 072013
January 3,2013 COMMUNITY DEVELOPMENT
DEPARTMENT
Ms.Erin Strelich,Planning Assistant
Los Angeles Department of City Planning
200 N.Spring Street,Room 750
Los Angeles,California 90012
Subject:Ponte Vista DEIR -Case No.ENV-2005-4516-EIR (26900 South
Western Avenue)
Dear Ms.Strelich:
Thank you for the opportunity to comment on the Draft Environmental Impact Report
(DEIR)for the project as referenced above.
The following comments have been prepared in response to the DEIR dated November
2012 for a planned 1,135 unit medium density housing project to be located at 26900
South Western Avenue in the City of Los Angeles.The DEIR concludes that there will be
significant traffic related impacts at the intersection of Crenshaw Boulevard and Palos
Verdes Drive North as the result of this project.After a review of the DEIR and Traffic
Impact Analysis (TIA),the following comments should be addressed:
1.The TIA fails to evaluate the intersection at Palos Verdes Drive North and Rolling
Hills Road.The intersection operates at an LOS=E in the PM peak hour and
would be expected to handle up to 8%inbound and 8%outbound project traffic.
The project distribution would likely include Rolling Hills Road a/5 a north~south
access to Crenshaw Boulevard and Pacific Coast Highway.Therefore,this
intersection must be analyzed using City of LA and Rolling Hills Estates impact
criteria for all scenarios.This intersection should be added to all tables and figures
in the TIA and DEIR.
2.Palos Verdes Drive North typically operates at or over capacity in the AM and PM
peaks between Palos Verdes Drive North and Hawthorne Boulevard.Therefore,a
street segment analysis is needed on this roadway pursuant to other segments
conducted in the TIA.
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3.The City of Rolling Hills Estates strongly objects to the proposed TRANS-2
mitigation measure at Crenshaw Boulevard and Palos Verdes Drive North (PVDN).
A northbound right turn overlap phase would adversely impact local neighborhood
access east of the intersection due to the very limited gaps available on Palos
Verdes Drive North.The existing "No Right Turn on Red"restriction for
northbound right turn movements has been in place for over 10 years as a means
to provide sufficient gaps for motorists on side streets to enter/exit PVDN.
Removal of this restriction would severely congest the single east bound lane.The
City recommends that the Response to DEIR Comments provide an alternate
mitigation measure,such as a third southbound lane on Crenshaw Boulevard.
Table 1-1 and all related figures in the TIA and DEIR should be revised accordingly.
4.Figure IV.N-3 of the DEIR is incorrectly shows the lane configuration for the
intersections instead of the AM Existing Traffic Volumes.
5.The increase in traffic on roadways within Rolling Hills Estates due to the project
would result in an incremental increase in the demand for public safety resources
such as Fire and Police services.
The City supports the findings and recommendations made by the City of Lomita in their
response to comments letter dated December 19,2012 for this project.In particular,the
recommended mitigation measures need to be acceptable by the jurisdiction in which
they are proposed,and all costs associated with the measures must be paid by the
applicant,including all design review,local and regional permits and fees,staff and/or
professional consultant time,and construction inspection.In addition,the City of Los
Angeles must take the lead in informing the adjacent cities of the pending project
activities and related mitigations as well as soliciting their comments prior to public
noticing.
The City of RollingHil.ls Estates would much appreciate if your traffic studies are revised
to address the above-mentioned issues.Should you have any questions or need
additional information,please do not hesitate to contact me at City Hall at (310)377-
1577,extension 103,or by email atdavidw@cLrolling-hills-estates.ca.us.
~~
David Wahba
Planning Director
CC:1.Rt!S.9it¥:Qpuncil
2.~§J:ty.i6f:R:P.V;i RH and Lomita City Manager/City Council
Ponle.visla.d",r Jtr2 .doc
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Sierra Club comments on the Ponte Vista EIR
2-148
January 7,2013
Erin Strelich,Planning Assistant
Los Angeles Department of City Planning
200 N.Spring Street,Room 750
Los Angeles,CA90012
Fax:(213)978-1343
erin.strelich@lacity.org
Re:Draft Environmental Impact Report (DEIR)Ponte Vista Project,No.Env-2005-4516-EIR
Dear Ms.Strelich:
The Sierra Club finds the above-referenced Draft EIR to be seriously flawed and recommends
that the DEIR for the Ponte Vista project not be approved.
The Sierra Club .is opposed to the removal of the OS-1XL designation for Open Space on the
project site.
The Sierra Club is also opposed to any increase in the existing R1-1XL housing density on the
project site.
The DEIR purports to be using an environmentally sound principle of concentrating
development in urban centers as a justification to significantly increase the zoning density of the
Ponte Vista project.While Sierra Club policy does support compact development within
appropriate existing urban centers as a planning tool to avoid urban sprawl that paves over
natural areas,Sierra Club policy cannot be used to justify approval of an increase in
development density in an area already characterized by highly congested and often grid locked
roadways as is the case along the Western Avenue corridor in San Pedro and Rancho Palos
Verdes.
Barring the establishment of public transportation options that would be likely to reduce the
traffic volume along this corridor,the Sierra Club cannot support an increase in zoning density in
this area and therefore opposes the proposed Ponte Vista Project of 1,135 units.For the same
reason,the Club opposes Project Alternatives C (830 units)and D (1,135 units).
The Sierra Club also is opposed to Alternative B (385 units)because it would not comply with
the existing OS-1 XL Open Space designation.
The Conceptual Site Plan for Alternative B shows a stair-stepped diagonal configuration,
presumably located on the earthquake setback zone,which is labeled as "open space".This
P.O Box 2464 •Palos Verdes Peninsula,California 90274
@ Printed on Recycled Paper
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area is not as large as the currently zoned OS-1XL area,nor is it in a location contiguous with
the DFSP native habitat area.Therefore the location shown is of far less potential habitat value
than the existing zoned area.
Should the applicant wish to relocate the OS-1XL area on the project site,a preferred
alternative would be to restore 9.1 acres including the remnant riparian area in the southwest
corner of the site.
While the area is not in its natural state and may currently have limited native flora and fauna,it
has the potential to be restored with riparian and other native vegetation that may attract the PV
blue butterfly and the California Gnatcatcher,particularly given the parcel's proximity to the
Defense Fuel Supply Point.The DFSP provides a relatively small patch of habitat for the
threatened Palos Verdes blue butterfly,a species rediscovered there in 1994 after it was
thought to be extinct.Expanding the butterfly's host plant restoration into the Project area would
enhance the potential to grow this species population thereby improving the possibility for long-
term success.
Given the project proposal and Alternatives provided,the Sierra Club can only support
Alternative A-no development-which offers community and environmental benefits that the
Sierra Club does support.
Sincerely,
It?t J~
Alfred Sattler
Chair
Palos Verdes-South Bay Regional Group
P.O Box 2464 •Palos Verdes Peninsula,California 90274
@ Printed on Recycled Paper
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Comments from AI and Barbara Sattler on the Ponte Vista EIR
2-151
Erin Strelich,Planning Assistant
Los Angeles Department of City Planning
200 N.Spring Street,Room 750
Los Angeles,CA 90012
Erin.strelich@lacity.org
January 7,2013
Re:DEIR Ponte Vista Project,No.Env-2005-4516-EIR
Dear Ms.Strelich,
Thank you for the opportunity to review the Draft Environmental Impact Report (DEIR)for the proposed Ponte Vista
project.We have noted a number of inadequacies in the DEIR,and thus we request that the DEIR be substantially revised
and not be approved.Our concerns are as follows:
Impediments to Public Comment
The digital copy of the DEIR (Page 1-5)presents an incorrect email address for the submission of comments.If public
comments were sent to that address,it is quite possible that they would not have been received in a timely manner,and
the submitter might not possibly be aware of a problem until after the submission deadline.
Although we appreciate having a public comment period of 60 days,the scheduling of the public comment period over the
winter holidays is unfortunate.That scheduling may have had the effect of minimizing public comment to some extent.
Inherent Bias in Review Document
The DEIR seems to be biased towards maximizing the number of housing units in order to maximize the Developer's profits
regardless of impacts to the surrounding community.Impacts to the neighboring communities,particularly to the Eastview
neighborhood in Rancho Palos Verdes,seem to be underplayed or even ignored by the DEIR.One wonders if impacts to
Eastview,which is just across the street from the proposed project,are being disregarded primarily because it is outside of
the jurisdiction of the city of Los Angeles.Should that be the case,we would like to remind you that impacts to the
Eastview neighborhood will also affect each and every family that has a child attending Dodson Middle School.That LAUSD
school is located entirely within Eastview.
Inadequate Representation of Cumulative Impacts
We were not able to find any mention in the DEIR of the recently constructed condominium development,Seaport Village,
which is located south of and directly adjacent to the project site.It is our understanding that because that project has
failed to sell many of the new condominium units,they were allowed to convert units to rentals.We do not know whether
the development is currently fully occupied.
The DEIR's failure to address this adjacent development is significant because:
1.It demonstrates a lack of market demand for condominiums in the area.The proposed project design ignores
that evidence,and instead proposes to further saturate the condominium construction in the area.
2.If the proposed project condominiums also prove to be undersold and are likewise converted to rental units,
then the Environmental Review must appropriately analyze that possibility.The DEIR does not address that
potential change in usage.
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3.If the Seaport Village is not yet fully occupied,the traffic study for the current project cannot be considered
valid unless it considers cumulative impacts including the eventual full occupation of that existing
development.
Inadequate Analysis of Traffic Impacts
As non-professionals we find it difficult to interpret the traffic data provided.We do not fully understand what is actually
being identified and measured by the studies and whether such measurements are adequate and reliable enough to be
used as the sole basis for traffic evaluations.As neighbors however,we are aware of the existing local traffic impacts from
Western Avenue and we do not see all of those impacts addressed by the DEIR.
For instance,the DEIR selectively studies a few sample intersections along Western Avenue itself.It does not acknowledge
or address the frequent gridlock situations that occur just off of Western on the various feeder streets in the adjacent
neighborhoods even though increased traffic on Western will impact adjacent neighborhoods as well.
The DEIR also fails to anticipate spontaneous driver shortcuts during congested situations.One situation we can imagine
with the proposed increased focus of traffic to the intersection of Avenida Aprenda and Western Avenue is southbound
drivers cutting over to the small neighborhood street parallel to Western Avenue (labeled as Tarrasa Drive in the Thomas
Guides and as Western Avenue on Google maps)just before Avenida Aprenda in hopes of a shortcu~.This will result in
them having to either make a left hand turn onto Avenida Aprenda to return to the main artery of Western -causing
congestion at the intersection of Tarrasa and Avenida Aprenda,or will result in them seeking alternative routes within the
neighborhood.
In regard to school traffic,we have noted that the traffic pattern to and from Dodson Middle School seems to shift in
location somewhat from year to year.We do not know whether this might be due to scheduling changes,bus routing
changes,or parents changing routes in response to congestion patterns.The pattern of change however leads us to
wonder how reliable some of the intersection studies might be.Furthermore,the intersection studies seem to only count
the number of cars traveling through an intersection at a given time.Do such counts really reveal gridlock situations?
Emergencies
The DEIR acknowledges the receipt of prior concerns regarding traffic impediments in an emergency situation.However the
DEIR analysis in this regard is completely inadequate -it offers only a reference to the designation of evacuation routes by
the cities of LA and RPV and then glibly concludes that since the se:ction of Western Avenue between Summerland and
Palos Verdes Drive North is not identified as an evacuation route by either city,that we residents of the Eastview
neighborhood should just stay where we are.Apparently,according to this DEIR,evacuation routes are only for selected
areas other than ours.(Remember,our neighborhood includes Dodson Middle School!)It seems that in this regard,the
DEIR has actually identified a failure of these combined evacuation plans -but rather than so stating,the DEIR rationalizes
those inadequate plans as the complete context for their analysis and does not bother to analyze any further.
The DEIR down plays the likelihood of a single extreme case scenario of evacuation from the port and states that
emergencies are much more likely to occur at smaller localized settings.However,it then completely ignores the potential
impacts of congested traffic on emergency access and response times.We often hear sirens of emergency vehicles on
Western.The sirens are often accompanied by much horn blowing as the emergency vehicles struggle to get through the
current traffic conditions.This situation will only become worse if traffic is increased to any degree.
Furthermore,the DEIR does not address the fact that Western Avenue is the ONLY ingress/egress corridor for the Eastview
neighborhood and Dodson Middle School.There are NO alternate routes.Therefore any increase in traffic congestion on
Western Avenue,particularly in the vicinity of the proposed project,will significantly impact emergency response time and
ease of evacuation to and from Eastview and Dodson.
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Of course,the proposed project configuration would also create an obstructive bottleneck in emergencies at Western
Avenue for both the Ponte Vista project itself and the surrounding community.
Extension of Avenida Aprenda east of Western Avenue
The DEIR characterizes the proposed extension of Avenida Aprenda from Western Avenue to Mary Star of the Sea High
School as a "benefit to the community."In actuality,such an extension has several problematic aspects.
It is our impression that the intersection of Avenida Aprenda and Western already has a rather high incidence of accidents.
Adding another direction of approach to that intersection will likely increase the number of accidents there because of the
need for numerous left hand turns from all directions.
Furthermore,the extension of Avenida Aprenda as proposed would simultaneously focus heavy school commute traffic for
both Dodson Middle School and Mary Star of the Sea High School to a single intersection at Avenida Aprenda and Western
Avenue.How can that possibly be considered a good idea?Dodson traffic alone is enough to cause gridlock.Add new high
school age drivers having to make left hand turns into a congested intersection in the context of drivers frustrated by traffic
delays and trying to get to school or work on time and you have a recipe for increased numbers of traffic accidents.
For these reasons,the extension of Avenida Aprenda seems to be a detriment rather than a benefit to the Eastview
neighborhood.Such an extension might potentially provide some limited additional east-west ingress/egress.However,
usage for such a purpose seems to be restricted to limited school access according to the DEIR.
Underrepresentation of eXisting traffic backups
The DEIR dismisses concerns about traffic backups from funeral processions to Green Hills Cemetery as "mere minutes."In
actuality,these backups occur fairly frequently and the delays are often such that drivers turn off their engines to wait,
sometimes for a considerable amount of time.For larger processions when the funeral procession is northbound and thus
making a left turn into the cemetery,the,southbound traffic backs up almost to Palos Verdes Drive North.This can be a
dangerous situation for the last cars in line when additional cars turn onto Western from PV North at speed and because of
the hill contour,do not see the backup until the last minute.Of course,traffic also backs up in the northbound direction at
the same time,for comparable distances.The DEIR's assertion that these processions generally do not occur at peak
commute hours does not mean that the problem is insignificant or that adding additional cars to the mix will not exacerbate
the existing problem.
The DEIR also fails to address traffic backups which occur in the adjacent neighborhoods on feeder streets to and from
Western Avenue.
Additional traffic problems
The DEIR fails to examine potential traffic problems such as that which impacted the Eastview neighborhood several years
ago when a huge sinkhole developed on Western Avenue.At that time traffic from Western was diverted into the Eastview
neighborhood,particularly to Pontevedra Drive,which is a narrow winding residential street roughly parallel to Western.
For several weeks,that small residential street was subject to the entirety of southbound Western Avenue traffic including
multi-axle delivery trucks,buses,construction vehicles and commuter autos.We vividly recall the frustration of the
Sheriff's Department who were called out after an auto accident during school commute hours at the intersection of
Pontevedra Drive and Avenida Aprenda.The neighborhood streets were not designed to accommodate that intensity of
traffic.Adding even more vehicles to the mix cannot be characterized as a responsible plan.
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Inadequacy of Mitigation for Traffic Impacts
The traffic mitigation measures offered by the DEIR seemly to consist only of a few dedicated turn lanes and the addition of
a few signal lights.While these measures might provide some accommodations for cross traffic,they do nothing to address
overall traffic congestion or emergency access.
At the same time,the DEIR fails to consider any possible options for mass transit mitigations to traffic impacts.For
example,a mitigation measure could obligate the Developer for the life of the project to pay for doubling the frequency of
the Metro #205 bus,which presently runs along Western Avenue.
The DEIR fails to acknowledge that at some point an eXisting road infrastructure reaches capacity and that it is not
reasonable to think that the traffic load can be indefinitely increased to a single artery using that existing infrastructure.
Denial of the significance of impacts or band aid mitigation measures do not sufficiently or honestly address the problem.
Project Density
The DEIR fails to transparently discuss current zoning for the project site in the early discussion of conditions and setting.It
is only after delving into Volume 2 of the DEIR that the reader discovers that not only is the majority of the site zoned R-l,
but that the northern portion of the site is zoned for Open Space as OS-lXL.
The DEIR seems to be biased in favor of maximizing the number of housing units and of weighing that "value"more strongly
than the project's impacts to the quality of life of the surrounding community.
Increased density is not necessarily "smart growth".Without appropriate supporting infrastructure and efficient design
that takes the context of the surrounding community into account,density is neither smart nor "green".Transitioning to
"smart growth"within the vast sprawl of southern California is quite a challenge.Merely accumulating pockets of great
density within the existing infrastructure is not a reasonable methodology for achieving a more efficient and livable urban
design.
In orderfor a densely populated residential area to be added to the project site to be a "smart"design,there would need to
be a functional network of alternative travel corridors to serve not only the project,but the surrounding neighborhoods.
Such a network of corridors does not currently exist,nor does such a network seem to be locally feasible in the foreseeable
future given the constraints of the surrounding properties.
Perhaps if public transportation options were improved considera,bly the volume of private automobiles could be reduced
to a level that would improve traffic flow.However,such a change has not yet occurred,nor is it currently planned.
Therefore that scenario cannot be used to justify increased population density at the project site.
The existing road infrastructure was designed to serve zoning consistent with the existing R-l zoning of the project site.
Since the road system was built,more and more large projects have been implemented in the area.These cumulative
increases in density have resulted in a road system that is already over-burdened and congested.It makes no sense to
continue to increase density beyond the infrastructure's designed capacity.Merely adding some turn out lanes and stop
lights does not mitigate the congestion and gridlock.
Impacts to the Character of the surrounding Community
The DEIR understates the impacts of adding multiple additional multi-story buildings to the project site.The fact that some
such buildings were recently constructed adjacent to the proposed project site does not make a continued proliferation of
buildings of such massive scale acceptable.Whether or not there is a "view"to consider,a blockade of large buildings
surrounding the public corridor and facing existing neighborhoods will certainly degrade the feel and character of the
surrounding community.
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Developer Profits vs.Community Quality of Life
The Applicant's desire to maximize his financial profits from the project should not be a consideration of the DEIR.The
business of the DEIR is to evaluate project impacts to the environment and the surrounding community.
We do not believe the DEIR's argument that under the R-l designation the Applicant can only build high end homes on the
site.That is merely the Applicant's argument designed to maximize profits.We suspect that it would be quite feasible to
build moderate-valued homes under the R-l designation and that such homes would be as desirable for families there as
they are in the Eastview neighborhood across the street.
Greenhouse Gas Emission Reduction and Energy Conservation
The DEIR does not consider the opportunities to reduce emissions of carbon dioxide by installing rooftop solar photovoltaic
and rooftop solar hot water heating systems.
The DEIR does not consider opportunities for energy conservation by using LEOs for parking lot lighting,and indeed for
interior lighting throughout the project.
Water conservation
The DEIR does not discuss opportunities for water conservation using greywater for landscape irrigation.
Natural Space and Habitat Issues
The DEIR seems to be trying to conceal the fact that approximately nine acres of the project site is currently zoned as Open
Space,OS-lXL.The DEIR does not address the proposed project's lack of compliance with that zoning designation.
There are two areas on the property of potential natural habitat value.One is the northernmost section abutting the DFSP
natural area.The second is the remnant riparian area in the southwest corner of the property.
The biological reports included in the Appendices of the DEIR indicate that northern section of the property has good
potential for restoration to a natural biological habitat because of its proximity to the DFSP natural area where restoration
efforts have been made for the Palos Verdes Blue Butterfly and the California Gnatcatcher.Those biological reports also
indicate that although the riparian area has been quite degraded by re-contouring the drainage and lining it with concrete
and asphalt,it could be re-vegetated with appropriate native plants and restored to a more naturalistic configuration.
Even in its currently weedy and degraded state,the open space on the project site is valuable to us as neighbors because it
provides an opportunity to be able to look out onto the landscape and visualize what the original natural state of our
surroundings might have been.It is interesting to consider how the remnant drainage might have originally connected from
George F Canyon above Palos Verdes Drive East extending out to what is now Harbor Lake,and how that might relate to the
geological contours of our neighborhood.We enjoy seeing hawks and other common wildlife in the area,although it is
disturbing to see the goats which are employed for weed control to keep the weedy vegetation under cotrol on the project
property stripping the bark from the native willows while they leave some of the worst weedy grasses untouched.
Certainly from our neighborhood,we would much prefer to see,and to be able to visit a natural area that has been
restored to its original native habitat function than yet another blockade of enormous three and four story bUildings.
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Concerns Regarding Alternative B
We had hoped that Alternative B would be the best option because it does comply with the currently zoned R-1 density.
However the design option for that Alternative as presented in the DEIR is at best only a grudging concession to R-1
limitations with a simplistic grid configuration designed only to maximize the number of dwelling units within the space
without any other considerations,including complying with the OS-1XL zoning on the site.The design proffered for
Alternative B is so bare bones that it is hard to imagine how it could possibly appeal to the upscale market it is supposedly
designed to attract.Instead,it seems to be intended to be unappealing so as to force consideration to the more lucrative
densely populated project Alternatives.
We believe that it would be quite possible to design a Project Alternative that meets the population densities capped by the
current R-1 zoning and that incorporates the existing OS-1 zoning to include some natural habitat designation.We
acknowledge that a more concentrated housing configuration than single family homes might be workable for that site,but
the total number of occupants should not exceed the existing R-1 zoning.
A truly optim'al design Alternative for the project site would cluster the allowable housing,retain and restore natural
habitat on site,and provide additional outdoor recreational amenities to the project.We believe that such a design would
be more consistent with "smart"growth and would have more market appeal than any of the Alternatives currently
proposed in this DEIR.
Conclusion
The DEIR for the Ponte Vista project does not adequately consider or mitigate the proposed project's impacts to the
surrounding community.Impacts to traffic congestion,and safety and to emergency ingress and egress in the area would
be particularly severe and have not been adequately addressed by the DEIR or mitigated by the project plan.The DEIR also
fails to adequately address the project's lack of compliance with the current R-1 and OS-1X land use designations.
Additionally,the inclusion of an incorrect address for the submission of public comments is a serious flaw.A public notice of
that error and a substantial extension of public comment time should be provided to address that issue.
Although we appreciate the staff recommendation of the somewhat downsized Alternative C,given the existing context of
the site,that Alternativeis not downsized enough.Frankly,we find it difficult to even comfortably anticipate the increased
impacts of 385 units with Alternative B.We are opposed to Alternative B because of its poor design and failure to
adequately comply with the existing Open Space zoning designatiqn.
Therefore we prefer Alternative A,the No Project Alternative,especially if the land were restored to an appropriate native
habitat.
Sincerely,
Barbara and Alfred Sattler
Rancho Palos Verdes Residents
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Comments from Janet Gunter on the Ponte Vista EIR
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Janet Schaaf-Gunter
PO Box 642 -San Pedro,CA 90733
Email-Arriane5@aol.com -Phone (310)251-7075
January 6,2013
Ms.Erin Strelich,Planning Assistant
Los Angeles Department of City Planning
200 North Spring Street,Room 750
Los Angeles,CA 90012
Dear Ms.Strelich:
RE:DEIR No.ENV-2005-4516-EIR -State Clearing House
#2010101082
Ponte Vista Development -San Pedro,CA
Public Comments on Sections related to Seismic/Geologic Conditions &
Hazardous Materials
My comments on this DEIR revolve around the continued denial of extraordinary risk
exposure to residents for miles due to the Ultra Hazardous "Rancho Liquid Petroleum
Gas"storage site located less within 12 to %of a mile from this new proposed housing
site.The Ponte Vista DEIR fails to address this undeniable risk.
Seismic/Geologic Comments
It is ironic to me that we are sending these comments to your office.The City of Los
Angeles Planning Department itself has designated the area of the hazardous Rancho
LPG tank storage as an "Earthquake Rupture Zone".Yet,we find the City of LA
advancing this Ponte Vista housing project as ifthere is no issue of safety to residents
present at all.Attached is the appropriate map out of the LA City Planning Department
(SAFETYLT)that identifies the problematic geologic situation.It is important to note
that the area of these tanks (located approximately %to %mile from the proposed 1100+
homes)is where there is a convergence of several earthquake faults,the largest one being
the Palos Verdes Fault (mag.7.3 potential).The DEIR fails to recognize either the LA
City Planning Department's designation of the "Earthquake Rupture Zone"that contains
these volatile tanks,or the fact that there an intersection of faults in that area that cause
increased seismic concern for the location.The Rancho site is also clearly identified in
LA Building and Safety documents as being located in a "Liquefaction Area",a
"Landslide Area",and a "Methane Zone".These are all matters that should have
provoked a prudent attitude by the City of LA toward public safety due to the hazardous
massive volume and extremely volatile nature of liquefied petroleum gas being stored on
the adjacent premises.This condition presents a very vulnerable safety environment for
all residents both existing and proposed.
The latest geology report commissioned by the EPA dated December 20th,2012 declares
and grades the soil of the Rancho LPG facility as "Class D-Stiff Soil".The following
information has been pulled from an Indiana website where they utilized information
from the National Earthquake Hazards Reduction Program (NEHRA)that establishes this
grade of soil as "Liquefaction Area".
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Short description of Class 0 Stiff Soil:
Liquefaction Potential of Surficial Materials in Indiana,2011 (1:500,000)-Shows shows highly
generalized categories (low,moderate,and high)of liquefaction potential,based on soil classes of
the National Earthquake Hazards Reduction Program (NEHRP).This data set provides a digital
coverage of the predicted response of surficial geologic materials in Indiana to liquefaction induced
by earthquakes.It is intended to be used by Indiana Department of Homeland Security,emergency
planners,and responders on the state and local level as a general reference gUide to identify
potential areas of evaluated risks of liquefaction.Low liquefaction potential includes NEHRP Soil
Class B (consisting of rock:sandstone,limestone,shale).Moderate liquefaction potential includes
NEHRP Soil Class C (hard or stiff soil,or gravel)and part of NEHRP Soil Class D (stiff soil,stiff clay,
and some gravel).High Iiguefaction potential includes parts of NEHRP Soil Class 0 (stiff
soil,stiff clay,and some gravel),and all of NEHRP Soil Class E (soft soil and soft to medium
clay)and F (lake and river deposits of sand and mud).The following is excerpted from Indiana
Geological Survey Miscellaneous Map 81:'liguefaction is a common ground-failure hazard
associated with earthguakes.It is defined as the sudden and temporary loss of strength
of a water-saturated sediment.This could result in the structural failure of buildings,
bridges,and other structures.'
Tags:
IndianaMap,IGS,Indiana,geoscienticInformation,geology,surficial geology,quaternary,
stratigraphy,earthquake,ground shaking,seismic,soil classification,liquefaction,shear-wave
velocity,National Earthquake Hazard Reductions Program (NEHRP)
Credits:
National Earthquake Hazard Reductions Program (NEHRP),Federal Emergency Management Agency
(FEMA),Indiana Department of Homeland Security (IDHS),Indiana Geological Survey Miscellaneous
Map 81 (2011)
FGDC Metadata:
Seismic Earthquake Liquefaction Potential.html
Download:Download a zip file that contains an ESRI Shape File and associated metadata:
Seismic Earthquake Liquefaction Potential.zip
Magnifying the geologic inappropriateness of installing yet more housing to an area
already exposed to elevated risk,is the antiquated infrastructure and sub-standard tank
construction of the two massive 13 Million Gallon Rancho LPG tanks built to a seismic
sub-standard of only5.5-6.0 over 40 years ago!These tanks were constructed in 1973
without benefit of LA Building and Safety permits which were only "certified"after
their construction and while in use.The proximity of the magnitude 7.3 potential PV
Fault coupled with the confirmation of the soil as "liquefaction area"at this facility
makes any opinion of earthquake safety at this site completely reckless and illogical.
The issue of risk to residents and the Port of LA from the Petrolane/Amerigas/and
currently Rancho (Plains All American Pipeline)LPG facility has been raised for literally
decades.Both the Port of LA and the LA City Council have gone on record in
acknowledging safety concerns and a lack of wisdom in ever locating the facility at its
current site.In spite of that,the City of LA continues to ignore the threat.Our residents
and homeowners are "forced"now to comment on the irresponsible concept ofthe Ponte
Vista housing project in order to protect others.This housing project plans to introduce
yet another 2,000+more potential victims to a certain highly increased exposure to harm.
Also attached to this letter is the recent geology report,from Geotechnologies Inc.,
referenced above.This EPA hired consultant does not perform their own comprehensive
exploration nor physical inspection of geologic conditions at the site.The company
simply relies on prior existing information provided by the LPG company's own
consultants and other sources of available information.
2-160
However,"Geotechnologies"did visit the location for a sight inspection and cited on
page 17 of that report that "the analysis critical for the evaluation ofthe seismic hazards
at the site were not addressed ...",page 15,"borings and soil samples near the tanks
were never done (particularly as it relates to Lateral Spreading)".Also,specifically
noted is a potential clear current violation described on page 9 relating to a storm drain
below the Rancho tanks,"no device exists to contain liquid butane (or other released
substances)from entering the drain in the event ofdischarge by the tanks".While there
are a number of deficiencies obvious in their report due to the limitation oftheir analysis,
Geotechnologies Inc.should be credited for both recognizing and emphasizing the above
facts and noting that other critical sites for geologic testing,sampling and study
necessary to ensure safety have never been analyzed.The report urges the study of these
areas and points out other vulnerabilities of the soils at the storage facility.These
deficiencies all point to significant safety problems.
Attached you will find graphics along with maps from Cal Trans and the USGS with a
Google Earth picture.This helps to show the discrepancy in the location of the Palos
Verdes Fault...and how it can be manipulated slightly to whatever result might benefit
someone with a an interest in deflecting the truth.According to the "Rancho consultant's
report",the earthquake fault falls directly under new homes.Who is right or wrong here?
It is important to remember that an earthquake fault is not a simple line in the
ground ...but,the fault's width itself can,at times,range in size up to 1 mile!The truth is
that whatever the case,the entire area of the tanks and vicinity (as seen on the graphics)is
either directly on top of,or slightly to one side or the other,of the Palos Verdes Fault.
Regardless of the tanks exact location upon the fault or along side of it,the structures,
tanks,rail cars and whatever happens to be on site during the minutes of significant
earthquake,will be incredibly impacted due to landslide and liquefaction of soil.Given
the volatility ofliquefied petroleum gas,that translates into a cataclysmic event capable
of killing thousands.
An issue completely ignored in the DEIR for Ponte Vista is the Tsunami threat.Due to
the close proximity of the LA harbor channel,this area just a few hundred yards away
from the harbor,is ripe for the effects of a tsunami.There are two nearby underwater
landslide areas that could produce a significant tsunami.Maps will show the area of
North Gaffey,just south of Westmont Drive,as being in the designated "Tsunami
Inundation Zone."Just how a tsunami wave is estimated to stop at that point is difficult
to ascertain since there is no significant rise in elevation that would prevent invasion of
waters.Approximately 1 ~years ago,(we have photos)there was a sign posted within
200 ft.of the LPG facility that read,"You are now leaving a tsunami zone".That sign
has mysteriously disappeared.The sign base remained until a Rail warning sign was
recently posted in the exact same spot after a Rancho LPG rail car collided with a truck in
March 2012 miraculously escaping rupture.Apparently,now,it is acknowledged as a
potential "rail accident zone."
Also,it appears that the "storm drain"that leads to the directly into the LA Harbor,
located right below the LPG tanks,has not been taken into "tsunami consideration".That
storm drain would drive the force of any tsunami wave in the harbor directly up
Westmont Drive and all along Gaffey Street.So,there are some critical questions to be
raised about effects from tsunami upon local residents including any residents of the
proposed Ponte Vista housing development.The Ponte Vista EIR never responds in
any way to a tsunami potential.
2-161
There have been numerous requests by LA City officials and neighboring Rancho Palos
Verdes requesting the insurance information of Rancho LPG /Plains All American
Pipeline covering this facility.This information is crucial in receiving assurance that
there is adequate coverage ofliability of harm to affected areas from an event stemming
from Rancho LPG.Those requests,thus far,have been denied.
The following is documented in a seismic analysis provided to the EPA in May of2012
by "Strong Motions"regarding earthquake insurance at Rancho LPG;
"Plains LPG has provided results of a "desktop"analysis of the earthquake loss.According to
this analysis,the "probable maximum loss"is $8.4 million and the "maximum forseeable loss"is
$18.6 million.These estimates were based on 250-year MRP ground shaking at the site.These
estimates include ONL Y the replacement value of the structures (tanks);they do NOT include
losses from:1)business interruption;2)spilled contents;3)environmental clean -up;4)fires;5)
explosions;and 6)third party liability.Plains LPG maintains earthquake insurance up to $60
million.It has not been demonstrated that the facility is insured up to the maximum possible
earthquake loss."
It is painfully clear that regardless ofthe precarious nature of the geology of this site and
the resulting devastation potential that exists,this Rancho LPG facility (a subsidiary and
LLC of Plains All American Pipeline)carries absolutely no insurance that would cover
the losses to the public,the City ofLA and (in particular response to this Ponte Vista
EIR)the future residents ofthe Ponte Vista Housing project.The developers of Ponte
Vista should be active participants along with our community in ensuring safety and
protecting their own investment from the risks presented by Rancho LPG.
Hazardous Materials Comments
The Ponte Vista DEIRconsultant,Mary O'Neil at CAJA Environmental,gives great
credibility to the risk analysis from Rancho LPG facility's consultant "Quest".
Interestingly,there appears to be no real investigative work related to the discrepancies
between various consultants in regard to true risk attributed to a catastrophe at Rancho or
a resulting "domino effect"disaster due to the many available fuel resources in the area.
This lack of consideration does not bode well for the potential residents of the Ponte
Vista housing project.
The issue ofa "domino effect"ofcascading events stemming from Rancho LPG,Conoco
Phillips refinery and the Naval Fuel Depot (along with the multitude ofmarine oil
terminals at the Port ofLos Angeles)has been identified as a matter ofgrave concern by
Professor Bob Bea from Berkeley University.Professor Bea is the renown expert hired
by the State &US government to identify the "why"ofour greatest recent us
catastrophes.From Columbia's fiery end,the collapse ofthe levees during Katrina,the
Gulfoil disaster and the devastating explosion ofSan Bruno;all have warranted the
expert investigation by Professor Bob Bea.Professor Bea has warned ofthe potential of
extreme danger due to the existence ofthis Rancho LPG facility and its sheer massive
volume ofLPG,the facility's conditions and its close proximity to other hazardous
facilities.How many times do we have a valued opinion such as Bea 's PRIOR to a
catastrophe??!!!!What more will it take to move us to take responsible action to protect
the innocent?
2-162
In the Ponte Vista EIR analysis,Ms.O'Neil (at CAJA)also underscored confidence in
the EPA solicited report by Dr.Daniel Crowl that buttressed the risk analysis perfonned
by Rancho's own consultant "Quest"pronouncing a very minimal zone of worst case
impact.Crowl's findings were used to give greater credibility to the Quest Risk analysis
over the "Cornerstone Technology"analysis commissioned by our local San Pedro
Neighborhood Council.The Cornerstone Report gave a worst case blast radius of impact
from at 6.8 miles.Dr.Crowl,a "chemical engineer"and instructor at Michigan Tech
University presented his report on "Michigan Tech"letterhead without authorization of
the University.The University has clearly stated that the report is Crowl's own
independent analysis having nothing to do with the University and without their
pennission.Crowl's scope of expertise is extremely limited in his analysis of the Rancho
situation.His basis for analysis was established entirely on the data provided by others.
Crowl never once visited the site.Crowl dismisses the validity of the Cornerstone
reporting and endorses the report ofthe Rancho LPG consultant.The quality of Crowl's
report can be gleaned by his assessment that the walls ofthe "containment basin"at the
base of the two large butane tanks will be left entirely unscathed and intact by an
earthquake strong enough to rupture a 13 million gallon tank sitting on liquefaction and
lands fide soil.A curious conclusion at best.But,this example handily illustrates
Crowl's lack of seismic and engineering education.It also reflects the
deficiency of study that Ms.O'Neil (CAJA Environmental)perfonned in her own
investigation of the hazard potential for this Ponte Vista EIR.
The Ponte Vista consultant blithe fully ignores the flagrant discrepancy in the worst case
scenario results between the findings of Rancho LPG and its abutting neighbor Conoco
Phillips refinery.The Conoco Phillips refinery,provides a worst case scenario radius of
impact from their own butane storage (representing afraction of the volume held at
Rancho)at 2.3 miles.This impact would certainly include the residential area of Ponte
Vista.Rancho LPG has disclosed a far less radius of impact from worst case scenario
with an end point of .~mile.This result is accepted despite Rancho having over 4 times
the volume of butane at the Rancho facility!The question becomes why the Ponte Vista
consultant found "no problem"with this assessment?Certainly,it would be more
beneficial to the developer to ignore this serious discrepancy.
There continues to be an ignorance of the properties ofliquefied petroleum gas and how
it differs from other gasses.In all risk analyses 'ofRancho LPG and its predecessors,
there is a complete disconnect of understanding when it comes to the value of a
"containment basin"for leaking butane gas.The leaking gas is treated as though it will
remain in its refrigerated and "cooled"tank liquid condition allowing it to be "contained"
by its "one"existing containment basin.That is a ridiculous conclusion since when the
liquid gas is exposed to ambient air temperature,it will vaporize and expand over 200
times its volume.Less than 1%of the LPG tanks capacity could possibly be "contained"!
The gas will seek the lowest levels,(is heavier than air)and will hug the ground until
finding any ignition source whatsoever.The spark from a passing car engine could easily
ignite the highly flammable gas in an instant.The resulting explosion from this would be
massive.Fires from LPG bum hotter than other fuels at over 3500 degrees,igniting and
gasifying all other flammables for MILES!This gasification would create a hazardous
cloud with a far greater zone of threat than can be imagined.
2-163
In closing,it is patently immoral to encourage the growth of housing in an area that is
already recognized for its elevated jeopardy to disaster.Whether the potential disaster is
caused by earthquake,terrorism,antiquated infrastructure or human error,the
consequences to human life and property are far too great to escape good conscience.
Mitigation that would allow the introduction of this Ponte Vista housing is the removal of
the threat causing the increased risk exposure itself.Nothing else justifies gambling with
the lives of innocent people.Nothing.
Most sincerely,
Janet Schaaf-Gunter
2-164
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2-169
Connie Rutter
879 Upland Ave.
San Pedro,Ca.90732
July 25,2012
Dear Connie,
Enclosed Tank Photos showing worrysome distortions,depressions and
bulges.
A po~ential 9-11 (No.2)is only 45 days away.An ordinary rifle shot
(Not even Armor Piercing)aimed at 40 year old highly stressed Weld
Joints may produce "The Epic Catastrophe"the extremists dream of
How can any terrorist resist "this invitation".So obvious ....Homeland
Security surely must know this.I feel that Rancho LP Tanks should be shut
down Immediately.I live 0.9 miles away.On 9-11 my family will be in
another city.
Questions:
Should a Welding or Structural Engineer be consulted r.e.current condition
Of tank welds r.e.warp,misalignments,load bearing distortions producing
new and hidden stresses?
Iftank capacity was reduced by 75%would the 3 mile danger zone be
reduced,and allow the facility to still function?
As an independent Contractor for 25 years serving petroleum Engineers
in the design of pipelines and off shore platfonns,many times I was
Asked,"Why would you put your family at risk living so close to
LP tanks "?(resident of S,P.since March 10,193 3 Earthquake).
Every Petrol.Engineer I've met knows this.
Hoping that these "Man on the street observations"will aid and encourage
you to continue your fine efforts to relocate these tanks,I am,
Jack and Rita Brown (neighbors of Jodie)
Email:jpb1933@sbcglobal.net
2-170
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2-171
2-172
Ponte Vista e-mail regarding 830-unit proposal
2-173
The 830-Unit Plan:The Right Fit for San Pedro Page 1 of2
Hi,just a reminder that you're receiving this email because you have expressed an interest in Ponte Vista.
Don't forget to add info@pontevista.com to your address book so we'll be sure to land in your inbox!
You may unsubscribe if you no longer wish to receive our emails.
The 830"'Unit Plan:
forSan Pedro
Dear Ponte Vista Friend,
!You may have already heard the news:
..
!The Ponte Vista project team recently announced that the:
:developer,iStar Financial,plans to seek entitlements for '.
:the reduced-density alternative studied in the DEIR.This
:plan includes 208 single-family homes covering nearly
:50%of the Ponte Vista site,as well as town homes,and
:single-and multi-level condominiums.
1
:Following in-depth conversations with community
:leadership,our neighbors,and the Council office,it is
:clear that the 830-unit plan is preferred by many in the
i community.
:The reduced-density alternative meets the project's
i overall goal:to design and build a project that exceeds
!the community's expectations,and bring high-quality new!
:homes to San Pedro.
j In the coming weeks,we will be updating the Ponte Vista
1 website with details of the 830-unit plan.We will also be
http://campaign.r20.constantcontact.com/render?1lr=109govcab&v=00 1bHw_LhcjpQouuh...1/28/20132-174
The 830-Unit Plan:The Right Fit for San Pedro Page 2 of2
hosting informational briefings at the Ponte Vista trailer.
Please email us info@pontevista.com or call us at
310.241.0699 and let us know if you would like to be
invited to future events.And,if you have friends who
may be interested in learning more about the new Ponte
Vista,please forward this email to them!
We look forward to hearing from you!
Best Wishes,
The Ponte Vista Outreach Team
Forward email
This email wassenttokitf@rpv.combyinfo@pontevista.com I
Update ProfilelEmail Address I Instant removal with SafeUnsubscribe™I Privacy Policy.
Ponte Vista I P.O.Box 989 I San Pedro I CA I 90733
http://campaign.r20.constantcontact.com/render?1lr=109govcab&v=00 1bHw_LhcjpQouuh...1/28/20132-175
Daily Breeze and PV News articles regarding Ponte Vista project
2-176
http://www.dailybreeze.com/news/ci_22374267/developers-will-Iimit-san-pedros-ponte-vista-830
Developers will limit San Pedro's Ponte Vista to 830 homes
By Donna Littlejohn,Staff Writer Daily Breeze
Posted:DailyBreeze.com
The developers of San Pedro's proposed Ponte Vista housing project announced Monday that they will limit the
project to 830 homes.
The announcement didn't come as a big surprise to community members,who had anticipated that the 830 number
-listed as an alternative project in the draft ErR -would be the most likely to win city approval.
"It's no surprise,"sai~Diana Nave,president of the Northwest San Pedro Neighborhood Council."Certainly 830 is
better than 1,135 (homes)."
Either way,though,the neighborhood council still has many concerns about the long-delayed project,she said.
The draft report currently under study by city planners focused on the more ambitious version ofthe proposed
project, calling for 1,135 homes.
But developers have said that the 830-unit version would be economically viable.
"The new plan for Ponte Vista will better reflect community desires,"said Dennis Cavallari,project manager for
the property owner,iStar,in a written news release emailed Monday about the scaled back version."The
community and Council member Joe Buscaino's office overwhelmingly prefer the 830-unit alternative."
Criticism of the project -to be built on
61.5 acres at 26900 S.Western Av~.-has long centered on density effects,especially in traffic.
Those concerns largely remain,Nave said,even with the 830-unit proposal.
"A lot of our concerns still apply,"she said."We'd like to see some modifications,"including a further reduction in
density,she said.
Other neighborhood council concerns include the lack of on-site amenities that could reduce traffic and the
elimination of dedicated senior housing and public park space.
There also are concerns about the number of rental units included,she said.
Cavallari said the lower-number project is a good fit for the community.
"The 830-unit alternative is the right project for the site,with the right mixture of home types,"Cavallari said.
Under different developers,Ponte Vista originally was proposed as a 2,300-home project in 2005.
The comment period closed Jan.7 on the draft environmental report,which now will undergo further review by
Los Angeles city planners.
donna.littlejohn@dailybreeze.com
Page 1 of!16/0112013 08:35 AM2-177
Print Version Page 1 of1
I Print Page]
Ponte Vista developers seek smaller project
Thursday,January 17,2013 12:00 PM PST
The public has spoken and developers have listened.
iStar Financial,owners of the vacant U.S.Navy housing site on Western Avenue in San Pedro,announced
Monday it has decided to limit the number of residential units it's seeking to build at the site,which borders
Rancho Palos Verdes.Based on public comments from residents and community leaders in both RPV and San
Pedro on the draft environmental impact report for the proposed Ponte Vista residential community,iStar
has decided to seek entitlements for its smaller alternative plan of 830 units.
"The new plan for Ponte Vista will better reflect community desires,"said Dennis Cavallari,project manager
for iStar."The community and [Los Angeles City]Council member Joe Buscaino's office overwhelmingly
prefer the 830-unit alternative."
The DEIR for the Ponte Vista project was released for public review and comment in November 2012.iStar
asked for 1,135 units of mixed housing types,which was scaled-down version from the original prQPosed
project.Prior to iStar taking over ownership of the property and project in 2010,developers had proposed
2,300 units,offering 575 of those units as affordable senior housing.iStar nixed the senior housing and
decreased the number of units to 1,135,devoted to single-family homes,single-and multilevel
condominiums,townhomes and luxury apartments.
The 830-unit plan was an alternative offered in the DEIR.It also includes single-family homes,townhomes,
and single-and multilevel condominiums.
"The 830-unit alternative is the right project for the site,with the right mixture of home types,"Cavallari
said."There will be opportunities for every type of resident in Ponte Vista -seniors,professionals,families
and empty-nesters."
iStar also proposed improvements to Western Avenue and traffic improvements for about 20 nearby
intersections.With the smaller plan,project developers say Ponte Vista's impact on traffic will be less than
originally studied.However,iStar will still contribute to upgrades for Western Avenue and improvements at
16 intersections.
"We understand that traffic remains a top community concern,"said David Shender,a traffic engineer with .
Linscott,Law and Greenspan."As a result of Ponte Vista,I anticipate the 16 intersection improvements Will,
in some cases,improve traffic flow beyond the needs of the project."
The U.S.Navy closed the housing site in 1997.More than 200 vacant duplexes sit empty and deteriorating.
Planners have tried to get the city of Los Angeles to approve various plans for a residential development at
the site but San Pedro and RPV residents have contested the plans over the years,saying the Ponte Vista
project is too big and would increase traffic and overcrowding.
-Mary Scott
mscott@pvnews.com
http://www.pvnews.com/articles/2013/01/17/10cal_news/news3.prt 1/21/20132-178
RHE Planning Commission Resolution No.PA-01-07
for Brickwalk,LLC project
2-179
PLANNING COMMISSION
CITY OF ROLLING HILLS ESl1'ATES
LOS ANGELES COUNTY,CALIFORNIA
RESOLUTION NO.PA·01·07
A RESOLUTION OF THf;PLANNING COMMISSION OF THE CITY OF ROLLING HILLS
ESTATES,RECOMMENDING APPROVAL OF VESTING TENTATIVE TRACT MAP NO.
67553,A CONDITIONAL USE PERMIT (CUP),A PRECISE PLAN OF DESIGN (PPD),A
VARIANCE TO EXCEED THE MAXIMUM PERMITTED BUILDING HEIGHT,A VARIANCE TO
PERMIT A SMALLER SETBACK THAN REQUIRED BY CODE,A VARIANCE TO PERMIT
FEWER PARKING SPACES THAN REQUIRED BY CODE/SHARED PARKING AGREEMENT,
A GRADING APPLICATION,AND AN ENVIRONMENTAL I,M PACT REPORT,FINDINGS AND
STATEMENT OF OVERRIDING CONSIDERATIONS UNDER THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT (CEQA)FOR A MIXED·USE DEVELOPMENT INCLUDING
148 CONDOMINIUM/TOWNHOME UNITS AND 14,200 SQUARE FEET OF COMMERCIAL
SPACE ON 10.42·ACRES.APPLICANT:MR.STEPHEN JORDAN FOR BRICKWALK,LLC
(MR.GEORGE DANESHGAR);LOCATION:655·683 DEEP VALLEY DRIVEl924·950 INDIAN
PEAK ROAD.
WHEREAS,Mr.Stephen Jordan filed an application with the Planning Department
requesting Vesting Tentative Tract Map 1\10.67553,a Conditional Use Permit (CUP)for a
mixed·use development including 148 condominium/townhome units and 14,200 square feet of
commercial space in the Commercial General (C-G)/Mixed-Use Overlay Zone,a Precise Plan
of Design (PPD),a Variance to exceed the maximum permitted bUilding height,a Variance to
permit a smaller setback than required by Code,a Variance to permit fewer parking spaces
than required by Code/shared parking agreement,and a Grading application on 10.42-acres as
required by Chapters 16.04, 16.12,17.30,17.37, 17.58,17.66,and 17.68 of the Rolling Hills
Estates Municipal Code;and
WHEREAS,project plans are attached as Exhibit A to this Resolution;and
WHEREAS,an Initial Study was prepared by the City pursuant to the requirements of the
California Environmental Quality Act (CEQA)and it was found that the project could potentially
have a significant impact on the environment and,thus,and Environmental Impact Report (EIR)
Was prepared;and
WHEREAS,in accordance with Section 65033 of the Government Code,the public,
abutting cities,affected agencies and districts were notified of the availability of the Draft EIR and
were given an opportunity to review and comment;and
WHEREAS,the Planning Department responded in writing to said comments in the
Response to Comments document;and
WHEREAS,upon giving the required notice the Planning Commission conducted a Public
Hearing on the 4th day of September,2012,15 th day of October,2012,and the 3'd day of
December,2012.All interested parties were given full opportunity to be heard and to present
evidence;and.
WHEREAS,as a result of studies and investigations made by the Planning Commission
and on its behalf,revealed that the facts as set forth in the Initial Study,Draft EIR,and those
discussed during the Public Hearing resulted in the following findings:
That the granting of this application will not be materially detrimental to the public welfare
or injurious to property and improvements in the Zoning District and neighborhood in which
the property is located because the proposed improvements will be regulated via a
Conditional Use Permit [Section 17.30.020(0)(25)]of the Rolling Hills Estates Municipal
Code)and a Precise Plan of Design [Section 17.37.020(C)],to rnitigate project impacts.
Resolution No.PA-01-07
December 17,2012
2-180
That the granting of this application will not be contrary to the objectives of the ~~neral
Plan because the development is consistent with the General Plan's Goals and PolicIes to
provide mixed-use housing in the City's commercial district.
That as provided under the California Environmental Quality Act (CEQA),the Vesting
Tentative Tract Map will result in a significant and unavoidable short-term noise impact
during construction as discussed in the Draft EIR,and Findings/A Statement of Overriding
Considerations will be considered for approval by the City Council as included as Exhibit C
to the Resolution.
Variance Findings
That there are exceptional or extraordinary circumstances or conditions applicable to the
property involved,or to its intended use which do not apply generally to other property in
the same zoning district and neighborhood because the lot is irregular in shape and has a
steep slope which was subject to a former landslide along Crenshaw Boulevardllndian
Peak Road,and because the diminished front setback and reduction in required project
parking avoid further grading in the hillside to the rear of the project site.
That such Variance is necessary for the preservation and enjoyment of a substantial
property right of the applicant,which right is possessed by other property owners under
like conditions in the same zoning district and neighborhood because other properties on
the south side of Deep Valley Drive are greater than the maximum 44'height limit,the
steep hillside condition limits the buildable area and opportunities for parking facilities
not experienced on other properties,and the zero front setback proposed can be
supported due to the slope to condition to minimize the need for grading.
That the granting of the Variance will not be materially detrimental to the public welfare of
injurious to property and improveme,nts in the zoning district and neighborhood in which
the property is located because the proposed project would prOVide a material public
benefit by repairing an unstable landslide condition,because the proposed building height
would not block views of any surrounding properties,because the architectural tower
element would visually enhance project architecture,because the proposed zero front
setback would enhance the interaction between the b.uilding and the street,and because
the shared parking agreement would ensure that adequate parking is available for uses
onsite.
That the granting of the Variance will not be contrary to the objectives of the master plan
because both the Zoning Code and General Plan provide for Mixed-Use developments for
the subject property,because the proposed project density is slightly lower than permitted
by the General Plan and Zoning Code,and because granting of Variances for height,to
permit a lesser setback,and to permit fewer parking spaces than required by Code/shared
parking agreement in support of a Mixed-Use project would be in conformance with the
objectives of applicable plans.
That the granting of the Variance will not authorize a use or activity which is not
otherwise expressly authorized by the zone regulations governing the parcel of property
because the use and activities of the proposed building as well as the parking of
vehicles are provided for in the governing zone regulations,and the granting of the
Variances would not authorize a use or activity which is not expressly authorized.
WHEREAS,Chapter 16.04 of the Rolling Hilis Estates Municipal Code requires the
Planning Commission to act in an advisory capacity to the City Council,which body shall approve,
conditionally approve,or deny such application for a subdivision map;and
WHEREAS,while the Planning Commission believes Variance findings as stated in this
Resolution can be made based upon an assumption that requested project density is required to
provide funds for repair of the landslide area inherent to the site,the Planning Commission did not
review financial evidence in support of this assumption and recommends that the City Council
consider this evidence in evaluating requested project Variances;and
WHEREAS, Ordinance No.646 requires findings for mixed-use and residential projects
to ensure that a project:1)Provides for a general public benefit (above and beyond the
Resolution No.PA-01-07
December 17,2012 2
2-181
payment of any City adopted development fees)including,but not limited to,public art,or semi-
public plazas or open space integrated into private development projects;2)Provides for a
specific benefit to a segment of the community including,but not limited to,facilities for teens or
children,a community recreational or meeting room,or a senior center;3)Maintains or
enhances the economic viability of the underlying commercial property and/or Commercial-
General or Commercial-Limited designation in general;4)Maintains the ability of the City to
proVide adequate land area and lease space for the provision of goods and services for the
community;and 5)Assists the City in meeting requirements of its Regional Housing Needs
Assessment (RHNA)especially with regard to affordable housing;and
WHEREAS,in response to findings required by Ordinance No.646,the Planning
C()mmission believes that the project provides a general public benefit by incorporating a public
plaza into the podium building and enhances the economic viability of the underlying
commercial property/maintains the provision of good and services by maintaining the Brickwalk
development and adding new commercial space;and
WHEREAS,the Planning Commission recommends that the City Council discuss with
the applicant how a specific benefit to a segment of the community may be provided by the
project and how the project may assist the City with meeting its Regional Housing Needs
Assessment especially with regard to affordable housing;and
WHEREAS,the Planning Commission is concerned about the completion of project
grading once commenced and expressly intends that Conditions of Approval No.37 and 38 will
provide for bonds in an amount necessary for the City to complete grading,retaining walls and
the proposed tie-back system if necessary;and
NOW,THEREFORE,the Planning Commission of the City of Rolling Hills Estates does
hereby resolve as follows:
SECTION 1.That the foregoing facts constitute conditions necessary to recommend
approval of Vesting Tentative Tract Map No.67553,a Conditional Use Permit (CUP)for a
mixed-use development including 148 condominium/town home units and 14,200 square feet of
commercial space in the Commercial General (C-G)/Mixed-Use Overlay Zone,a Precise Plan
of Design (PPD),a Variance to exceed the maximum permitted building height,a Variance to
permit a smaller setback than required by Code,a Variance to permit fewer parking spaces
than required by Code/shared parking agreement,a Grading application,and certification of an
Environmental Impact Report.Therefore,the Planning Commission recommends approval of PA-
01~07 to the City Council.Unless otherwise stated,these conditions must be met at all times by
the applicant,otherwise,this approval becomes null and void.
1.That the development shall be located and constructed as shown on Exhibit A.
2.That any substantial modification including,but not limited to,exterior building elevations,
parking lot design,and landscaping,shall receive prior approval of the Planning
Commission;minor modifications may be approved by the City Manager.
3.That all applicable requirements of the State,County,City and other Governmental
entities,must be met.
4.That prior to issuance of Building Permits or Grading Permits,a Zone Clearance shall be
obtained from the Planning Department.
5.That the applicant shall comply with all applicable NPDES (National Pollutant Discharge
Elimination Systems)requirements.
6.That all proposed new utilities shall be placed underground to the nearest off-site facility,
per Municipal Code Section 15.04.080.
7.The applicant shall defend,hold harmless and indemnify at his or her own expense the
City;its agents,officers and employees,from any claim,action,or proceeding,to attack,
set aside,void or annul the approval granted in this resolution and shall reimburse the
City,its agents,officers and employees for any damages,court costs and attorneys'fees
incurred as a result of such action.The City at its sole discretion may participate in the
Resolution No.PA-01-07
December 17,2012 3
2-182
defense of any such action but such participation shall not relieve applicant of his or her
obligation under this condition.
8.The applicant shall erect a six-foot high security fence around the construction area(s)
of the property to the satisfaction of the Planning Director and Building Official.Prior to
construction,a construction sign(s)as provided by the City shall be conspicuously
posted on the fence adjacent to the street of the project and/or adjacent to all entrances
of the project.The site shall be maintained in a clean sanitary manner at all times
during and after construction.
9.That all roof-mounted equipment shall be screened from view.Any screening features
shall be architecturally integrated with the proposed structure and shown on Exhibit A,as
approved by the Planning Commission.
10.That,prior to the issuance of Zone Clearance,a method of control to prevent dust and
windblown earth problems,and the route for trucking soil,shall be submitted to,and
approved by,the City Manager.
11.That permits are required for all work within public rights-of-way,and shall be subject to
review and approval of the City Manager.
12.That all handicapped spaces are to be posted and painted to meet the State Handicapped
Parking Requirements.
13.That the applicant shall comply with the City's Noise Ordinance,both during the
construction phase of the development and during the operation of the complex after
construction is completed,excepted that the site noise is expected to exceed permitted
thresholds during the short-term construction phase of the project as described in the Draft
Environmental Impact Report.
14.That trash enclosures shall be architecturally compatible with the proposed construction as
approved by tile Planning Commission and shown in Exhibit A,incorporated herein by
reference.The trash receptacle and debris shall be contained and maintained within the
enclosed area.
15.That,prior to issuance of a Zone Clearance,the·applicant shall:(A)submit a Landscaping
and Irrigation Plan prepared by a licensed Landscape Architect for the subject site;and (B)
shall have that Plan reviewed by the Park and Activities Commission;and (C)shall have
the landscaping and irrigation installed to the satisfaction of the City Manager prior to
occupancy.
16.That the Landscape Plan shall comply with Chapter 17.59 (Landscaping and Irrigation)of
the Municipal Code for water efficiency.
17.That the development shall not produce odors which would exceed State or County
Sanitation Standards or odors determined to be offensive by the County Health
Department..
18.That all project Mitigation Measures,as identified in the attached Mitigation Monitoring
Program (Exflibit B),shall be completed to the satisfaction of the responsible
DepartmenVagency within the designated time frames.
19.That this project is classified as a large project under Ordinance No.668.As such,it
shall be subject to a one-year time period (commencing upon the effective date of
project approval),in which the entire project must be submitted for plan check review
with the Department of Building and Safety,with two six month time extensions
maximum allowed to be granted by the Planning Commission.
20.Prior to issuance of a grading or building permit,the project applicant shall provide a
Construction Management Plan inclusive of a haul route plan for review and approval by
the City Engineer.The haul route plan'shall identify routes for vehicles accessing the
project site,staging areas,and worker parking areas.In addition,the plan shall include
Resolution No.PA-01-07
December 17,2012 4
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a photo log of pavement along the haul route to ascertain any damage at the end of
construction.
21.That prior to demolition,the applicant shall submit a traffic control plan to minimize traffic
disruption,subject to review and approval by the City of Rolling Hills Estates;said plan
shall include,but not limited to,the use of flag persons.
22.All construction activity shall be limited to between the hours of 7:00 A.M.and 5:00 P.M.
Monday through Friday,and 9:00 A.M.and 5:00 P.M.on Saturday.No work shall be
permitted on Sundays or holidays (New Years Day,Memorial Day,Independence Day,
Labor Day,Thanksgiving Day and Christmas Day).
23.No queuing of trucks or arrival of construction materials and/or workers to the
construction site shall be permitted outside the permitted construction hours and days.
24.Contractor shall ensure that construction equipment is fitted with modern sound-
reduction equipment.
25.That the applicant shall,to the extent feasible or as required by law,salvage and recycle
demolition materials.
26.That the sign location,size,materials and colors,etc.,for all signing of the site,shall be
approved under a Master Sign Plan to be approved by the Planning Commission prior to
issuing any Sign Permits.
27.That no storage containers,merchandise or delivery trucks shall be permitted in any off-
street parking lots.
28.Prior to issuance of building permits,the project applicant shall be reqUired to pay its fair
share of applicable fees for Park and Recreation Facility,Library,Traffic and General
Plan purposes,as a condition of the discretionary land use approvals granted by the
City.
29.The applicant shall submit a copy of the CC&Rs to the City Manager for review and
approval prior to the recordation of the Final Map specifying the following requirements:
a.The City of Rolling Hills Estates shall be named asa third party beneficiary.Any
proposed amendments to the CC&Rs must first receive approval of the City of
Rolling Hills Estates.
b.The Homeowners Association shall be responsible for the maintenance of all
landscaping located within commonly owned aneas.as shown on Exhibit A.
c.No recreational vehicles shall be parked on-site.
d.A provision shall be included for trash pick-up and disposal for common areas and
private residences.
e.The Homeowners Association shall maintain any natural drainage courses
traversing the property.
f.That all residential units of the development shall be restricted to home-occupation
uses,as specified in the Municipal Code.
g.That the Homeowner's Association will adopt the City'S Municipal Code Section
10.24.090 restricting all night on-street of vehicles,Section 10.24.130 restricting
the on-street parking of vehicles for more than seventy-two hours,and other codes
as set forth in the California Vehicle Code as they may relate to private streets.
Resolution No.PA-01-07
December 17,2012 5
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30.That the applicant shall ensure that lighting on the project site shall be directed only onto
the property where the light source is located.No lighting shall be permitted which
results in the direct illumination of other properties.Prior to issuance of building permits,
a lighting plan in conformance with Chapter 17.42 of the City's Municipal Code shall be
reviewed and approved by the Planning Director.
31.That all improvements hereafter constructed or installed on land which is the subject of
this approval shall be located substantially as shown on Exhibit A and constructed of
materials indicated on the materials and color board,and/or as required under the
Municipal Code and/or as required in these conditions.
32.That all applicable requirements of the State,County,City,and other governmental
entities shall be met,and that prior to commencing any work on lands divided by the
application and prior to applying for a building or grading permit,a zone clearance shall be
obtained from the Planning Department.
33.That the Tentative Tract Map shall be valid for two years from the date of adoption of the
City Council resolution of approval.Requests for extensions shall be made prior to the
expiration of this map and shall require approval by ther City Council.
34.That any substantial modification including,but not limited to,exterior building elevations,
site plan design,and landscaping,shall receive prior approval of the Planning
Commission;minor modifications may be approved by the Planning Director.
35.That in the event of one or more violations of these conditions,the City Manager shall
have enforcement capability to remedy such violations and/or revoke said approvals.
36.That the City Council shall review and approve the final map prior to filing with the County
Recorder's Office.
37.That the applicant shall submit plans for approval by the City Manager for all
improvements reqUired herein and further that the applicant will provide proof of
completion of all improvements to City standards prior to recordation of the final map or,in
those cases where permitted by the City Council,post labor,material,and performance
bonds,or other appropriate forms of security in an amount to be determined by the City
Manager in a form approved by the City Attorney.Improvements which are bonded must
be installed within one year of recordation unless a time extension is granted by the City
Council.
38.That the amount of the performance bond posted by the applicant prior to the
commencement of grading shall be sufficient to ensure that completion of all grading
activities including,but not limited to,the proposed retaining wall and tie-back system can
be completed by the City should grading activities by the applicant cease prior to
completion.
39.That prior to submitting the final map to the City Manager for his examination pursuant to
Section 66450 of the Government Code,the applicant shall obtain clearances from all
affected Departments and Divisions,including a clearance from the City Engineer,for the
following mapping items:including but not limited to mathematical accuracy,survey
analysis,and correctness of certificates and signatures.
40.That prior to final map approval,the applicant shall pay any required fees for Department
of Fish and Game review.
41.Details shown on the tentative map are not necessarily approved.Any details,which
are inconsistent with requirements of ordinances,general conditions of approval,or City
Engineer's policies,must be specifically approved in the final map or improvement plan
approvals.
42.A final tract map prepared by,or under the direction of a Registered Civil Engineer
authorized to practice land surveying,or a Licensed Land Surveyor,must be processed
through the City Engineer's office prior to being filed with the County Recorder.
Resolution No.PA-01-07
December 17,2012 6
2-185
43.A preliminary subdivision guarantee is required showing all fee interest holders and
encumbrances.An updated title report shall be provided before the final tract map is
released for filing with the County Recorder.
44.Monumentation of tract map boundaries,street centerline and lot boundaries is required
for a map based on a field survey.
45.Final tract map shall be filed with the County Recorder and one (1)mylar copy of filed
map shall be submitted to the City Engineer's office Wior to issuance of building permits.
46.Approval for filing of this land division is contingent upon approval of plans and
specifications mentioned in these conditions of approval.If the improvements are not
installed prior to the filing of this division,the developer must submit an Undertaking
Agreement and a Faithful Performance and Labor and Materials Bond in the amount
estimated by the City Engineer guaranteeing the installation of the improvements.
47.The City reserves the right to impose any new plan .check and/or permit fees approved
by City Council subsequent to tentative approval of this map.
.48.Prior to the recordation of the final map,grading and drainage plans must be approved
to provide for contributory drainage from adjoining properties as approved by the City
Engineer,including dedication of the necessary easements.
49.A grading and drainage plan must provide for each lot haVing an independent drainage
system to the public street,to a public drainage facility,or by means of an approved
drainage easement.
50.The project proposes to disturb nearly ten acres of land.A State Construction Activity
permit is required prior to the start of clearing and grubbing,demolition or grading
activities on the site.The grading plan shall show the State issued WDID number for
purposes of identification.Prior to the issuance of the grading permit a copy of the
project SWPPP shaH be reviewed by the City Engineer to determine that adequate
provisions have been made for erosion and sediment control.
51.The proposed drainage system shall be constructed and connected to Deep Valley
Drive.Developer shall provide a detailed hydrology and hydraulic analysis of the
projects impact on Deep Valley Drive.If the City Engineer and the City Director of
Public Works determines that Deep Valley Drive does not have capacity for the storm
runoff increase a Storm Drain extension will be required.The Developer shall process
the storm drain plans through Los Angeles County Department of Public Works as a
Miscellaneous Transfer Drain.
52.Retaining walls proposed in conjundion with this development plan are up to 3D-feet in
height.Plans for these walls shall be reviewed and approved by a Structural Engineer,
a Geotechnical Engineer and a Geologist and approved prior to the issuance of grading
permits for this project.The current building code requires that retaining walls of the
heights proposed must be designed to resist loading from earthquake loading.
53.Tiebacks for support of the proposed retaining walls shall not extend under any
adjoining public streets without prior approval of the City of Rancho Palos Verdes.The
applicant shall present a permit issued by the City of Rancho Palos Verdes prior to the
commencement of construction of tieback walls below Indian Peak and Crenshaw
Boulevard.
54.Prior to the excavation and construction of the proposed tie back walls and pile
supported walls,inclinometers shall be installed along the edge of Indian Peak Road
and Crenshaw Boulevard to monitor the stability of the existing roads and slope.
Resolution No.PA-01-07
December 17,2012 7
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55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
The project proposes to export 48,200 cubic yards of material from the property as part
of this development.The Director of Public Works shall approve a haul route for the
trucks entering and leaving the site.The haul route shall define all public streets
proposed for use,and shall define any safety issues for trucks operating in the vicinity of
Schools or other public places.The applicant shall place advance-warning signs to
warn the public of trucks entering the highways at the point of ingress and egress to the
site.
Prior to the commencement of grading,the applicant and staff shall attend a pre-grade
meeting to discuss items including,but not limited to,grading activities,neighbor
notification,contact persons,and safety measures.
The applicant shall post bonds to ensure that the public streets in the immediate Vicinity
of the project are not damaged by the haul operation.The Director of Public Works
shall establish the amount of tile bond,and it shall be posted prior to the issuance of the
grading permit.
Developer shall prepare a covenant,subject to City Engineer's approval,for ingress and
egress to serve multiple lots.
Plans for street improvements and street light layout for the proposed private street shall
be submitted to the City Engineer and must be approved prior to filing the final map.
Damaged curb,gutter and sidewalk along Indian Peak,Crenshaw and Deep Valley shall
be reconstructed.
Developer shall construct a wheelchair ramp per City standards at the corner of
Crenshaw and Indian Peak.
Private street shall be paved with 4-inch thick asphalt over crushed aggregate base
(CAB).The CAB section shall be determined by soils report submitted to the City by the
developer.
The entire frontage of street on Deep Valley Drive shall be slurry sealed for half of the
street width.Due to the AC stretch cracking on Indian Peak Road,the Applicant shall
overlay Indian Peak Road to the satisfaction of the Public Works Department of the City
of Rancho Palos Verdes.
Developer shall install residential type streetlights on private streets at spacing as
required for public streets.
Developer shall install street name sign at the corner of the proposed Private Street and
Deep Valley Drive and also at the Private Street and Indian Peak Road.
Approval of this land division is contingent upon the installation of local main line public
sewer within the proposed private street.
The developer shall send a print of the sewer plans to the City and to the Los Angeles
.county Department of Public Works for review.Approval must be assured prior to filing
this land division map.
The developer shall consult the City Engineer to determine the sewer location and
design requirements.A sewer capacity study shali be prepared to assure that down
stream sewers will not exceed capacity with the addition of the sewage from this project
to the Sanitation District trunk sewer that collects the sewage from this area.
Easements may be required and shall be subject to review by the City Engineer to
determine the final locations and requirements.
Power,telephone and cable television service shall be underground.
Resolution No.PA-01-07
December 17,2012 8
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71.Any utilities that are in conflict with the development shall be relocated at the developer's
expense.
72.All lots shall be served by adequately sized water system facilities,which shall include
fire hydrants of the size,type and location as determined by the Fire Chief.
73.The water mains shall be of sufficient size to accommodate the total domestic and fire
flow required for the land division.Domestic flows required are to be determined by the
City Engineer.Fire flows required are to be determined by the Fire Chief.
74.Plans and specifications for the water system facilities shall be submitted for approval to
the water company serving this land division.The subdivider shall submit an agreement
and other evidence,satisfactory to the City Engineer,indicating that the subdivider has
entered into a contract with the servicing water purveyor guaranteeing payment and
installation of the water improvements.
75.Prior to the filing of the final map,there shall also be filed with the City Engineer,a
statement from the water purveyor indicating subdivider compliance with the Fire Chief's
fire flow requirements.
76.This project is a priority project as defined in the City's MS4 permit.The applicant shall
prepare a Water Quality Management Plan prior to the submittal of the grading plan for
check.The WQMP shall establish the pollutants of concern;the BMP's for treatment of
these pollutants and shall establish the maintenance obligation for the selected BMP's.
The plan shall include the local TMDLs applicable to the Lake Machado TMDLs and
receiving waters as well as pollutants normally expected on residential projects.The
2012 Los Angeles County MS4 permit will be effective prior to the approval of this
project.The City of Rolling Hills Estates shall determine if this project qualifies to be
designed under the 2001 MS4 permit or if it must be designed to meet the 2012 MS4
permit.The provisions of Part VI.D.7.b.iLd should b.e used to determine applicability of
the 2012 MS4 permit.The ConSUlting Geotechnical Engineer shall evaluate the use of
infiltration as a treatment BMP and shall make a determination is it is an option for this
project.
77.Due to the large volume of export from this site the applicant shall maintain a street
sweeper at the site to remove tracked soil from all public streets during the export
operations.The sweeper shall be required on a daily basis with the Director of Public
Works establishing the level of sweeping required.
78.A Construct.ion Waste recycling plan will be required for this project prior to the issuance
of grading or building permits for this project.The City of Rolling Hills Estates Waste
Management coordinator shall approve the plan.
79.The traffic circle at the entrance driveway shall be constructed no less than 45 feet in
diameter with decorative pavement and controlled with stop signs and markings on the
Brickwalk and podium building driveway approaches.A centerline shall be painted on the
private street on all turns and at Deep Valley 9rive driveway.
80.The private street shall be designed to discourage cut-through traffic between Indian Peak
Road and Deep Valley drive by non-residents.If the City Traffic Engineer determines that
cut-through traffic is prevalent,the owner shall provide additional calming measures such
as private property signs,speed humps,limited access gates or other means on the
private street to resolve the condition to the satisfaction of the City.
81.Adequate sight distance for all driveway connections with private and public streets shall
be provided.The minimum sight distance shall not be obstructed by walls,columns or
landscaping to the satisfaction of the City Traffic Engineer.Minimum sight distance along
the private streets and driveways shall be maintained by the property owner(s).
82.The pedestrian access ramp for Lot 2 on the east side of the private street at Deep Valley
Drive shall be constructed with see-through railing to provide sufficient sight distance.
Provide a 25'sight visibility triangle formed by the edges of each private street and
intersecting street right-of-way line for eXiting vehicles or show adequate sight lines to the
Resolution No.PA-01-07
December 17,2012 9
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satisfaction of the City Traffic Engineer.The sight visibility line shall not be obstructed by
walls,columns or landscaping over 30"high.
83.The retail mixed use driveway at Deep Valley Drive shall provide a 5'sight visibility triangle
formed by the edges of the parking structure driveway and the intersecting street right-of-
way line.The sight visibility triangle shall not be obstructed by walls,columns or
landscaping over 30"high.
84.The developer shall provide and install all traffic control signs and markings for private
street circulation including stop signs,crosswalks and directional signs for various users to
the satisfaction of the City Traffic Engineer.Visitor and customer spaces must be clearly
designated by signs and markings outside any gated area.Each private street and
parking level driveway entrance shall be signed to indicate the designated parking for that
area.
85.Stop signs and related markings shall be installed on the private road at Deep Valley Drive
and Indian Peak Road to the satisfaction of the City Traffic Engineer.
86.The developer shall fully reconstruct the private street driveway on Deep Valley Drive with
decorative sidewalk,curb bulb-out and landscaping per the Deep Valley Streetscape Plan
design elements.
.87.The minimum number of required parking spaces for the condo visitor and customer use
must remain publicly accessible at all times during normal business hours.No closed
gates shall be permitted for the customer or shared parking areas during business hours.
88.Height clearance signs and clearance warning bars shall be provided for subterranean
parking areas at entrance to that level.
89.At least one vehicle shall be able to queue in front of all proposed access gates in both
directions without blocking the street,private roadway,sidewalk or aisle.The proposed
gates at both mixed use building driveways must be located inside the building.No gates
may open into the City right-of-way.
90.Key or code controlled ingress shall be provided at any gate,including an intercom system
connected to individual units if guest parking is allowed behind gate.Automatic exiting
using vehicle detection must be provided when vehicles leave the gated area.
91.Separate dedicated loading areas for retail uses shall be provided for the mixed-use
bUilding andBrickwalkRetaii Center (Lot 2).
92.No portion of a column shall encroach into the required 9'wide parking width.Column
placement must be at least 2'inside end of stall and not obstruct vehicle door opening.
Alternately.the stall may be at least one foot wider next to the column.This condition does
not apply to existing parking spaces for Lot 2 that will not be modified by the project.
93.All parking spaces adjacent to an obstruction;except columns,shall be at least one foot
wider than a standard space (9'+1 '=1 0').
94.At least three feet shall be required beyond the end of an aisle to provide sufficient back-
up space for vehicles in the last space of the aisle.
95.All two-way driveways and aisles adjacent to a wall or obstruction shall be at least 25 feet
wide.
96.All existing street improvements on Indian Peak Road including turn pockets and
deceleration lane shall remain in place at the discretion of the City.
97.Wheel stops or 6"high curb shall be provided for all parking spaces.
98.Disabled parking shall comply with current standards unless otherwise permitted by the
bUilding official.One or more van size spaces shall be reqUired for each separate
Resolution No.PA-01-07
December 17,2012 10
2-189
structure with visitor/customer spaces.An ADA accessible path shall be shown from
disabled parking to building entrance on building plans.
99.Separate disabled parking shall be provided for Brickwalk parking area,Townhome guest
parking,mixed-use commercial parking and guest parking areas at the required ratio
unless otherwise directed by the building official.
100.Staircases shall not exit directly onto a vehicle aisle or street without a landing ...
101.Slopes,cross-sections and transitions for all vehicle ramps and private streets as required
by code shall be shown on building plans.All ramps shall include transition slopes at the
beginning and end of the ramp and must meet the required slope setbacks behind the
property line.
102.Parking stall cross-slope shall not exceed 5%except those existing spaces in Lot 2 that
will not be modified by the project.
103.A system of connecting pedestrian walkways shall be provided between all separate
structures within the development and must connect to Deep Valley Drive without requiring
pedestrians to walk in roadways or along private driveways to the satisfaction of the City
Traffic Engineer.
104.All private streets shall be 28 feet or greater in width.No parking shall be allowed on the
internal private streets at any time.
105.The private street shall provide a full height curb along its entire length.
106.All gates,entrances and private streets shall comply with Fire Department requirements
for turning radii and access.
107.The residential parking ramp in the mixed-use (podium)building shall provide van
accessible vertical clearance.
108.To reduce the potential and severity of run-off-road type vehicle collisions,rolled curbs
shall not be permitted on any common driveway,private or public street in any of the
following conditions:
•Vertical slope greater than 5 percent,
•Horizontal curves less than 300 feet in radius,
•Adjacent to side slopes greater than 1:2 ratio (V:H),
•Adjacent to a sidewalk,or
•Within 15 feet of a wall,building or structure.
109.A shared parking agreement shall be executed between Lots 1 and 2 to permit the
parking of vehicles for the Brickwalk development in the podium condoiminium building.
These spaces shall be accessible to patrons/employees of the Brickwalk development at
all times during normal business hours.
110.A Conditional Use Permit shall be required for any new use that affects parking supply
in the Brickwalk commercial development.Specifically,any new restaurant use that
increases parking demand shall be evaluated through a shared use parking demand
analysis at the time of review.
111.Prior to issuance of building permits,a master sign plan for the commercial component
of the condominium building shall be reviewed and approved by the Planning
Commission.
112.Prior to issuance of building permits,a master sign plan,awning program,and building
painting proposal indicating colors to be used shall be approved by the Planning
Commission through Precise Plan of Design review for the Brickwalk commercial
development.
Resolution No.PA-01-07
December 17,2012 11
2-190
113.The applicant shall provide and construct all streetscape improvements consistent with the
Deep Valley Drive Streetscape Master Plan in the public right-ot-way immediately adjacent
to their property on the south side of Deep Valley Drive.The proposed
hardscape/landscape improvements in the pUblic right-of-way shall be reviewed and
approved by the Park and Activities Commission and/or Public Works with all soft and
hard costs payable by the applicant.
SECTION 2.That the City Clerk shall certify to the adoption of this Resolution.
ADOPTED this 17111 day of December,2012 .
._--~...~..,.-7f7'...//~."
BRITT HUFF,CH/l(~~MAN
.ATTEST:
I HEREBY CERTIFY that the foregoing Resolution No.PA-01-07 was adopted by the Planning
Commission ot the City of Rolling Hills Estates at a regular meeting held thereof on the 1i h day of
December,2012,by the following vote:
AYES:
NOES:
Bayer,Huff,Schmitz,Scott,Southwell
ABSENT:Rein
ABSTAIN:Conway
Resolution No.PA-01-07
December 17,2012 12
2-191
Notice for open house/public hearing for the
San Pedro Community Plan Update
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Estatutll de IaCiudad de los Angell'lS.Elelistente Plan Cumullilario
deSanPedrolueadoptadoenlS99yahoraseestAactualizaodo
para renejar pollti~as.practicas.y condicione~attuales.los
CambiosPmpuestosdeZullasyEnmiHllllasfuemniniciadiislKlrJa
Ciudad de los Angeles einvolucranpropiedades privadasypOblicas.
Durante la Sesi!ln Comunitaria.que 135 de las 5:00pm a las
6:Jlipm.representantes del Departamento de Planifi.aci6n Urban3
presenlaranloscambiilspfOpuestosalPlanexistenteyconteslaran
pregufltas relocionadas a l1st1'!.Ccmemando a las 6:30pm.una
Audiencia Publica sera .cndutida por un OfIcial de Audiencias,
quien considerara lndos los teslimonios del pUblico y cualquier
comunkaciOn escritJ que sa hava recibidoantes dr..oduranle 13
Audiellcia Publica.Posteriormente.ser~prell<lrado un repot1e de
reccmendaciones por eJ Departamento de Planilicaclon Ur!)ana
paralaconsideraciOr,delaCcfl',lsi6ndePlanilica,i611delaCiudad.
vdi!sPUeSporeIConsejalyeIAlcaJdedelaCiudad.ClltnetItariospor
ISCritopIlBdcnsersomBtidosporeorrvollpcKCllrJe08IactrDnk:lIl:
Debbie Lawrence.Depmment IIftny Planning
200 N.Spring Street.ROllm 661
Los Angeles.CA 90012
t!vb~JfI.lllwnmefl@lillo'ltj.org
DistritoCollSejale15
Sesion Comunltaria y Audiencia Publica
Fecba:Mietcoles.12.de dicientbre 2012
Sitio:The:BoyundGirIs,Club
100 W.5th Street
San Pedro.CA90131
Hora:5:011PM-6:3DPM Sesi6nComunitaria
6:3DPM-8:00PM Audiencia FUblica
Un mapa,una tabJa de datos,eltextodelos cambios propuestos
aJ Plan ComunitJno de San Pedro.'I el Reportr.Bor.tdcr de
Impactos al Mef1ioambiente.seran dispanibJes para inspocciOn
durante las Sesiones Comunitarias y Audiencias P6blicas,y
tambitm po;inlelll!!l al:www.planningJlcity.org.Adamas,estes
materiales seran dlsponibles para inspecciOn en las bibliotecas
identilitadosenlapaginaslguI6flte.PuedeliamaraI1213i978-117!l
sitienealgunapregunta.
8 resumen del mapa con propuestDs cambias se indl/\,e en este avisn.
forthe
San Pedro
Community Plan Update
Pleijse·~·t!'Js·llOticawil1tj4:lll/'neig/ibt;rrsarrd-~i,'1r1lea}/"'mrjty.
Data:WedMsday.Oc,."mber12,Z61Z
Locittion;.11teBoysarMlGirlsQub
100W~5th Street
San Petfro,CA 90731
i8uildingentriltlte~pattiuaioll!ilr)
Time:S:GD,PM.,.&;30:PM Open House
6:30 PM-8:00PM PUbl~Heafing
Importante:En este aviso eru:ontrara infDrmacion de su comunidad en Espai'io{.
City Planning Case;Cf'C..20D9-1557-&PU
Environmental Case:ENV~2OO!J.1S5B-aR
San Pedro Community Plan Update
Tile City 01 los Angeles will hold an Open HouselFublic Hearing
regardillfl proposed Zonll Changes aild Plan Amendmllnts to the
San Pedro Community Plan.in accoldance with the los Aflgeles
City Cl1arter.The existing San Pedm Community Plan was adopted
in 19!1!l 3nd i5 being updated to reflecl CUflent policies,practices.
and conditions.The proposed Zone Changes and Plan Amernlments
are initiated by the City o!los Angeles and involve private and
publicly owned land.
The format of the sassionwilJ be an Open House followed by a Public
Hearing.Atlhe Open House,from 5:00-6:30pm,Department of City
PlanningslarfwiHpresaottheprop!lsedctlangestolhee~islingplan
and will answer rela~ed questions.Beginning at 6:30pm.a Public
Hearing will be conduttsd by a Hearing Offi~er,who will consider all
public testimony and anywritteflcommunicatian received pnorto,01
at the hearing.A Writl1ll1 recommendation report will subsequently
be prepared bytlle Department 01 City Planning for consideration by
t'leCI1yPlanningCommissionar.dthenby1l1eCityCounctlandMa';'tJr.
Wrifl'fll communlcarioD JIIould be emailed or mailed fa:
Debbie lawrence,Depllrtment of City PlaAniag
2DO N,Spring Street,RDom 661
LosAngmlls.CA90Dl2
debb-ifl.BrY'lronc&@lllcity.::l1.1
A map,tllble,and text 01 lhe proposedchanllestat!le San Pellm
Commuflity Plan,as well as the Draft Environmental Impact Report.
will be available for IIlview at the Open HouselPubfic Hearirlg and
online at www.planningJm:ity.Drg under N!:'N Community Plans.
They will also be available for viewing ar
Council District 15
Open House &Public Hearing
Date:Wednesday.December 12,Z012
Location:The Boys and Girls-Qub
100 W.5th Street
San Pedro.CA 907-31
(Buildlngll/lffilllCllandpafki.'l9/,1ff!arJ
TIme:5:00PM-6:30PM Open House
&:3DPM-8:0D'PM Public Hearing
•San Pedro Ragional Branchlibrar,'
(931 S.Galfev Strcetl in San Pedro
•Harbor City-Harbor Gateway Branch library
J24000 S.Western Ave.l in Harbor CitY
•l.csAngelesCentrallibrary
153DWl}:;l 5th Slreet)in dllwnlown ws Angr.lr.s,
You may also contact project staff with any queslions at 1213197lJ.116J,
Thesummilry map is inc!uded in this notice indicatingareasvmere
changes are being proposed for re1!iew.
Ef 08par'<i1ffl(jnfl1 diJ Fi;milicacioo de la CirJl1iid Iff Inliira a dar $U IflSl1l1lf1t1io 0 cmr<8nlaOOp/JI 6sclito.CfN'llIJilicaci{Jfl,iS plJrlm;rito df!brmMlr fflCibidaSIlfl 61
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sn el tiemptJ ds ws pms<llltarilJ.1f!5 lJf,o~1tJ a liml~aallnu rie liempo y f}J11J rndlIc;tal m'nmlD fa rep8rtr;/$l.(j/Oep;irtmmmfl1 aHiIlItiJ f!f/Wln~dll
ropresentiJ/llffsl1f!lflVpo$urgar..iladUSfinlu/FinJereslimcrliosimJivirroJll.'es.
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CualquierrotrosJNJf/dl1m:ia 'lscnraenrrl1gadaalllapart<imenwdePlanifkacidrlanresoe/sd!:Ci:i6n delil CamlsiOn r1ePlsnific8C;rerobreet&l/tIwpsss~s
fomliffparrfldfJlexpedie;llItadminisiraliliO.Porfal'OrtMgall/lCuffnlaQuff6StallOser;la.,jlrirrra.8U!fifm{;iasoore81leaSiinw.
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Angelesr:Ol1rur!minapormollvosdamSClJpdcidiJd.EJI:JfJa,~lalJlJdieflf:id rell!sw:r(Jfl;jmicntf}sooii(;C~/bI~p8r3f.'CrslJT/iJ$.cnsi/lUl1etlJ(j(/;Js./JIIi!q;mlcs
rfe idi(}/f!!I.disposilWcs de Sj'llda i1lJffirive,II otros mea."os f/JXiliares r III a,TOSselviciOs $I){JlJ~e:lproiX}ff:iMiI'i1petitiM_Pam eSlSlflIriJrfadispiJtlibilidiid
delos serYicics.porfal'flrl:aga $1/sOlicitlHla m~stal"dar~:Has !lJbilfIIi(12/rarasJenltls riola ISv:JieP.cia i1121'·!!lB·/tlS.isCir;dedde los 4ngsh!sesur.a
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",m""""..•'Iilii::jl)}:m;a
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1M uepa.'Tm8n1 Gf City PlaMlfl9 icwites .yom ~rtim;my or K-'rillan conrmelroS.Wrinen comtrwnica!iofl$shwld be receivM1 in rile Deparmem as
5001!01$possibJ~_It;orrfer that all ~'imtPGillts mar ~pmsenfed.spwhHS al rhe hear:'ng !lli/Y be limired in lha tellglh of rheir prosenfall{}fl$_Bl1t:illJsc
of dIM CiJflstrilint;;lind to minimill1 rspafition.tIItJ 08pi1rl111l1/lt tJflCiJlJr.Jgss pfSs8marirms by repnJUllrariVe1s ot orginiJerJ {'roups,i,1·[/8lI of
m.:lllJ'imJil'idualspea!rett.
ElhiJ!lSticn cf AdmJnlsrralin!Rllffliidies .{f I'flIJ chall/mge t!lis !lli/tter in COUrt.~w milY I:c limlWd Ii}lOOse /lsueS I'fl:t or someonfl elsii raised at tflt;
publit;hf!iiringdfl~ribedin/lll$norics.orinwn'lteJIccr;8sptJMien,eQlllhemalf6(dl!lil.-'IIrf!dlOrh!slIgencyat,(.'fpri(}rlotrreptJblic1l4aring,AnywriU8n
wmspondenwdelive:rollJthe De/ii3rtmem.~forfIl/l!/flam/ing C(Il/Itr.isJiffm's actiooon 1118 mltterwill1Jecome a part-ofl1tfl admittistrllti~'e reaJrd.Please
/!G1il!1larlhisl\".ayllDtlltlthsIMthl1aringcnlhisffldlllU.
ft..i"<l t.n'JCrod j)fItilylilJlJer Title II (}f lila Americans with Di!tiibilities Act.ths CilY /If (11$tngaies dolts no,tiis~;'Ilinars The trn1I!'fing (3C(lily aM ilS
parting ./11 Wheekhai,·a«tlss/ble.Sign lenguage irtffupreters.ass/slit"!!IiSl~rti1 devist!s,.,r other aUJIiliary eil1s 6nd/l1r s"fllices mil'l blt pffJfiried
r;poofSflUfist T"ensul8i1~iJatil;ryofS'!,..it:fls,pisasemalreJ'CurrequflstllOlilterthanlh1"fl&"iO..liir:g rfar.tfl2hour$Jf)fiort"'hftmeeti"llbyClflfing
Ocbti!!lawronccat(213197B-116J.
2
-
1
9
3
Draft Land Use and Zoning Map -Areas of Proposed Change
San Pedro CommullIty Plan Atea
LEGEND I GUlADE MAPA,
Areas of Proposed Change I AmlJls de Cnmbills PIOpUl}s!n$
San Pedro Community Plan Update
. .~
t;IllUpilmUIiSllillaszo:'lasllumillsa propeneI'!uscwnbios a IOSft:qllisilns
ili!~lIl1ifica.:lljr.0 [!{imin cmre:c'mHl~tec!licm:~:IIIl!cpr,r.en_La rna~crfa do I,)s
camhio~lesu!tan en Ie adicion till IlIHl'ias normas de disc!lu a.::eri:il los Ifmiles
de CMStruCl;icl'.las ,,!turas de edificiGs.yl!l~lelrems donegocios adem~s a
mrasmglas ElmapadlllillhlIJoyregulac:cn<:spmpuf1stassepue(lefl\,*=renla
scsioncomllr.itariayalldicntiapuhlka
Draft Lund USB And Zoning Changos
11m map Shll'Nli ~haded amllS whem changes to lOJ1jJ1!J reqaimmr.r!ls ilia hein!1
prl!po~;efl.Drwtl!iflll!:-.~hf1it.all:mrr;clic;nr.;IW Mil")>!mll~e Moslcha:'lges involvll
thcudditionofnewdesigr:regllfatilll1swgardinllsotbacks,hElight,andsiunallC
iI1l\llll!lothml'lil1l1fll1iOIlS.ThedlllililadrnaPilndplG!KlSlldreguiationSClmho
vieWlld,UUmnmiemlopo!lhouSIlRndpllhlithlilllill[l.
CanJlrios De USll Oil La Tierra VDe Zonificilchin Propuusfas
·····························1,
I
Morelnforrnation Is Available Online
All propc:sadc!'IiJflgesareaVilllatlle cnlinewith fJatailmleAp:dnaticmsnftim
Community Flan llpdalll lllllcess.Tho map of propo~ed zoning changes by
subarea aMI:ml'tlSlll)nl".!iI19 surnmmy nl rngU!;II:c:ns tim also M ...inwr:rionlin(J ,ll
bttps://sites.google.com/sito/sanpedrocolnmunityplalll
Mas Informaciim Esta Disponible en 01lnt9rnot
todnsl(lscambiCSjlropueS\(ISestc'lflditPOfliblnsflnr:liIl1lIrnet con InS
llxplicatiOnasdelalfildilsdlllprocBsodCfevisarelPianComunitario.Elmap<!
Cill1loscmnbiDspropueSIOS'flllrosun-J3ndelasrt:{juiilciormstmnbiilnSil
puml'.'/.IVC!lPJ111il!llr:f1W,t
https://sitas.google.comlsite/sllnpedrocommunitypfanl
2-194
Letter to Councilman Buscaino regarding
San Pedro Community Plan Update
2-195
CITY ~~\1.L
7<12 N.$prr'O $!ro~t
nOOJ\14Z&
uJ!::~rQe(~.CJl~gC"Jl:2
(t<:ll;r:i,~;:W!!1
F~~:Zl~62l}5?~~
Counci.lt'llember
JOe:BUS(~H Ino
Fifteenth District
DISTRiCT C;:;FICE$;
SAN PEnRO OFFlCf-
!l.lllS,111;000n ::1I~t
Sl.m~ES2
So.",P<:r.!r".C:A~;u ,;j"",
,1{)·7:!2·,lJH6
Fa>.,'!W<J:r,M!illll
Vr"ifdTS ·=rnrz
1<1221 C'.Q<'i'1j;:<Jl'PI...
Sull<J211v
L""Ml1llI~C,\HU:IlI~
"S....l73-ti1:Z$
F..21:!·4731i1X!
December 13,2012'
Mr.Michael La Grande,Director
Los Angeles Department of City Planning
2'00 North Spring:street,5th F~oor
Los Angeles,CA 9'001.2
RE:Proposed Change to San Pedro Community Plan ~25th and ~fStern
Dear Michael:
I respectfully request that the Planning Department's suggested plan for sub ..area 260
(25th and Western)be withdrawn from the proposed CommuniiyPlan Update.I
strongly believetnat the proposed Increase In density is inappropriate fo.r this locetion.
As your staff witnessed at its open house and public meeting on Wednesday evening,
thecommuf11ty.l$unanimously opposed to 'increased density at 25th and Western.By
far,the most contentiolJs item was this proposed zone change for sub-area 260 in the
coastal San Pedro neighborhood.
Preservi:ng the current k,w densityresiden11al neighbo'rhood and its coastal ocean views
are important to me and my constituents.My sincere thanks for your attention 10 this
request.
Sincerely,
JOE BUSCAINO
COl.lncilmember,15t1\District
2-196
E-mails and correspondence regarding Rancho LPG facility
2-197
Kit Fox
From:
Sent:
To:
Subject:
Attachments:
Kit,fyi.
CL
Carolyn Lehr
Friday,December 07,20122:41 PM
Kit Fox
FW:"LA City Fire (CUPA)Rancho LPG Situation ..urgent!"
finaUire_departmenUetter_on_cupa_deficiency.doc;rancho nuisance abatement nov
2012.doc;saftyelt.pdf;bea correspondence aug 32012.pdf
From:Bonnie Christensen [mailto:sphomeunited@earthlink.net]
Sent:Friday,December 07,2012 11:55 AM
To:sally.magnani@doj.ca.gov;brian.cummings@lacity.org;daryl.osby@fire.lacounty.gov;
helmlinger.andrew@epamail.epa.gov;wesling.mary@epamail.epa.gov;blumenfeld.jared@epamail.epa.gov;
Hamilton.c1oud@mail.house.gov;Ricardo.Hong@lacity.org;meveloff@gmail.com;william.carter@lacity.org;
marisol.espinoza@lacity.org;joe.buscaino@lacity.org;jacob.haik@lacity.org;gnatz@portofla.org;jcynthiaperry@aol.com;
rkim@lacbos.org;CC;g.sugano@lomitacity.com;June Smith;diananave@gmail.com;info@centralsanpedro.org;
ksmith@klct.com;Anthony Patchett;noelweiss@ca.rr.com;Lacombe Lacombe;Jody James;Connie;Pat Herrera-Duran;
wimmerarchitect@aim.com;Andrew Mardesich;David L.Rivera;Bonnie Christensen;
christie.whitman@whitmanstrategygroup.com;dpettit@nrdc.org;elise.swanson@mail.house.gov
Subject:Fwd:"LA City Fire (CUPA)Rancho LPG Situation ..urgent!"
There should be 5 attachments.Let me know if you do not receive all five.
zbiddy.com
1
2-198
San Pedro Peninsula Homeowners United Inc.
PO Box 6455 -San Pedro,CA 90734
E-Mail:sphomeunited@earthlink.net -Fax:(310)548-4255
November 27,2012
LA Fire Chief,Brian Cummings
Los Angeles Fire Department
200 No.Main St.,16 th Floor
Los Angeles,CA 90012
RE:RANCHO LPG NUISANCE ABATEMENT COMPLAINT
Rancho LPG
2110 No.Gaffey St.
Sim Pedro,CA 90731
Dear Chief Cummings,
Please find the attached Nuisance complaint filed with the LA Zoning administrator
against Rancho LPG storage facility in San Pedro.
The LA City Fire Department has been charged with the responsibility of oversight as it
pertains to the safety management of hazardous facilities such as Rancho Liquid
Petroleum Gas LLC and their voluminous 25+Million Gallon storage of butane and
propane gas.This gasstorage facility is operated by Plains Mid-Stream Canada (Plains
All American Pipeline)under the supervision ofthe fire department's Certified Unified
Program Agency (CUPA).In the 1990's,there was a consolidation ofa number of
agencies having jurisdiction over these types of facilities with added emphasis upon
CUPA's responsibility as the primary enforcement.It is painfully obvious that while the
CUPA was formally responsible for this importap.t duty,the LA City Fire Department is
woefully understaffed and under-funded in competently fulfilling its obligation.That
reality can be witnessed by reviewing California EPA's "deficiency findings letter".The
EPA findings letter stems from their evaluation of the City of LA Fire Departments
CUPA and is dated September 15,2011 with a subsequent Deficiency Progress Report-
Update 3 submitted June 15,2012.
While this summary confirms an inordinate amount of deficiency associated with the
collection and charging of various fees,there is also substantial acknowledgement of
CUPA's (the LA City Fire Department's)inadequate inspection and review of facility
conditions related to an operation's compliance with existing laws.Rancho LPG is a
glaring illustration of that deficiency.While installed over 40 years ago,and exempted
from CEQA conditions and LA City Fire Regulations at that time,many facts under the
supervision of CUPA have continued to be ignored with complete disregard to the
elevated hazard that the facility poses.
2-199
Possibly the most flagrant is the continuation ofthe "fallacy"that the single impound
basin below the two 12.5 Million gallon butane tanks would serve as some kind of safety
measure in the event of a substantial tank leak or rupture.Clearly,at the time of its
introduction most authorities involved were ignorant
of the chemical and physical properties of Butane/Propane gas and how it would react
upon release.Butane gas is only liquefied under refrigeration and upon release into the
ambient air will vaporize and expand over 200 times its volume.The gas is heavier than
air,and will hug the ground seeking the lowest levels until finding any ignition source.
There are 5 ignition sources on the facility's very premises.The impound basin,(the
company's emphasized safety measure)would be able to contain less than 1%of the
volume of a single tank as a vapor upon total rupture.Any confidence ofthis basin's
effectiveness in the "containment"of a single 12.5 Million gallon tank's contents is
bogus.This particular point,that is so absent of educated consideration,should be the
first point that the Fire Department identifies in relation to the safety of such a facility.
Upon'visiting any fire station in the immediate Harbor region,you will find a map of the
area that will have two red circles identifying Rancho's two largest tanks.These tanks
are clearly regarded as an elevated risk by the Fire Department,standing above and apart
from other hazardous facilities,yet the LA City Fire Department representing CUPA
continues to ignore the obvious problem allowing this extraordinary risk to jeopardize
public safety.
Another legal issue at hand,is the geologic conditions of the facility.The facility and its
tanks sit directly upon the Palos Verdes Fault (mag 7.3).Legally,any structure built
upon an earthquake fault demands an exemption by a State Geologist.That law has been
in effect since before 1973.Yet,this criteria was never followed.In addition to this,the
existing butane/propane tanks at Rancho LPG were built to a seismic substandard of 5.5-
6.0 and were constructed without benefit of LA City Building and Safety permits.The
tanks were only "certified"by LA Building &Safety in 1978 while the facility was
already in operation.
Rules created through various jurisdictional agencies instruct CUPA to re-evaluate a
facility that experiences any significant change in operation.Over these past 40 years
there have been many changes to this LPG facility.The facility (Petro lane LPG)in 1973
was located in the Harbor region for the expressed purpose of capturing the highly
profitable opportunity of importing and exporting their gaseous commodity (propane)by
sea.Over 68%was shipped by this method.The storage facility has been located on
private property within the City of LA with pipeline access to a wharf at the adj acent Port
of LA under a lease agreement.There have been additional tanks added to this facility as
well as a major shift in their business in the 1980's when it changed from the
predominant storage of propane gas to that of butane gas.In 2006 the port refused to
renew the wharflease with the company (then Amerigas),and ALL LPG product was
transferred from ocean shipping to land transport by rail and truck.This change should
have flagged a completely new EIR process responsive to the new business operation.
However,it did not.
2-200
The American Petroleum Industry set forward 9 recommendations (under their design
specifications 2510 for appropriate siting to minimize risk from explosion and fire)for an
LPG facility.Eight out of nine recommendations for proper responsible siting are
violated by the Rancho LPG facility location.Only one solitary item,"availability of
needed utilities"falls into the perimeter of API's proper guidance for hazardous siting of
LPG facilities.Also,the existing tank set back conditions of Rancho violate current
standards for these types of facilities
It is incumbent upon the LA City Fire Department and all jurisdictional and other
governmental authorities to begin to face the grim reality of the presence of this risk-
prone facility and deal with the problem before it materializes into the cataclysmic
inferno that it has the capability to become.With the aftermath of failing infrastructures
(gas leaks &explosions)being recently felt across our Nation,and the likelihood of
earthquake and terrorism rising daily,the culpable indifference and ignorance associated
with continuing on this course so ripe for disaster is intolerable.
Without question,the LA City Fire Department has been unfairly and unwisely saddled
with the monumental task of supervision of hazardous facilities with insufficient
resources to complete the job.There is an inordinate number of petrochemical facilities
assigned for monitoring by the LA City Fire Department as CUPA without enough staff
and expertise to responsibly meet the challenge.
We urge the LA City Fire Department to acknowledge the obvious governmental
negligence in allowing this ultra hazardous facility to expose the innocent public and the
ports of both LA and Long Beach to extreme harm.The Los Angeles Fire Department,
as CUPA,will take the most blame in the event of a disaster from this facility.The LA
City Fire department has become the virtual scapegoat for other jurisdictional agencies
who have burdened LAFD with an onerous task.We urge you,Chief Cummings,to
fulfill your leadership role in representing and protecting the people of the City of Los
Angeles and all other citizens within the estimated (through EPA's formula)catastrophic
10.6 mile blast radius of Rancho LPG.This blast radius is very real and totally feasible if
the entire Rancho facility blows.This scenario doesn't even take into consideration the
probable "domino effect"of that explosion upon the multitude of other adj acent chemical
and fuel resources available.Please stand with us in our complaint of Rancho LPG as a
public nuisance that needs to be removed or relocated.
Previous EPA Chief,Christine Todd Whitman's comments regarding issues of risks from
hazardous facilities reported on in April of this year are well founded.
The McClatchy Report:April 15,2012
WASHINGTON -Wading into a decade-old controversy,former Environmental
Protection Agency chief Christine Todd Whitman has urged current EPA administrator
Lisa Jackson to close loopholes in a 2006 chemical security law "before a tragedy of
historic proportions occurs."
2-201
Whitman,who led the EPA under George W Bush,suggests the agency use its authority
to seal gaps in "extremely limited"Department ofHomeland Security rules designed to
prevent releases oftoxic chemicals,according to an April 3 letter she wrote to Jackson
that was obtained by the Center for Public Integrity.
Those 2007 rules,Whitman wrote,bar DHSfrom requiring industry to take specific
measures to prevent accidental or terrorism-related toxic releases.The rules exempt
"thousands ofchemical facilities,including all water treatment plants and hundreds of
other potentially high-risk facilities,such as refineries located on navigable waters,"
she wrote.
The EPA has the power to regulate chemical security under 1990 amendments to the
Clean Air Act,Whitman noted,writing that the act's "general duty"clause "obligates
chemical facilities handling the most dangerous chemicals to prevent potentially
catastrophic releases to surrounding communities.
"Facilities with the largest quantities...should assess their operations to identify safer
cost-effective processes that will reduce or eliminate hazards in the event ofa terrorist
attack or accident,"Whitman wrote."This has never been required and today
hundreds ofthese facilities continue to put millions ofAmericans at risk."
According to DHS testimony this year,there are 4,458 high-riskfacilities nationwide.
In 2006,then-Sen.Barack Obama co-sponsored legislation that would have required
high-hazard plants -which Obama called "stationary weapons ofmass destruction"-
to consider using safer technologies and enhance security.The billfailed.
LAFD as CUPA has the authority and responsibility to respond to this facility's
deficiencies and identify the Rancho LPG facility for the hazard that it represents.We
urge you to do so.It is time for the LA City Fire Department and other responsible
agencies and government officials to represent tl;1e constituents that they have been
appointed and elected to protect and serve.The time is now.There may not be much
time left.
Thank you for your time.
Sincerely,
Chuck Hart,President
Cc:Lisa Jackson EPA,Andrew Helmlinger EPA,Jared Blumenfeld EPA,Mary Wesling EPA,Sally Magani DOJ,
Congresswoman Janice Hahn,Congresswoman Maxine Waters,LA County District Attorney Jackie Lacy,LA County
Board of Supervisors,LA County Fire Dept.,LA Mayor Antonio Villiaraigosa,LA City Atty Carmen Trutanich,LA
City Controller Wendy Greuel,LA City Councilman Joe Buscaino,LA City Councilwoman Jan Perry,Assemblyman
Rod Wright,Assemblywoman Bonnie Lowenthal,Rancho Palos Verdes City Council,Lomita City Council,Rolling
Hills Estates City Council,Atty.Anthony Patchett,David Pettit NRDC,Christine Todd Whitman
2-202
San Pedro Peninsula Homeowners United Inc.
PO Box 6455 -San Pedro,CA 90734
E-Mail:sphomeunited@earthlink.net-Fax:(310)548-4255
November 22,2012
Michael J.LoGrande,Zoning Administrator
Los Angeles Planning Department
201 North Figueroa Street #4
Los Angeles,CA 90012
RE:FILING FOR NUISANCE ABATEMENTIREVOCATION
RANCHO LPG (ORIGINALLY,PETROLANE LPG)
2110 No.Gaffey St.
San Pedro,CA 90731
Dear Mr.LoGrande:
The San Pedro Peninsula Homeowners United is a non-profit 501 C-3 corporation that was a
litigant and prevailed in the interest of the community in the China Shipping lawsuit in 2003.
Unfortunately,our Homeowners have been unaware until recently of the changes in 2008 to
Nuisance Abatement criteria that now offers the opportunity to take action on situations that have
been "grandfathered in"as a means to protect the citizenry.We applaud the long overdue
wisdom of this inclusion.We now "officially"lodge our complaint and action with a demand to
the City of LA to protectour community.
The above listed Liquid Petroleum Gas storage facility has been a matter of consistent concern to
residents since inception in 1973.Since that time an extensive list of LA City and County
officials,State officials and Agencies,Federal officials and agencies have all been solicited to
take action on this ultra hazardous facility due to the.risk it poses to the public to no avail.
The introduction of the liquid petroleum gas facility (initially,Petrolane)created a condition that
is harmful to the public's health and safety.The large radius of impact endangers a great number
of people.Ordinary citizens are negatively affected by the presence of this facility.The
incorporation of this facility was a violation of the 1st principle of Civil Law;"Exposure of the
public to risks that they do not know about,nor have agreed to accept."The seriousness of the
potential harm significantly outweighs the social utility of Rancho LPG.Plaintiffs within the
radius of impact suffer harm that is different from the type of harm experienced by the general
public.Rancho LPG's operation is a substantial factor in causing harm to the plaintiffs.
This LPG facility was introduced without benefit of a risk analysis,without a proper EIR;The
EIR does not respond to the volatility of its gas commodity,the existence of residential
neighborhoods,and the myriad of geologic and seismic vulnerabilities of the property.The
facility was given an undefined "emergency exemption"to CEQA and LA City fire
regulations.Governor Brown's 1977 report by the PUC confirms these facts.
2-203
We have included a copy of the City of LA Planning Department's own map which clearly shows
that the two12.5 to13 million gallon capacity tanks of the storage facility are located directly in
the Earthquake Rupture Zone of the Palos Verdes Fault (mag.7.3).As if that is not worrisome
enough,the existing tanks were built "without having pulled LA City Building Permits"and were
only "certified"after serious controversy and pressure in 1978 while the facility was in
operation.The tanks construction meets a seismic sub-standard of 5.5-6.0!The cataclysmic
potential of this facility is incredible.Yet,the City of LA has appeared unconcerned about the
danger.
LA City's business permitting process demands that a business must "re-file"as a new business if
there is a change of over 50%in their business operation.RancholPetrolanelAmerigas LPG
facility located in the Harbor area for the main purpose of shipping their LPG by sea.Although
only one EIR was conducted under a "Marine Terminal"at the Port of LA,the actual storage
facility was always located on a remote and separate piece of LA City private property with a
pipeline to a "wharf'located at the Port of LA.Over 68%of their propane product was shipped
by sea :with the remaining percentage made up of rail and truck transport.
In approximately 2006,the Port of LA refused to renew the company's 30 year old pipeline lease
to the wharf.At that time,there was an immediate and demonstrative change in their operation
shifting ALL hazardous Liquid Energy Gas transport to Rail and Truck!This is an inherently
more dangerous mode of transport.Also,sometime within those 30 years,the business of major
"propane"shipping,changed to "butane"shipping.The largest tanks are now storing "butane"
rather than the original "propane".These business changes should have triggered a new EIR,but
that never happened.
The bottom line is now this:
As tragically irresponsible as the above conditions are and have been since 1972,the situation
has only gotten more intense with time.We are continually witnessing devastation caused by
antiquated infrastructure problems in the US.This facility is now sitting on an infrastructure that
is over 40 years old.The likelihood of significant earthquake has increased dramatically and we
now understand with climate change an increase in concern for tsunami in the port region as
well.The facility sits within Y:z mile of the inner harbor of the port with a storm drain at its base
that leads directly into the LA harbor.Any significant rise in that harbor is going to channel
water back to the facility site,which happens to be in a "flood zone".There was recently a sign
removed within 200 f1.of the facility that said,"You 'are now exiting a tsunami zone"yet there is
no rise in elevation nor apparently was there any consideration of the storm drain location.The
potential for terrorism has greatly increased making this site one of the most obvious choices for
attack.This volatile gas bums at over 3500 degrees F,and the heat generated from a fire
there would ignite flammables for miles.This makes the available cadre of refineries,fuel
storage facilities and marine oil terminals abutting and across the street from these tanks a virtual
"bonanza"target of opportunity for terrorists.
It is time for sanity to prevail on this issue.Attached is one of the personal emails sent to one of
our activists from Professor Bob Bea ofUC Berkeley.Professor Bea has been the premiere
expert hired by the US government to establish the "why"of engineering failures in catastrophes
such as the Gulf disaster,Katrina and San Bruno.He was contacted after his appearance on "60
Minutes"and has reviewed details of the Rancho facility.Like our residents,Bea has grave
concerns about this facility and its potential of "domino effect"that could likely cause an inferno
never witnessed before by man.There is no reason why our citizens should have to prove to
2-204
government the perilous potential of this facility with their lives.The handwriting has been
written boldly on the wall for years now.
In closing,we invite all City Officials and other Civic groups to join in this complaint to remove
this looming threat to our public.
This is the City of LA's opportunity to step up in a legal action that can save lives and
property.It is long overdue.Take action before it is too late!
Sincerely,
Chuck Hart
President,San Pedro Peninsula Homeowners United,Inc.
PO Box 6455
San Pedro,CA 90734
For more information:
Janet Gunter (310)251-7075
Attach.(3):map of rupture zone
source document:p.47,Safety Element ofthe Los Angeles City Plan
copy,Bea email correspondence
Cc:Mayor Antonio Villaraigosa
City Atty Carmen Trutanich
City Controller Wendy Greuel
City Councilman Joe Buscaino
City Councilwoman Jan Perry
LA County Supervisors
RPV City Councilmembers
Lomita City Councilmembers
San Pedro Neighborhood Councils
Port Community Advisory Committee
2-205
From:Robert G Bea <bea@ce.berkeley.edu>
To:Janet Gunter <arriane5@aol.com>
Subject:Re:Link to article in City Watch LA today re:LPG 5 ituation
Date:Fri,Aug 3,20122:46 pm
very good summary Janet.
status report from UC Berkeley Rancho LPG study group.three members of group are 'totally engaged'in the San
Bruno disaster litigation (since BP trial was suspended end February).trial date October 10th.all Rancho work put
on hold until trial is completed.
i had a 'mild stroke'July 22nd.major effect was loss of left eye vision.still undergoing tests to determine short and
long term prognosis.no signs the circulation system 'trash'reached my brain.
perhaps the San Bruno trial will provide opportunities to raise the flags about Rancho and about the prices of ignoring
infrastructure risk assessment and management...industry and government.we will stay alert for the
opportunities ...San Bruno is a perfect analog for a future Rancho disaster....lack of any realistic assessment of the
SYSTEM RISKS ...denial by industry ....more denial by government.....public not informed ....you know the rest.
bob bea
On 8/3/12 11:13 AM,Janet Gunter wrote:
http://citywatchla.coml com ponent!content!artj c le/317 -8box -right!3555-where-t heres-s moke-theres-fi re-
and-pass ibly-a-catastrophe?utm source=General+CityWatch+List&utm campaign=f17bf8d350-
CW10628 2 2012&utm medium=email
Professor Emeritus Robert Bea,PhD,PE
Department of Civil &Environmental Engineering
University of California Berkeley
Email:bea@ce.berkeley.edu
Home Office
Risk Assessment &Management Services
60 Shuey Drive
Moraga,California 94556
Telephone 925-631-1587
Cell 925-699-3503
Email:BeaP.AlvlS@gmaLL.com
2-206
2
C31$M St
223id St
!J:efifJfltf"~1i BI
2-207
Kit Fox
From:
Sent:
To:
SUbject:
Attachments:
Hi Kit-
Carolynn Petru
Wednesday,January 02,20137:46 AM
Kit Fox
FW:EPA-R9-2013-001262 Geo-technical Report for Rancho LPG
20278_tech_rew_rpt_12-20-12.pdf
I doesn't appear that you were copied on this exchange.
CP
From:Janet Gunter [mailto:arriane5@aol.com]
Sent:Tuesday,January 01,2013 7:17 PM
To:WongJeannie@epamail.epa.gov
Cc:SimmonsJoan@epamail.epa.gov;wesling.mary@epamail.epa.gov;helmlinger.andrew@epa.gov;
MrEnvirlaw@sbcgldbal.net;sally.magnani@doi.ca.gov;brian.hembacher@doj.ca.gov;hamilton.c1oud@mail.house.gov;
jcynthiaperry@aol.com;cary@brazeman.com;igornla@cox.net;det310@juno.com;noelweiss@ca.rr.com;
carl.southwell@gmail.com;CC;dpettit@nrdc.org;connie@rutter.us;jody.james@sbcglobal.net;grgrysmth@aol.com;
bea@ce.berkeley.edu
Subject:Re:EPA-R9-2013-001262 Geo-technical Report for Rancho LPG
Dear Ms.Wong-
Thank you for providing this information.This long awaited information certainly underscores our reasons for extreme
concern and emphasizes the critical need for urgency regarding the safety and security of our pUblic due to the presence
of this ultra hazardous facility.This report's direction for further analysis and evaluation of the geologic conditions of the
Rancho site should be assigned to an "uninterested party"immediately in the interest of public safety.An obvious area of
discrepancy is the lack of acknowledgement of the LPG facility site as being in an "Earthquake Rupture Zone"as clearly
defined in official LA City Planning D~partment documents.How ...and why...would that not be acknowledged?However,
there are many other very serious issues regarding soils and geologic conditions that remain reported in this document.
We are still awaiting the correspondence between the EPA and Rancho that was requested months ago.In particular,is
a letter referenced by the manager of Rancho LPG,Ron Conrow,at a Rancho Palos Verdes City Council meeting over 4
months ago..Please provide this correspondence at your earliest convenience.It is important for our public to
understand the dialogue that has been conducted between the operators of Rancho and your agency.
Thank you for your time and cooperation.
Janet Gunter
-----Original Message-----
From:Wong.Jeannie <Wong.Jeannie@epamail.epa.gov>
To:arriane5 <arriane5@aol.com>
Cc:Simmons.Joan <Simmons.Joan@epamail.epa.gov>
Sent:Mon,Dec 31,201212:02 pm
Subject:EPA-R9-2013-001262
Hi Ms.Gunter:
Attached is our response to your FOIA Request EPA-R9-2013-001262 regarding "Geotechnical analysis performed by the
EPA on Rancho LPG".
Regards,
1
2-208
Environmental Protection Agency
Superfund Division
Jeannie Wong
(415)972-3079
Email:wong.jeannie@epa.gov
Please open the attached document.It was scanned and sent to you using a Xerox
WorkCentre.
Attachment File Type:PDF,Multi-page
WorkCentre Location:USEPA Region 9,8th Floor,Room R8102
Device Name:PN R8102 Xerox5755 PS- --
For assistance,please call IRM helpline at 415-947-8023.Thanks .
•
•
2
2-209
BeOlechouloUles,Inc.
Consulting GeotechnIcal Engineers
cet£et6·
J1...ears~
SenJUe-
1971-2011
December 20,2012
File No.20278
US EPA Region IX (SFD-9-3)
75 Hawthorne Street
San Francisco,California 94105
Attention:Mary Wesling
EPCRAJRMP Enforcement Coordinator
Subject:Third Party Expert Technical Review
Seismic Hazards Analysis
San Pedro Terminal,Rancho LPG,LP.
2110 North Gaffey Street,San Pedro,California
SAIC Prime Contract No.#EP-W -09-032
Ladies and Gentlemen:
This letter transmits the third party review of the referenced report.This review was performed
in order to verify the accuracy and adequacy of the evaluation by GMU dated July 19,2010.The
referenced report was prepared to address geotechnical-related questions posed earlier by the
USEPA resulting from a review of a Tank Assessment Report by ABS Consulting.The criteria
by which the evaluation by GMU Geotechnical,Inc.was reviewed were those from the Guidance
for California Accidental Release Prevention (CalARP)Program Seismic Assessment by the
CalARP Program Seismic Guidance Committee dated September 2009.
No new subsurface work was performed by Geotechnologies,Inc.as part of this third party
review.A review of published geotechnical-related references for the area was performed as
well as a site visit.Separate commentary resulting from these tasks is provided.
Geotechnologies,Inc.appreciates the opportunity to provide our services on this project.Should
you have any questions please contact this office.
Should you have any questions please contact this office.
REINA T.K
G.E.2755,C.E.G.1547
Distribution:(1)SAIC,Attn:Diane Bodine
(l)EPA,Attn:Mary Wesling
Email to:[Diane.C.Bodine@SAIC.com],Attn:Diane Bodine
[Wesling.Mary@epamail.epa.gov],Attn:Mary Wesling
439 Western Avenue,Glendale,California 91201-2837·818.240.9600 •818.240.9675 fax
www.geoteq.com
2-210
SECTION
TABLE OF CONTENTS
PAGE
INTRODUCTION 1
BACKGROUND 2
SITE DESCRIPTION 3
LOCAL GEOLOGY 5
SITE VISIT 8
REVIEW OF EVALUATION BY GMU GEOTECHNICAL 11
RECOMMENDATIONS BASED ON THE SITE VISIT 16
CONCLUSION 17
CLOSURE AND LIMITATIONS 17
ENCLOSURES
References
Vicinity Map
Plot Plan 1 (West)
Plot Plan 2 (East)
Local Geologic Map (Dibblee,T.W.,Jr.)
Local Geologic Map (Woodring,W.P.et al.)
Historically Highest Groundwater Levels
Earthquake Fault Zone Map
Southern California Fault Map
Geotechnical Map by GMU
Geotechnical Sections by GMU
Geotechnologies,Inc.
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www.geoteq.com
2-211
THIRD PARTY TECHNICAL REVIEW
SEISMIC HAZARDS ANALYSIS
SAN PEDRO TERMINAL,RANCHO LPG,LP.
2110 NORTH GAFFEY STREET,SAN PEDRO,CALIFORNIA
INTRODUCTION
This report presents the results of the third party review of the Geotechnical Seismic Evaluation
for the Rancho LPG Holding Facility in San Pedro by GMU Geotechnical,Inc.dated July 19,
2010.The purpose of this review was to assess the accuracy and adequacy of the evaluation by
GMU Geotechnical,Inc.(GMU).The report by GMU was prepared to address Geotechnical-
related questions posed by the USEPA after review of a report "Tank Assessment Report for
Compliance with CalARP"by ABS Consulting dated August 17,2010.Since the initial report by
ABS Consulting was prepared for compliance with CalARP,the work by GMU Geotechnical was
reviewed in consideration with the objectives outlined by CalARP (California Accidental Release
Prevention Program).
The methods and findings by GMU were compared to the geotechnical guidelines found in the
CalARP Program Seismic Guidance Committee document,"Guidance for California Accidental
Prevention Program Seismic Assessment",dated September 2009.The CalARP guidelines
provide for a conservative level of assessment as they apply to the release of regulated substances
and potential consequences that may occur in the event of their release.The CalARP guidelines
have geographic jurisdiction over the site and were prepared for facilities similar to those found
on the subject site.It should be noted that the report by GMU does not refer to or intentionally
address the criteria outlined in the CalARP seismic assessment guidance document.
This review included research of published geotechnical documents,and a site reconnaissance.
Summaries of the findings from these tasks are provided.No subsurface exploration or testing
was performed as part of this review.This report was performed in concert with the Seismic Risk
Geotechnologies,Inc.
439 Western Avenue,Glendale,California 91201-2837·Tel:818.240.9600 •Fax:818.240.9675
www.geoteq.com
2-212
December 20,2012
File No.20278
Page 2
Review of Plains LPG Facility in San Pedro,California,by Strong Motions,Inc,dated April 17,
2012.
BACKGROUND
The basis for the CalARP Program is summarized in the following statement:"The objective of
the California Accidental Release Prevention (CalARP)program seismic assessment is to provide
reasonable assurance that the release to Regulated Substances (RS)as listed in California Code of
Regulations (CCR)Title 19 Division 2 Chapter 4.5 having offsite consequences (caused by a loss
of containment or pressure boundary integrity)would not occur as a result of an earthquake"
(CalARP,1999).The CalARP program guidelines are narrow in scope than those in the
California Building Code whose purpose is to "establish the minimum requirements to safeguard
the public health,safety and general welfare through structural strength...safety to life and
property from fire and other hazards attributed to the built environment..."
The CalARP document "Guidance for California Accidental Release Prevention (CaIARP)
Program Seismic Assessments prepared by the CalARP program Seismic Guidance Committee"
(CalARP,2009),provides criteria for evaluation the geotechnical and seismic aspects of a site.In
order to meet the objective that release of regulated substances would not occur as a result of an
earthquake,the guidelines provide several performance criteria for structures and systems:
Maintain structural integrity,
•Maintain position,
•Maintain containment of material and,
•Function immediately following an earthquake.
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December 20,2012
File No.20278
Page 3
Since these criteria are of interest for the on-site structures,the recommendations set forth in the
CalARP guidelines should be considered appropriate for the type of facilities constructed on the
subject site.
The subject site was developed in the early 1970's,prior to the existence of the CalARP
Guidelines.The CalARP guidelines recognize facilities that were constructed to earlier building
codes.For facilities that were constructed to the 1985 Uniform Building Code and earlier,the
document states "there were no specific seismic code requirements for non-building structures
and non-structural components in heavy industrial applications and they were rarely reviewed and
inspected by building departments ..."Since 1998 the seismic assessment study has been a
necessary requirement of the State's CalARP program reports.In general,the performance
objectives for new facilities are more restrictive that those for existing facilities.The guidance
document recognizes the disparity in design and construction requirements between old and new
facilities by suggesting "any regular inspecting and repair of systems containing regulated
substances should make them significantly safer than similar systems for which these steps are
not taken."
SITE DESCRIPTION
The site is located near the toe of the east side of Palos Verdes Hills at 211 0 North Gaffey Street
in San Pedro,California.The site is bordered by a petroleum tank farm to the north,warehouses
to the east,Westmont Drive to the south, and North Gaffey Street to the west.The site vicinity is
developed with a mix of industrial,commercial and residential properties.The site is shown
relative to nearby topographic features on the attached Vicinity Map.
Geotechnologles,Inc.
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December 20,2012
File No.20278
Page 4
The site was graded and construction commenced in 1971;construction was completed in 1972.
Based on photographs provided during the site visit,the site consisted of undeveloped,rolling
hills.
Elevations vary from 130 feet above mean sea level (msl)on the east side site of the site to 20 feet
above msl on the west side.Grading on the site has resulted in a moderately steep,westerly
descending,terraced slope.The slope ranges in elevation from 130 feet to approximately 40 feet
for a total height of 90 feet.The slope descends at a 1.5 to 1 gradient between terraces and a 1.75
to 1 gradient average gradient over the entire slope.Graded terraces support several small one
structures and one two story structure.Several berms are placed around to deflect and contain
liquids in the event of releases and to contain rainfall runoff.The slopes are vegetated with
annual grasses.Detailed site topography is shown on the attached Plot Plan 1 and Plot Plan 2.
The site is developed with the following above-ground tanks:
•Two,13,OOO,OOO-gallon refrigerated butane tanks (labeled as T-1 and T-2 on the attached
Plot Plans),
Three,20,000-gallon propane tanks,
•Three,20,000-gallon butane tanks,
•One,3,500-gallon Ethyl Mercaptan tank,
Two,127-gallon Accumulators (V-17 and V-Z8),
•One,509 cubic foot knock out butane Tank (V -19),
•One truck loading rack and a Railcar Loading Rack.
Due to their large capacity,the two atmospheric,refrigerated butane tanks are the focus of this
assessment.The butane tanks are located on two separate,relatively flat terraces at elevation 50
feet (Butane Tank T-1)and 40 feet (Butane Tank T-2).A large,soil-bermed containment basin is
located on the west side of the two large butane tanks.The butane tanks are located
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December 20,2012
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Page 5
approximately 20 feet from the toe of the high westerly-descending slope and approximately 50
feet from the top of the containment basin slope.
The containment basin measures approximately 90 by 160 feet at its base,and is over 20 feet deep
with slopes that are inclined at a 1.5 to 1 gradient (horizontal to vertical).The slopes are covered
with an asphalt emulsion and the bottom is vegetated with annual grasses.The bottom of the
containment area ranged from elevation 20.7 to 24.5 feet.
LOCAL GEOLOGY
The site is located in the San Pedro Hills near the northeast side of Palos Verdes.Palos Verdes is
large hill in the Los Angeles Basin that has been uplifted due to compression by nearby faults.
The basement rock underlying Palos Verdes is the Catalina Schist and is found at a relatively
shallow depth of less than 1 kilometer.Overlying the basement rock are Miocene sedimentary
rocks with various Pleistocene-age,poorly-consolidated sediments.The subject site is underlain
by Quaternary alluvium,San Pedro Sand and old,uplifted alluvium (Dibblee,1999).A copy of
the geologic map by Dibblee is attached to this letter as "Local Geologic Map (Dibblee,T.W.)".
Earlier geologic mapping work by Woodring,Bramlette,and Kew (1946)is attached as "Local
Geologic Map (Woodring,W.P.,et al)".The map by Woodring,Bramlette,and Kew shows
geologic materials of similar composition to those indicated on the geologic map by Dibblee.The
map also shows the topography of the site vicinity prior to development.
GMU Geotechnical drilled two borings located at the top of the hill on the east comer of the
property and DH-2 located at the toe of the hill between Tanks T-l and T-2.DH-I was drilled to
100 feet below the ground surface (bgs).DH -2 was drilled to a depth of 50 feet bgs.
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December 20,2012
File No.20278
Page 6
Review of the boring logs indicate 12 feet of artificial fill at the top of the westerly-descending
slope.The fill is composed of poorly graded sand that is damp,dense,massive and has no
cementation.
The San Pedro Formation underlies the fill in Boring DH-l and was identified at the ground
surface in DH-2.The San Pedro Formation is described as poorly graded sand that is dense,
moist and without cementation.In Boring DH-l,drilled at the top of the slope,silty sand and
sandy silt were identified between the depths of 70 to 90 feet bgs,which in tum is underlain by
poorly graded sand.
Water was not identified in the 100 foot deep boring,DH-I.The ground surface of this boring
was 120 feet,therefore the boring terminates at an elevation of 20 feet above mean sea level.
Boring DH-2 was drilled at a surface elevation of 50 feet above mean seal level to a depth of 50
feet bgs.Water was identified at a depth of 37.3 feet bgs which correlates with an elevation of
12.7 feet above mean sea level.Therefore,the water surface is approximately 27.3 and 37.3 feet
below the Tanks T-l and T-2,respectively.
According to Seismic Hazard Zone Report for the Torrance 7.S-Minute Quadrangle (CDMG,
2006),the historically highest groundwater is approximately 10 feet below the ground surface at
Gaffey Street.The ground surface elevation of Gaffey Street is near elevation 28 feet above mean
sea level,therefore the historically highest groundwater elevation is at 18 feet above msl.Since
the water surface is relatively planar and horizontal in the granular San Pedro Formation sand,the
historically highest ground water surface can be projected to the containment basin and Tanks T-l
and T-2.The depth to the historically highest groundwater surface beneath these features is
summarized in the following table.
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December 20,2012
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Page 7
Feature Ground Surface Elevation of Depth to HHGW
Elevation Historically Highest (feet bgs)
(feet above msl)Groundwater
(feet above msl)
Tank T-1 50 18 32
Tank-T-2 40 18 22
Containment Basin 23 18 5
Faults
The site'is not underlain by the surface trace of any known faults.A generalized map showing
regional faults is attached as Southern California Fault Map.The Local Geologic Map (Dibblee,
T.W.)shows the nearest fault to the subject site is the "inferred position of the Palos Verdes
Fault".This fault is located 400 feet northeast.
An Earthquake Fault Zone is designated if the State of California deems a fault to have a
relatively high potential for ground rupture.The criteria for such zoning is if a fault has evidence
of surface displacement in the last 11,000 years (sufficiently active)and if the fault trace is
clearly detectable by a trained geologist as a physical feature (well defined).The Palos Verdes
Fault has not been designated by the California Geological Survey (CGS)with an Earthquake
Fault Zone (Hart and Bryant,2008).
In 1972,the Alquist-Priolo Special Studies Zones Act (now known as the Alquist-Priolo
Earthquake Fault Zoning Act)was passed into law.The Act defines "active"and "potentially
active"faults utilizing the same aging criteria as that used by California Geological Survey
(CGS).However,established state policy has been to zone only those faults which have direct
evidence of movement within the last 11,000 years.It is this recency of fault movement that the
CGS considers as a characteristic for faults that have a relatively high potential for ground rupture
in the future.
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The Palos Verdes Fault is considered to have been active in Holocene time (last 11,000 years).
The fault is oriented in a northwest-southeast direction and has a left-lateral,strike-slip motion.
Recent work suggests that the fault has slip rate of 2.7 to 3.0 mm/yr.and is capable of an Mw
event of7.0 to 7.2 at an interval of 400 to 900 years (McNeilan,T.W.,et.aI,1995).
The nearest CGS-designated Earthquake Fault Zone is for the Newport Inglewood Fault,located
6.6 miles to the northeast.A map showing the site location relative to the nearest Earthquake
Fault zone is attached to this letter as "Earthquake Fault Zone Map".
SITE VISIT
A site visit was performed on February 10,2012 to observe the site conditions and meet with the
facility operators.The site visit consisted of a walk-through of the entire facility,including the
top of the eastern slope,the bottom of the containment basin,as well as review of construction
documents and photos available in the office.The purpose of the site visit was to observe
geotechnical-related issues such as the conditions of slopes,indications of settlement or instability
at the ground surface,the condition of observable of footings,drainage-related installations and
general maintenance of the drainage facilities.
The site visit was performed in the presence of repres.entatives from the following entities:
•United States Environmental Protection Agency (Region IX)
•Strong Motions Inc.
Plains All-American
•Rancho LPG Holding,LLC
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The site reconnaissance was led by personnel of Plains All-American and they permitted access to
all locations requested by this firm and Strong Motions,Inc.The site appeared to be generally
well maintained and organized.Work was being performed during the site visit to drain one of
the large butane tanks for scheduled maintenance of the tank.The following paragraphs
summarize the geotechnical-related observations by this firm.
Slopes-Containment Basin
The purpose of the containment basin is to capture butane (as a liquid)should any escape from
Butane Tanks T-1 or T-2 resulting from catastrophic failure.The containment basin is labeled on
the attached Plot Plan 1 (East).The containment area consists of an enclosed pit measuring 180
feet by 320 feet at its base with slopes that range in height from 15 to 25 feet and are inclined at a
1.5 to 1 gradient (horizontal to vertical).The slopes are covered with an asphalt emulsion.
Cracks up to 1Yz inches in width in the emulsion appear near the top of the slopes.Holes and soil
piles from ground-burrowing rodents were observed on the surface of the asphalt emulsion at
several locations of the containment basin.No scarps or deformations in the slopes suggestive of
a previous or incipient failure were noted.
The bottom of the containment basin is unlined and vegetated with grasses.In order to permit the
drainage of storm runoff water from the basin,an outlet drain is located near the southwest
corner.The drain consists of a 16-inch diameter,corrugated,metal pipe.It is the understanding
of this firm that the pipe discharges to the storm drain system on North Gaffey Street.No device
exists to contain liquid butane (or other released substance)from entering the drain in the event of
discharge by the tanks.However,a control valve near Gaffey Street controls the flow of
stormwater and,in the event of a liquid release into the storm drain system.
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Slopes -East Side of Tanks T-1 and T-2
The slopes rise to the east from 75 to 90 feet above the base of tanks.The slopes were cut during
mass grading of the site around 1973 and have concrete lined terrace drains at approximately 25
foot vertical intervals.The terrace drains discharge to concrete-lined downdrains.The slopes
expose light brown silty sand that is consistent with the descriptions found on the attached
geologic maps.The slopes are vegetated with annual grasses.No indications of instability such
as cracked and displaced terrace drains,hummock topography,or surficial scars on the slopes
were noted.
Area Drains
It was noted that the surficial drains that collect rainfall runoff from the terraces at Tanks T-1 and
T-2 were partially filled with sediment that will impede drainage of the runoff.The sediment
needs to be removed as part of regular maintenance of the site.
Ring Foundation for Tanks T-1 and T-2
The foundation appeared to be in good condition with no cracks greater than hairline in width
noted.
Flare Stack
A flare stack is located near the southeast comer of the site near the top of the 90 foot high,
westerly-descending slope.The foundations for the flare stack have been recently upgraded.The
concrete foundation of the flare stack appeared to relatively new and uncracked.The ground
surface around the flare stack did not exhibit indications of slope instability such as cracks,
ground settlement,or surficial scars.However,evidence of rodent activity was noted nearby.
Rodent burrows will directly reduce the stability of a slope and permit pathways for water
infiltration that will further destabilize a slope.
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REVIEW OF EVALUATION BY GMU GEOTECHNICAL
The purpose of the evaluation by GMU Geotechnical,Inc.(GMU,2010)was to respond to
questions by raised by the EPA following a review of a seismic hazard assessment report
completed by ABS Consulting (ABS,2010).The EPA raised questions about the facility
concerning the findings found in the ABS.The facility operator commissioned a follow-up
evaluation by GMU to respond to the EPA's questions.Geotechnologies,Inc.has not attached a
copy of the email correspondence between the EPA and the facility operator concerning the ABS
report.However,the questions are repeated in the report with the consultant responses
immediately following.The issues that were addressed in the report include:
•Field exploration
Laboratory testing
•Site specific seismic parameters
Stability analysis of on-site slopes
•Liquefaction potential
General commentary of the work by GMU as well as correlation of the work to the CalARP
seismic guidance document follows.
Field Exploration
The field exploration by GMU included drilling and sampling two borings to depths of 50 and
100 feet with a hollowstem auger,and three soundings to depths ranging from 37 to 50 feet with a
cone penetrometer.Soil samples taken from the borings were tested for various soil properties.
Three of the explorations (DH-1,DH-2,and CPT-I)were performed either at the toe or the top of
the west-descending slope near the tanks T-1 and T-2.The remaining two explorations were
conducted in the vicinity of the office,located near the northeast comer of the site.
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Comment 1:No borings were drilled between the butane tanks and the containment area slope
by GMU.As mentioned in the Local Geology section of this report,groundwater
was identified at an elevation of 12.8 feet above msl in Boring DH-2.This
elevation corresponds to a depth of 10.2 feet below the ground surface at the
bottom of the containment basin.Additional investigation is warranted to
characterize the soils comprising the slope between the containment basin and the
butane tanks.This information should be used to address comments found later in
this review.
One of ~he CPT soundings (CPT-3)was excavated near the office building to a depth of 50 feet.
This sounding was used to obtain the value V s30 that is used in a later calculation for the site
specific ground motion hazard analysis.The value obtained for Vs30 was 510 ft.Isecond (155
m/s).
Comment 2:The value obtained 155 m/s is considered by this firm to be low for the San Pedro
sand.Based on the research by Tinsley and Fumal (1985)a higher velocity value
may be appropriate.The value of Vs30 should be based on measurements from
the upper 100 feet of soils and therefore may yield a higher value.It is
recommended that a shear wave velocity measurement to a depth of 100 feet be
obtained by either a CPT sounding or a downhole measurement in a boring.
Laboratory Testing
The selection of tests appears appropriate and the tabulated results appear reasonable.However,
the soil samples were not obtained from the location between the butane tanks and containment
area.
Comment 3:Additional geotechnical tests of the soils obtained from the recommended
boring(s)between the butane tanks and the containment basin are warranted.The
results should be used to respond to comments that appear later in this review.
Comment 4:It is not stated in the evaluation if the direct shear tests on the San Pedro Sand were
performed at field moisture or saturated conditions.The tests should be run under
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saturated conditions and the results utilized in the slope stability calculations as
appropriate.Saturated conditions can occur during extended period of rainfall and
represent the most critical soil moisture state from the standpoint of soil strength.
Site-Specific Seismic Parameters
Site-specific seismic parameters were calculated using the US Geological Survey computer
program,Ground Motion Parameter Calculator (Version 5.0.09a).The results were used in the
calculation of seismic slope stability and for liquefaction analyses.
Comment 5:According to the CalARP guidance manual,the procedure of ASCE 7-05,Chapter
21 should be used for site-specific,ground motion hazard assessments. The more
detailed and site specific procedure of ASCE 7-05 Chapter 21 be followed.
Comment 6:The site is located 400 feet from the Palos Verdes Fault which has a recurrence
interval of 400 to 900 years (McNeilan,T.W.,et.aI,1995).As a result of this
proximity and recurrence interval,the near source directivity option should be used
when performing the site specific analysis of ASCE 7-05 chapter 21.
Comment 7:The Vs30value used in the analysis should be derived from a site-specific
measurement that extends to a depth of 100 feet as mentioned in Comment 2.
Slope Stability -Westerly Descending Slope above Butane Tanks
GMU Geotechnical performed a slope stability analysis along Cross Section 2-2'that shows the
profile of the westerly descending slope through Butane Tank T-1.
Comment 8:A slope stability analysis should also be performed through the westerly-
descending slope and Butane Tank T-2.The slope is 15 feet higher and may be
more critical.A new cross section perpendicular to the slope face that would be
the most critical section should be drawn.
Comment 9:The pseudo static slope stability analysis should be performed using the results
from an updated seismic hazard analysis described in Comment 5.
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Comment 10:The summary page of the slope stability analyses (pages Cl and C2)identifies the
seismic displacement of the high slope on the east side of the site to be 7 inches
and 8 inches.GMU Geotechnical concluded the tanks located at the toe of the
slope are not likely to be impacted by the slope displacement.It should be noted
that the values yielded by the methodology used (Bray,2007)are not actual
displacement distances but should be used as an index of performance (Blake,
Hollingsworth and Stewart,2002).The calculated index value (7 and 8 inches for
a slope 75 to 90 feet high)is significant,and should be addressed.
Slope Sfability-Westerly Descending Slope of Containment Area,Below Butane Tanks
GMU Geotechnical performed a slope stability analysis along Cross Section 2-2'that shows the
profile of the westerly-descending slope through Butane Tank T-l.The analyzed cross section
includes a portion of the Butane Tank.
Comment 11:The cross section used in the analysis is not oriented perpendicular to the slope to
yield the most conservative value for Factor of Safety.The cross section should be
redrawn and to include the steepest slope orientation.
Comment 12:Based on the information provided in the report,it does not appear stability
analysis was performed that considers the surcharge caused by the butane tank
with contents.A new analyses should consider the surcharge on the slope caused
by a tank at operational capacity.
Comment 13:As mentioned in Comment 4,it is unknown if the soil strength obtained from the
direct shear testing was performed under saturated conditions.A saturated shear
strength should be used in light of the shallow depth to groundwater table beneath
the containment basin.
Comment 14 A large fill wedge is shown on the cross sections used for the stability analysis on
the east face of containment basin.The geometry of the fill wedge is likely based
on review of a Grading Plan cited in the references.Subsurface explorations
should be performed to identify the properties of the fill soil comprising this slope
as addressed in Comment 1.
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Comment 15:The groundwater elevation shown on the slope stability analysis Cross Sections
(Figure C-8.1)is approximately coincident with the groundwater depth identified
in the borings by GMU Geotechnical.Review of the Seismic Hazard Report for
the Torrance 7.5-Minute Quadrangle (CDMG,2006)suggest that groundwater
may reach an elevation of 20 feet.The stability analysis (and lateral spreading)
analysis should consider the groundwater at this higher elevation.
Comment 16:The data input file from the computer program should be included for all analyses
results.
Liquefaction
The potential for liquefaction was addressed at the locations near the base of the westerly
descending hill (CPT-I)and near the office building (CPT-2 and CPT-3).The values in the
analysis using a peak ground acceleration ofO.5g which appears adequate.
Comment 17:The potential for liquefaction in the containment basin should be addressed since
the basin is downslope of Butane Tanks T-l and T-2 and the historically highest
groundwater level is shallow in this area (less than 5 feet below the ground
surface).Additional boring(s)and laboratory analyses in the containment area and
adjacent berm will be necessary.
Lateral Spreading
Lateral spreading is a seismic related phenomenon that occurs to gently sloping ground with a
free face when layers of geologic materials are liquefied and move in a downslope direction.This
hazard was not addressed in the evaluation.
Comment 18:This hazard should be addressed according to the CalARP guidance document.
The analysis should also be performed in the containment area,below the Butane
Tanks T-l and T-2.The borings and analyses identified in Comment 18 may be
used for this purpose.
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Seismic Settlement
Seismic settlement occurs when loose dry,cohesionless soils settle as a result of seismic shaking.
This hazard is listed in the Ca1ARP guidance document,but was not addressed in the referenced
evaluation.
Comment 19:Analysis for these phenomena should be performed for the soil column in the
vicinity of the butane tanks,to the depth of the current ground water surface.
RECOMMENDATIONS BASED ON THE SITE VISIT
Based on the observations made by this firm during the site visit,the following geotechnical-
related maintenance recommendations are provided but are unrelated to the review by GMU.The
items listed are not listed in the Cal-ARP document but are prudent maintenance practices,and
should be addressed by the site owner.
Item 1:
Item 2:
Item 3:
Item 4:
Several slope areas were noted to have evidence of burrowing rodents.The
burrows will degrade the strength of the materials comprising the slope as well as
provide avenues for water infiltration.An eradication program for the rodents
should be implemented.
The asphalt emulsion that lines the containment area was observed to have cracks
up to 1Y2 inches wide.The cracks should be filled with new emulsion to prevent
rainfall runoff from entering the cracks.
Two area drain inlets that collect water from butane Tank T-1 and T-2 terraces
were partially filled with sediment.These storm drains should be cleaned of the
debris to restore full capacity.
The site maintenance program should include regular observations and cleaning 00
repair,as needed,of all area drains,terrace drains and asphalt emulsion surfaces.
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Item 5:
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The design of the storm water outlet at the southwest comer of the containment
basin should be checked.Also,the valve near Gaffey Street should be included on
a maintenance program.
CONCLUSION
Although the GME report addressed some the data collection and analysis requirements for a
seismic hazard analysis found in the Guidance for CalARP Program Seismic Assessments
document,some analysis critical for the evaluation of the seismic hazards at the site were not
addressed as described in this review.
CLOSURE AND LIMITATIONS
The purpose of this review is to aid in the analysis of the described facility.Implementation of
the advice presented in this report is intended to reduce certain risks.The professional opinions
and geotechnical advice contained in this report are sought because of special skill in engineering
and geology and were prepared in accordance with generally accepted geotechnical engineering
practice.Geotechnologies,Inc.has a duty to exercise the ordinary skill and competence of
members of the engineering profession.Those who hire Geotechnologies,Inc.are not justified in
expecting infallibility,but can expect reasonable pro~essional care and competence.
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REFERENCES
ABS Consulting,January 13,2010,Tank Assessment Report of Compliance with CaIARP,Plains
Midstream Canada LPG Storage Plant in San Pedro California,Project No.2278018.
Abrahamson,N.A.,2000,Effects of Rupture Directivity on Probabilistic Seismic Hazard
Analysis,Proceedings of 6th International Conference on Seismic Zonation,Palm Springs.
Boore,D.M.,Atkinson,G.M.,2008,Boore-Atkinson NGA Ground Motion Relations for the
Geometric Mean Horizontal Component of Peak and Spectral Ground Motion Parameters,
Pacific Earthquake Engineering Research Center,PEER 2007/01.
Blake,T.F.,Hollingsworth,R.A.,and Stewart,1.P.,editors,2002.Recommended Procedures
~or Implementation of DMG Special Publication 117 Guidelines for Analyzing and
Mitigating Landslide Hazards in California,Southern California Earthquake Center,
University of Southern California.
Bray,J.D.and T.Travasarou,"Simplified Procedure for Estimating Earthquake-Induced
Deviatoric Slope Displacements,"Journal of Geotechnical and Geoenvironmental
Engineering,ASCE,April 2007,Vol.133,No.4,pp.381-392,doi:O.l0611(ASCE)1090-
0241 (2007)133:4(381).
CalARP Seismic Guidance Committee,September 2009,Guidance for California Accidental
Release Prevention (CaIARP)Program Seismic Assessments,Prepared for the
Administering Agency (AA)subcommittee,Region I Local Emergency Planning
Committee (LEPC)/43 pages.
California Department of General Services,Division of the State Architect,2009,Use of Next
Generation Attenuation (NGA)Relations,DSA Bulletin 09-01.,issue date January 26,
2009,Effective Date March 1,2009.
California Division of Mines and Geology,1999,Sei~mic Hazard Zones,Torrance Quadrangle.
California Division of Mines and Geology,1998,revised 2006,Seismic Hazard Zone Report for
the Torrance 7.5 Minute Quadrangle,Los Angeles County,California,Seismic Hazard
Zone Report 03529.
Campbell,K.W.,and Bozorgnia,Y,2008,Campbell-Bozorgnia NGA Ground Motion Relations
for the Geometric Mean Horizontal Component of Peak and Spectral Ground Motion
Parameters,Pacific Earthquake Engineering Research Center,PEER 2007/02.
Geotechnologies,Inc.
439 Western Avenue,Glendale,California 91201-2837·Tel:818.240.9600 •Fax:818.240.9675
www.geoteq.com
2-229
REFERENCES -continued
Chiou,B.S.,Youngs,RR.,2008,Chiou and Youngs PEER_NGA Empirical Ground Motion
Model for the Average Horizontal Component of Peak Acceleration and Pseudo Spectral
Acceleration for Spectral Periods of 0.01 to 10 Seconds,Pacific Earthquake Engineering
Research Center,PEER 2008.
Dibb1ee,T.W.,Jr.,1999,Geologic Map of the Palos Verdes Peninsula and Vicinity,Dibblee
Foundation Map #Df-790.Map scale 1:24,000.
Fumal,TE.,Tinsley J.C.,1985,Mapping Shear Wave Velocities of Near-Source Geologic
Materials,in Evaluation Earthquake Hazards in the Los Angeles Region-An Earth
Science Perspective,U.S.Geological Survey Professional Paper 1360,Ziony,J.1.ed.,pp
126-149.
GMU Geotechnical,Inc.July 19,2010,Geotechnical Seismic Evaluation,Rancho LPG Holdings
Facility,2110 North Gaffey Street,San Pedro,California,Prepared for Rancho LPG
Holdings,LLC.GMU Project No.1 0-069-00.
Hart,E.W.,Bryant,W.A.,2008,Fault-rupture Hazards Zones in California,Alquist-Priolo
Earthquake Fault Zoning Act,with index to Earthquake Fault zone Maps, California
division of Mines and geology,Special Publication 42.
Huang,Y.-N,Whittaker,A.A.,and Luco,N.,2008,Performance Assessment of Conventional and
Base-Isolated Nuclear Power Plant for Earthquake and Blast Loadings,MCEER-08-0029,
Multi-Disciplinary Center for Earthquake Engineering Research,State University of New
York,Buffalo,NY;
McNeilan,T.W.,Rockwell,T.K.,Resnick,G.S.,1995,Style and rate of Holocene Slip,Palos
Verdes Fault,Southern California,Journal of Geophysical Research,Vol.101,No.4,
pages 8317 to 8334.
Risk Engineering Software,2007,EZ-FRISK,Software for Earthquake Ground Motion
Estimation,Version 7.62.
Somerville,P.G.,et aI.,1997,Modification of Empirical Strong Ground Motion Attenuation
Relations to Include the Amplitude and Duration Effects of Rupture Directivity,
Seismological Research Letters,Volume 68,Number 1,pp.199.
Geotechnologles,Inc.
439 Western Avenue,Glendale,California 91201-2837·Tel:818.240.9600 •Fax:818.240.9675
www.geoteq.com
2-230
REFERENCES -continued
State of California,Office of Stateside Health Planning and Development,2008,Next
Generation Attenuation Relations for Use with the 2007 California Building Code,Code
Application Notice 2-1802A.6.2,Effective date 9/30108.
Tinsley,J.C.,and Fuma1,T.E.,1985,Mapping Quaternary Sedimentary Deposits for Areal
Variations in Shaking Response,in Evaluation Earthquake Hazards in the Los Angeles
Region-An Earth Science Perspective,U.S.Geological Survey Professional Paper 1360,
Ziony,J.1.ed.,pp 101-125.
United 'States Geological Survey,2010,Ground Motion Parameter Calculator (Version 5.1.0),
[http:///earthquake.usgs.gov/research/hazmapsldesign/].
United States Geological Survey,2008,Interactive Deaggregations (Beta),
[https:llgeohazards.usgs.gov/deaggint/2008/].
Wells,D.L.and Coppersmith,K.J.,1994,New Empirical Relationships among Magnitude,
Rupture Length,Rupture Width,Rupture Area,and Surface Displacement,Bulletin of
Seismological Society of America,Vol 84,pp 974-1002.
Woodring,W.,Bramlette,M.N.,Kew,W.S.W.,1946,Geology and Paleontology of Palos
Verdes Hills,California,United States Geological Survey,Professional Paper 207.
Yerkes,RF.,et al.1965,Geology of the Los Angeles,Basin,California-An Introduction,U.S.
Geological Survey Professional Paper 420-A.
Geotechnologies,Inc.
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REFERENCE:U.S.G.S.TOPOGRAPHIC MAPS,7.5 MINUTE SERIES,
TORRANCE,CA QUADRANGLE
VICINITY MAP
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SAle -SAN PEDRO
20278
May '12
t~,-
#\V "..,
SCALE IN FEET__-=::::3_-=
,......,~~i
o 80 160
FileNo.:
Date:
PLOT PLAN 1 •(WEST)
Geotechnologies,Inc.
Consulting Geotechnical Engineers
REFERENCE:ALTA!ACSM LAND TITLE SURVEY BY DULIN AND BOYNTON
DATED 1'1/12/08
2
-
2
3
3
~,-
w
I
__~~L;;.;CALE;;.:IN FEET_--------.,o 80 160
REFERENCE:ALTA/ACSM LAND TITLE SURVEY BY DULIN AND BQYNfON
DATED 11/1l/OS A"i,!,I
i
Geotechnologies,Inc.
Consulting Geotechnical Engineers
PLOT PLAN 2 •(EAST)
SAle -SAN PEDRO
File No.:20278
Date:May "12
2
-
2
3
4
~
N
SCALE IN FEET
If 1000 2000 4000
LEGEND
af:Arliliciallill or cut and Iill
Qs:Beach Sediments·Sand to cobble-boulder gravel
Qa:Alluvium·Mostly loamy clay
Qae:Alluvium·Similar to Qa,but slightly elevaled and locally disected
QIs:Landslide debris·Mostly of Monterey shale
Qoa:Older Alluvium -Non-Marine terrace cover,sandy loam,and loamy clay
Qsp:San Pedro Sand·Sand and pebble gravel
Tmg:Malaga Mudstone -Mudstone with diatomaceous strata and limestone concretions
Tmv:Monterey Fonnation:Valmonte Diatomite -Sahle and mudstone
Tma:Monterey Formation:AIlamira Shale·Upper part
Tmal:Monterey Formation:AIlamira Shale·Upper parl
_H..T Fault -dashed where indefinite or inferred,dotted where concealed,
queried where existence is doubtful
LOCAL GEOLOGIC MAP
DIBBLEE,T.W.
Jl Beotechnologies,Inc.~Consulting Geotechnical Engineers
sAle -SAN PEDRO
FILE No.20278
D1BBLEE.T.W.,(1999J,MAP #DF·70.GEOLOGIC MAP OF THE PALOS VERDES PENINSULA AND VICINITY DATE:May '12
2
-
2
3
5
o
N
SCALE IN FEET
C !o 1000 .1000 4000
LEGEND
Qal:Alluvium and artificial fill
Qgr:Stream terrace gravel
Qtc:Nonmarine terrace cover
Qpv:Palos Verdes sand
Qsp:San Pedro sand
QI:Lomita marl
Tm:Malaga mudstone member
Tv:Valmonte diatomite member
Ta:Altamira shale member
LOCAL GEOLOGIC MAP
WOODRING.W.P.•ET AL
Jl Beotechnologies,Inc.~Consulting Geotechnical Engineers
sAle -SAN PEDRO
FILE No.20278
WOODRING,W.P.,BRAMLETTE,M.N.,KEW.W.S.W..(1946).GEOLOGIGMAP AND SECfIONS OF PALOS VERDES HILLS DATE:May '12
2
-
2
3
6
ONE MILE
SCALE
/10,-""Depth to groundwater in feet
REFERENCE:CDMG,SEISMIC HAZARD ZONE REPORT,035
TORRANCE 7.5 •MINUTE QUADRANGLE,LOS ANGELES COUNTY,CALIFORNIA (1998,REVISED 2006)
HISTORICALLY HIGHEST GROUNDWATER LEVELS
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~~
o
Scale in Miles
1/2
EARTHQUAKEFAULTZONE~
REFERENCES:SPECIAL STUDIES ZONES,LONG BEACH QUADRANGLE,CDMG,1986
SPECIAL STUDIES ZONES,TORRANCE QUADRANGLE,CDMG,1986 !Geotechnologies,Inc.
Consulting Geotechnical Engineers
0---0 Earthquake Fault Zones
Alquist-Priolo Earthquake Fault Zone
sAle -SAN PEDRO
FILE NO.20278
2
-
2
3
8
/(
~I.Lancaster
;
!\
1 Alamo thrust 21 Helendale fault
2 Al'rowhead fault 22 Hollywood fault
3 Bailey fault 23 Holser fault
4 BIg Mountain fault 24 Lion Conyon fault
5 Big Pine fault 25 Llano fault
6 Blake Ranch fault 26 Los Alamitos tault
7 Cabrilio fault 27 Malibu Coast taull
8 Chatsworth fault 28 Mint Canyon faull
9 Chino faull 29 Mirage Valley faull zone
10 Clarnshell-SOwpit faull 30 Mission Hills faull
11 Clearwater fault 31 Newport Inglewood taull zone
12 Cleghorn fault 32 North Frontal faull zone
13 Crallon Hills tault zone 33 Northridge Hills fault
14 Cucamonga faull zone 34 oak RIdge fault
15 Dry Creek fault 35 Palos Verdes faull zone
16 Eagle Rock fault 36 Pelona faull
17 EI Modena fault 37 Peralla Hills faull
18 Frazier Mountain thrust 38 Pine Mountain fault
19 Garlock fault zone 39 Raymond faull
20 Grass Valley faull 40 Red Hili (Eflwanda Ave)fault
REFERENCE:hffp:!Iposadena.wr.usgs.gov/lnfo!lmagesJLA%20Faults.pdf
41 Redondo Canyon fault
42 SOn Andreas Fault
43 San Antonio fault
44 San Cayetano fault
45 SOn Fernando fault zone
46 SOn Gabriel faull zone
47 San Jacinto fault
48 SOn Jose tault
49 SOnta Cruz-Santa Catalina Ridge f.z.
50 SOnta Monica fault
51 Santa Ynez faull
52 SOnta Susana faull zone
53 Sierra Madre faull zone
54 Simi fault
55 SOledad Canyon faull
56 Stoddard Canyon tault
57 Tunnel Ridge taull
58 Verdugo tault
59 Waterman Canyon faull
60 WhIffler taull
SOUTHERN CALIFORNIA FAULT MAP
SAle -SAN PEDROGeotechnologies,Inc.
Consulting Geotechnical Engineers FILE No.20278 FIGURE I
2-239
2-240
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2-241
Kit Fox
From:
Sent:
To:
SUbject:
Carolynn Petru
Wednesday,January 02,20139:47 AM
Kit Fox
FW:EPA-R9-2013-001262 Geo-technical Report for Rancho LPG
From:Janet Gunter [mailto:arrianeS@aol.com]
Sent:Wednesday,January 02,20139:18 AM
To:connie@rutter.us;det310@juno.com;jody.james@sbcglobal.net;MrEnvirlaw@sbcglobal.net;noelweiss@ca.rr.com;
chateau4us@att.net;CC
Subject:Fwd:EPA-R9-2013-001262 Geo-technical Report for Rancho LPG
Carl is a professional "risk analysis expert"......
-----Original Message-----
From:Carl Southwell <carl.southwell@gmail.com>
To:Janet Gunter <arriane5@aol.com>
Sent:Wed,Jan 2,2013 8:59 am
Subject:Re:EPA-R9-2013-001262 Geo-technical Report for Rancho LPG
Hi Janet,
The report,in summary,states "It should be noted that the report by GMU does not refer to or intentionally address the
criteria outlined in the CalARP seismic assessment gUidance document.This review included research of published
geotechnical documents,and a site reconnaissance.Summaries of the findings from these tasks are provided.No
subsurface exploration or testing was performed as part of this review."(emphasis mine)
The takeaway is that subsurface exploration,testing,and analysis sufficient to comply with the CalARP seismic
assessment guidance document (see,e.g.,http://fire.lacountv.gov/HealthHazMat/PDFs/CaIARPGuidelndustrv.pdf)is
needed as part of the facility's RMP ...
It's amazing that pre-existing infrastructure gets a pass on so many regulations.
Carl
On Tue,Jan 1,2013 at 7:17 PM,Janet Gunter <arriane5@aol.com>wrote:
Dear Ms.Wong-
Thank you for prOViding this information.This long awaited information certainly underscores our reasons for extreme
concern and emphasizes the critical need for urgency regarding the safety and security of our public due to the presence
of this ultra hazardous facility.This report's direction for further analysis and evaluation of the geologic conditions of the
Rancho site should be assigned to an "uninterested party"immediately in the interest of pUblic safety.An obvious area of
discrepancy is the lack of acknowledgement of the LPG facility site as being in an "Earthquake Rupture Zone"as clearly
defined in official LA City Planning Department documents.How ...and why...would that not be acknowledged?However,
there are many other very serious issues regarding soils and geologic conditions that remain reported in this document.
We are still awaiting the correspondence between the EPA and Rancho that was requested months ago.In particular,is
a letter referenced by the manager of Rancho LPG,Ron Conrow,at a Rancho Palos Verdes City Council meeting over 4
months ago..Please provide this correspondence at your earliest convenience.It is important for our public to
understand the dialogue that has been conducted between the operators of Rancho and your agency.
Thank you for your time and cooperation.
Janet Gunter
-----Original Message-----
From:Wong.Jeannie <Wong.Jeannie@epamail.epa.gov>
1
2-242
To:arriane5 <arriane5@aol.com>
Cc:Simmons.Joan <Simmons.Joan@epamail.epa.gov>
Sent:Mon,Dec 31,201212:02 pm
Subject:EPA-R9-2013-001262
Hi Ms.Gunter:
Attached is our response to your FOIA Request EPA-R9-2013-001262 regarding "Geotechnical analysis performed by the
EPA on Rancho LPG".
Regards,
Environmental Protection Agency
Superfund Division
Jeannie Wong
(415)972-3079
Email:wong.jeann.ie@epa.gov
Please open the attached document.It was scanned and sent to you using a Xerox
WorkCentre.
Attachment File Type:PDF,Multi-page
WorkCentre Location:USEPA Region 9,8th Floor,Room R8102
Device Name:PN_R8102_Xerox5755 PS
For assistance,please call IRM helpline at 415-947-8023.Thanks .
•
•
Carl Southwell
Contact me at (use whichever you prefer):
carl.southwell@gmail.com
carl.southwell@usc.edu
My blog:anotheruniqueperspective.blogspot.com
Also visit:www.pressfriends.org
Making writing fun for elementary school kids,empowering kids to become mentors and leaders,and creating friendships
among youth from diverse backgrounds.
2
2-243
Kit Fox
From:
Sent:
To:
Subject:
Carolynn Petru
Wednesday,January 02,20139:47 AM
Kit Fox
FW:Fwd:EPA-R9-2013-001262 Geo-technical Report for Rancho LPG
From:Noel Weiss [mailto:noelweiss@ca.rr.com]
Sent:Wednesday,January 02,2013 9:25 AM
To:connie@rutter.us;det310@juno.com;jody.james@sbcglobal.net;MrEnvirlaw@sbcglobal.net;chateau4us@att.net;
CC;Janet Gunter
Subject:Re:Fwd:EPA-R9-2013-001262 Geo-technical Report for Rancho LPG
Connie:
I don't believe that it is lawful for the storm drain to go unprotected here...The report says on Page 9 that "no device
exists to contain liquid butane (or other released substance)from entering the drain in the event of a discharge by the
tanks .."
I haven't researched this down to the 'nth'degree,but my sense is that the City does have laws which require storm
drains to be protected from fluid contamination ...If so,Rancho is in violation ..Which is why I have encouraged Janet to
get this report out to the other City Attorney candidates and get their reaction ...In addition,the point (and the other
points raised in the report)need to be made in the response to the Draft EIR on Pointe Vista ..with a request that further
environmental review be undertaken,along with an objective tie-breaker'risk assessment analysis ...which can be
commented on by the public as part of the Pointe Vista EIR.
The Rancho Palos Verdes City Council also needs to follow-up and ascertain if Rancho ever met its commitment to
provide evidence of insurance to the RPV City Attorney...
That fact also needs to be cited in the Draft EIR since none of the Pointe Vista property owners are insured against
damages or personal injury occasioned by an accident at the Rancho facility.
Noel
(310)822-0239
From:Janet Gunter
Sent:Wednesday,January 02,2013 9:17 AM
To:connie@rutter.us ;det31O@juno.com ;jody.james@sbcglobal.net ;MrEnvirlaw@sbcglobal.net ;noelweiss@ca.rr.com
;chateau4us@att.net ;cc@rpv.com
Subject:Fwd:EPA-R9-2013-001262 Geo-technical Report for Rancho LPG
Carl is a professional "risk analysis expert"......
-----Original Message-----
From:Carl Southwell <carl.southwell@gmail.com>
To:Janet Gunter <arriane5@aol.com>
Sent:Wed,Jan 2,2013 8:59 am
SUbject:Re:EPA-R9-2013-001262 Geo-technical Report for Rancho LPG
Hi Janet,
The report,in summary,states "It should be noted that the report by GMU does not refer to or intentionally address the
criteria outlined in the CalARP seismic assessment guidance document.This review included research of pUblished
geotechnical documents,and a site reconnaissance.Summaries of the findings from these tasks are provided.No
subsurface exploration or testing was performed as part of this review."(emphasis mine)
1
2-244
The takeaway is that subsurface exploration,testing,and analysis sufficient to comply with the CalARP seismic
assessment guidance document (see,e.g.,http://fire.lacounty.gov/HealthHazMat/PDFs/CaIARPGuidelndustrv.pdf)is
needed as part of the facility's RMP.
It's amazing that pre-existing infrastructure gets a pass on so many regulations.
Carl
On Tue,Jan 1,2013 at 7:17 PM,Janet Gunter <arriane5@aol.com>wrote:
Dear Ms.Wong-
Thank you for providing this information.This long awaited information certainly underscores our reasons for extreme
concern and emphasizes the critical need for urgency regarding the safety and security of our public due to the presence
of this ultra hazardous facility.This report's direction for further analysis and evaluation of the geologic conditions of the
Rancho site should be assigned to an "uninterested party"immediately in the interest of public safety.An obvious area of
discrepancy is the lack of acknowledgement of the LPG facility site as being in an "Earthquake Rupture Zone"as clearly
defined in official LA City Planning Department documents.How ...and why...would that not be acknowledged?However,
there are many other very serious issues regarding soils and geologic conditions that remain reported in this document.
We are still awaiting the correspondence between the EPA and Rancho that was requested months ago.In particular,is
a letter referenced by the manager of Rancho LPG,Ron Conrow,at a Rancho Palos Verdes City Council meeting over 4
months ago..Please provide this correspondence at your earliest convenience.It is important for our public to
understand the dialogue that has been conducted between the operators of Rancho and your agency.
Thank you for your time and cooperation.
Janet Gunter
-----Original Message-----
From:Wong.Jeannie <Wong.Jeannie@epamail.epa.gov>
To:arriane5 <arriane5@aol.com>
Cc:Simmons.Joan <Simmons.Joan@epamail.epa.gov>
Sent:Mon,Dec 31,201212:02 pm
Subject:EPA-R9-2013-001262
Hi Ms.Gunter:
Attached is our response to your FOIA Request EPA-R9-2013-001262 regarding "Geotechnical analysis performed by the
EPA on Rancho LPG".
Regards,
Environmental Protection Agency
Superfund Division
Jeannie Wong
(415)972-3079
Email:wong.jeannie@epa.gov
Please open the attached document.It was scanned and sent to you using a Xerox
WorkCentre.
Attachment File Type:PDF,Multi-page
WorkCentre Location:USEPA Region 9,8th Floor,Room R8102
Device Name:PN_R8102_Xerox5755 PS
2
2-245
For assistance,please call IRM helpline at 415-947-8023.Thanks .
•
•
Carl Southwell
Contact me at (use whichever you prefer):
carl.southwell@gmail.com
carl.southwell@usc.edu
My blog:anotheruniqueperspective.blogspot.com
Also visit:www.pressfriends.org
Making writing fun ",or elementary school kids,empowering kids to become mentors and leaders,and creating friendships
among youth from diverse backgrounds.
3
2-246
Kit Fox
From:
Sent:
To:
Subject:
Carolynn Petru
Monday,January 07,20135:49 PM
Kit Fox
FW:Rancho LPG information re:insurance &seismic issues
From:Janet Gunter [mailto:arriane5@aol.com]
Sent:Saturday,January 05,2013 11:45 AM
To:CC;chateau4us@att.net;det310@juno.com;MrEnvirlaw@sbcglobal.net;connie@rutter.us;noelweiss@ca.rr.com;
jody.james@sbcglobal.net
Subject:Rancho LPG information re:insurance &seismic issues
Hello All &Happy New Year-
In doing a bit more intensive research to produce my comments for the Ponte Vista Housing
development EIR,the following has been discovered.This below information is documented in a
seismic report to the EPA from May of 2012 by "Strong Motions".Apparently,they looked at what
Rancho LPG/Plains All American had in the way of "earthquake insurance."
"Plains LPG has provided results of a "desktop"analysis of the earthquake loss.According to this
analysis,the ''probable maximum loss"is $8.4 million and the "maximum forseeable loss"is $18.6
million.These estimates were based on 250-year MRP ground shaking at the site.These estimates
include ONL Y the replacement value of the structures (tanks);they do NOT include losses from:1)
business interruption;2)spilled contents;3)environmental clean -up;4)fires;5)explosions;and 6)
third party liability.Plains LPG maintains earthquake insurance up to $60 million.It has not been
demonstrated that the facility is insured up to the maximum possible earthquake loss."
Also,upon review of the recent geologic report provided for the EPA from "Geotechnologies"(which I
previously forwarded to you)there is a designation of the soil at Rancho as a "Grade D Stiff
Soil".Unfortunately,my lack of education about geology left me void of any reference to what this
actually meant until my research yesterday which I am providing.I had to go to the Indiana item
since I was looking for "free information."However,this is very valid information.I've provided their
references.
Short description:
Liquefaction Potential of Surficial Materials in Indiana,2011 (1:500,000)-Shows shows highly generalized categories (low,
moderate,and high)of liquefaction potential,based on soil classes of the National Earthquake Hazards Reduction Program
(NEHRP).This data set provides a digital coverage of the predicted response of surficial geologic materials in Indiana to
liquefaction induced by earthquakes.It is intended to be used by Indiana Department of Homeland Security,emergency
planners,and responders on the state and local level as a general reference guide to identify potential areas of evaluated
risks of liquefaction.Low liquefaction potential includes NEHRP Soil Class B (consisting of rock:sandstone,limestone,shale).
Moderate liquefaction potential includes NEHRP Soil Class C (hard or stiff soil,or gravel)and part of NEHRP Soil Class D (stiff
soil,stiff clay,and some gravel).High liquefaction potential includes parts of NEHRP Soil Class 0 (stiff soil,stiff
clay,and some gravel),and all of NEHRP Soil Class E (soft soil and soft to medium clay)and F (lake and river
deposits of sand and mud).The following is excerpted from Indiana Geological Survey Miscellaneous Map 81:
'Liquefaction is a common ground-failure hazard associated with earthquakes.It is defined as the sudden and
temporary loss of strength of a water-saturated sediment.This could result in the structural failure of buildings,
bridges,and other structures.'
Tags:
IndianaMap,IGS,Indiana,geoscienticInformation,geology,surficial geology,quaternary,stratigraphy,earthquake,ground
shaking,seismic,soil classification,liquefaction,shear-wave velocity,National Earthquake Hazard Reductions Program
(NEHRP)
1
2-247
Credits:
National Earthquake Hazard Reductions Program (NEHRP),Federal Emergency Management Agency (FEMA),Indiana
Department of Homeland Security (IDHS),Indiana Geological Survey Miscellaneous Map 81 (2011)
FGDC Metadata:
Seismic Earthquake Liquefaction Potential.html
Download:Download a zip file that contains an ESRI Shape File and associated metadata:
Seismic Earthquake Liquefaction Potential.zip
Also of note,is that the geologic reports on Rancho rely entirely on existing information either
provided by the company's own consultants,or other existing data.There has been absolutely no
independent testing or modeling of conditions that can prove safety of geologic conditions.Also,in
looking at the coverage and estimation of seismic risk potential the analyses NEVER respond to
"liquefaction"of the soil during an earthquake!.The condition of soil "liquefaction"is acknowledged,
yet never analyzed under resulting seismic impacts.
On top of all of this,the issue of "tsunami"is never approached regardless of the fact that according
to maps the facility sits approximately 200 ft.north of a "designated tsunami zone".How the tsunami
wave is estimat~d to stop at that point needs explanation since there is no ground elevation that
would prevent further invasion.What was the tsunami wave size used to estimate this result?There
are two underwater landslide areas directly in our vicinity capable of causing a tsunami at the local
level.It is obvious in that in estimating that tsunami impact,there was no consideration of the fact
that there is a storm drain just below the tanks that leads directly out into LA Harbor.That storm drain
that would channel the force of a tsunami wave directly onto Gaffey St.and Westmont Drive seriously
impacting the area and extending the tsunami zone and its potentially devastating impacts
significantly.
To borrow an important line from Apollo 13,"Houston,we have a problem".
I have the sense that the EPA (due to some of the results from their recent commissioned reports on
Rancho)may be pursuing some type of action on the facility.I hope that your City Council members
will contact them and let them know your concerns regarding the safety of your community.This is a
time that we need to band together collectively in our effort to protect our residents.Let's hope that
2013 brings results that deliver a safer and saner environment to us all.
Thanks for your time,
Janet Gunter
2
2-248
Kit Fox
From:
Sent:
To:
Subject:
Attachments:
Carolynn Petru
Thursday,January 10,2013 9:49 AM
Kit Fox
FW:Disappointment in LEPC &Request for Opposition to Ponte Vista DEIR
pontevista_eir_submissionjan_2013_signed_final.doc;
Geotechnologies_report_on_rancho.pdf
From:Janet Gunter [mailto:arriane5@aol.com]
Sent:Thursday,January 10,2013 9:37 AM
To:CC;chateau4us@att,net
Subject:Fwd:Disappointment in LEPC &Request for Opposition to Ponte Vista DEIR
fyi
-----Original Message-----
From:Janet Gunter <arriane5@aol.com>
To:LaNette.Long <LaNette.Long@calema.ca.gov>;aalva <aalva@fire.lacounty.gov>;asalmen
<asalmen@responsegroupinc.com>;Brian.Abeel <Brian.Abeel@calema.ca.gov>;Akira.Yoshimura
<Akira.Yoshimura@bp.com>;Fisheral <Fisheral@epa.com>;Alien_O'Neil <Allen_O'Neil@longbeach.gov>;
Trevor.Anderson <Trevor.Anderson@calema.ca.gov>;anna.olekszyk <anna.olekszyk@lacitv.org>;BYu
<BYu@fire.lacounty.gov>;brunothehunter33 <brunothehunter33@hotmail.com>;bryank <bryank@bulk-dpi.com>;
Cdeaton <Cdeaton@fcc.gov>;CDiep <CDiep@dhs.ca.gov>;DRasmuss <DRasmuss@dtsc.ca.gov>;DanC
<DanC@TRNDUSTRIES.com>;Dan.Reed <Dan.Reed@linde.com>;dguillory <dguillory@mwdh20.com>;darrell_dennis
<darrell dennis@kindermorgan.com>;DChng <DChng@ochca.com>;Annabelle.Dixon
<Annabelle.Dixon@calema.ca.gov>;ethomas <ethomas@nesglobal.net>;earl.whitley <earl.whitley@dot.gov>;
em edgerton <emedgerton@earthlink.net>;fernando_benavides <fernando benavides@kindermorgan.com>;gbaker1
<gbaker1@dtsc.ca.gov>;grivera <grivera@ocsd.com>;gstaylor <gstaylor@socal.rr.com>;Jack.Harrah
<Jack.Harrah@calema.ca.gov>;William .Hatch <William .Hatch@calema.ca.gov>;Douglas .Huls
<Douglas.Huls@calema.ca.gov>;jbushnes <jbushnes@bis.doc.gov>;jlane <j1ane@SempraUtilities.com>;jessicaJalcon
<jessica.falcon@hg.dhs.gov>;jim.wada <iim.wada@ventura.org>;jody.james <jody.james@sbcglobal.net>;
Sherryl.Jones <SherryI.Jones@calema.ca.gov>;jagbc15 <jagbc15@hotmail.com>;justin.diedolf
<justin.diedolf@losangeles.af.mil>;klew <klew@torranceca.gov>;LWalters <LWalters@fire.lacounty.gov>;Iindakp5
<lindakp5@cox.net>;Mkazarians <Mkazarians@kazarians.com>;BiII.Martinez <BilI.Martinez@calema.ca.gov>;
michael.tia <michael.tia@kazarians.com>;mike_albarran <mike albarran@longbeach.gov>;bontty.mona
<bontty.mona@calema.ca.gov>;Edward.Newman <Edward.Newman@calema.ca.gov>;Patricio.romero
<Patricio.romero@sce.com>;phillip.langhus <phillip.langhus@edwards.af.mil>;RLEHMANN
<RLEHMANN@co.riverside.ca.us>;ryeaman <rveaman@dtsc.ca.gov>;rltaylor2 <rltaylor2@paalp.com>;Rich.Robles
<Rich.Robles@calema.ca.gov>;rlinton <rlinton@simivalley.org>;Ronald.Conrow
<Ronald.Conrow@plainsmidstream.com>;zach.streeter <zach.streeter@linde.com>
Cc:brian.hembacher <brian.hembacher@doj.ca.gov>;michael_davies <michael davies@feinstein.senate.gov>;
sally.magnani <sally.magnani@doLca.gov>;hamilton.cloud <hamilton.cloud@mail.house.gov>;jacob.haik
<jacob.haik@lacity.org>;MrEnvirlaw <MrEnvirlaw@sbcglobal.net>; noelweiss <noelweiss@ca.rr.com>;wesling.mary
<wesling.mary@epamail.epa.gov>;helmlinger.andrew <helmlinger.andrew@epa.gov>;connie <connie@rutter.us>;
carl.southwell <carl.southwell@gmail.com>;bea <bea@ce.berkeley.edu>;Ipryor <Ipryor@usc.edu>;nancy.lauer
<nancy.lauer@lapd.lacity.org>;bonbon90731 <bonbon90731@gmail.com>;jody.james <jody.james@sbcglobal.net>;
burling 102 <burling 102@aol.com>;marciesmiller <marciesmiller@sbcglobal.net>;jcynthiaperry
<jcynthiaperry@aol.com>;d.pettit <d.pettit@nrdc.org>
Sent:Wed,Jan 9,2013 2:26 pm
Subject:Re:Disappointment in LEPC &Request for Opposition to Ponte Vista DEIR
San Pedro homeowners have pursued assistance from the State of California's Local Planning Emergency
Committee for well over a decade with our chronic and very real concerns regarding the highly elevated risk to population
due to the existence of the Amerigas/Rancho Liquid Petroleum Gas facility.This facility stores a massive volume (over 25
Million gallons)of this gas.
1
2-249
The LEPC dismissed homeowner members at your meeting late last year with the statement that the LEPC's input is
limited to "emergency planning".You stated that the Rancho LPG facility is a grandfathered in facility and you have no
power to do anything since they are legal.However,we have noticed that your mission statement is a bit broader than
that:
"The Mission of the Local Emergency Planning Committee (LEPC)is to identify incidents or events that present a threat
to the health,safety,and well being of people,and to coordinate the planning and preparation efforts of the local response
community and private sector.
In our view,the LEPC has not lived up to this directive.Certainly,your interaction is warranted in identifying any
jeopardy involved in exposing greater population to harm and establishing the means to "mitigate"that harm".It is the
obligation of your Committee to intervene in such projects as the proposed Ponte Vista housing project to ensure both the
identification of hazard and proper mitigation to eliminate public risk.
Attached are documents representing a portion of my personal submission to the Ponte Vista Draft Environmental
Impact Report.That DEIR fails to identify the true risk of Rancho LPG.The Ponte Vista project is planning to introduce
yet another approximately 2,000 +residents (potential victims)to North San Pedro.This proposed housing project would
create over 1,100 new homes within 3/4 mile of the Rancho LPG facility.There is also an additional low income housing
project slated for abutting property of this Ponte Vista site for the housing of widows and children of American veterans.
Placement of the low income housing at this site is in direct violation to HUD regulations because of its close proximity to
both Rancho LPG and Conoco Phillips.In addition,there is a proposal for a new school at the same site.
Although the increased risk due to Rancho LPG has been acknowledged by various governmental agencies and
officials for many years,the area has been allowed great growth of housing despite that risk acknowledgment.
The lack of energy in your LEPC,with its chronic vacancy of board positions,is more than likely attributable to an
inability to move the committee in a direction that reflects meaning and purpose.It is obvious that the leadership
necessary to restore a focus and an infusion of sense of duty and function is absent.It is unfortunate.We hope that 2013
will bring an invigorated sense of duty and commitment to this Committee.A State body that could effectively serve in
safeguarding public safety in the sea of hazards in which we live,is sorely needed.
This Ponte Vista housing proposal offers an open invitation to the LEPC to do precisely what it should be doing.The
homeowners in San Pedro and the Harbor Peninsula region deserve your attention to this matter.The potential for
disaster and loss of human life is already too great to ignore.We respectfully request that the LEPC oppose the DEIR
because it does not address the safety issue of the Rancho tanks and,accordingly,provides no mitigation measures.
Thank you for your time.
Janet Gunter
-----Original Message-----
From:Long,LaNette@CaIEMA <LaNette.Long@calema.ca.gov>,
To:A.Alva <aalva@fire.lacounty.gov>;A.Salmen <asalmen@responsegroupinc.com>;Abeel,Brian@CaiEMA
<Brian.Abeel@calema.ca.gov>;Akira Yoshimura <Akira.Yoshimura@bp.com>;AI Fischer <Fisheral@epa.com>;Allen
O'Neil <Allen_O'Neil@longbeach.gov>;Anderson,Trevor@CalEMA <Trevor.Anderson@calema.ca.gov>;Anna
Okekszyk,P.E.<anna.olekszyk@lacity.org>;Arriane <arriane5@aol.com>;Barbara C.Yu <BYu@fire.lacounty.gov>;
Bruno Loran <brunothehunter33@hotmail.com>;Bryan Keegan <bryank@bulk-dpi.com>;C.Beaton <Cdeaton@fcc.gov>;
C.Diep <CDiep@dhs.ca.gov>;D.Rasmuss <DRasmuss@dtsc.ca.gov>;Dan Coots <DanC@TRNDUSTRIES.com>;Dan
Reed <Dan.Reed@linde.com>;Daniel J.Guillory <dguillory@mwdh20.com>;Darrell Dennis
<darrell dennis@kindermorgan.com>;Darwin Cheng,JD,REHS <DChng@ochca.com>;Dixon,Annabelle@CalEMA
<Annabelle.Dixon@calema.ca.gov>;Earl Thomas <ethomas@nesglobal.net>;Earl Whitley <earl.whitley@dot.gov>;
EileenM.Edgerton <emedgerton@earthlink.net>;Fernando Benavides <fernando benavides@kindermorgan.com>;G.
Baker <gbaker1 @dtsc.ca.gov>;G.Rivera <grivera@ocsd.com>;Glen Taylor <gstaylor@socal.rr.com>;Harrah,
Jack@CaIEMA <Jack.Harrah@calema.ca.gov>;Hatch,William@CalEMA <William.Hatch@calema.ca.gov>;Huls,
Douglas@CalEMA <Douglas.Huls@calema.ca.gov>;J.Bushnel <jbushnes@bis.doc.gov>;J.Lane
<jlane@SempraUtilities.com>;Jessica Falcon <jessica.falcon@hg.dhs.gov>;Jim Wada <iim.wada@ventura.org>;Jody
James <jody.james@sbcglobal.net>;Jones,Sherryl@CalEMA <SherryI.Jones@calema.ca.gov>;Juan Gonzalez
<jagbc15@hotmail.com>;Justis Diedolf <justin.diedolf@losangeles.af.mil>;K.Lew <klew@torranceca.gov>;L.Walters
<LWalters@fire.lacounty.gov>;Linda Phillips <lindakp5@cox.net>;M.Kazarians <Mkazarians@kazarians.com>;
Martinez,Bill@CaIEMA <BiII.Martinez@calema.ca.gov>;Michael Tia <michael.tia@kazarians.com>;Mike Albarran
<mike albarran@longbeach.gov>;Mona Bontty <bontty.mona@calema.ca.gov>;Newman,Edward@CalEMA
2
2-250
<Edward.Newman@calema.ca.gov>;Patricio Romero <Patricio.romero@sce.com>;Phil Angus
<phillip.langhus@edwards.af.mil>;R.Lehmann <RLEHMANN@co.riverside.ca.us>;R.Yeaman
<rveaman@dtsc.ca.gov>;Rick Taylor <rltaylor2@paalp.com>;Robles,Rich@CaIEMA <Rich.Robles@calema.ca.gov>;
Ron Linton <rlinton@simivalley.org>;Ronald Conrow <Ronald.Conrow@plainsmidstream.com>;Zach Streeter
<zach .streeter@linde.com>
Sent:Tue,Jan 8,2013 2:28 pm
Subject:LEPC Meeting
If you plan on attending the meeting,please RSVP via email:lanette.long@calema.ca.gov
Time:
Location:
10:00 am
California Emergency Management Agency
Joint Forces Training Base
4671 Liberty Avenue,Bldg.918
Los Alamitos,CA 90720
LaNette K.Long
Office Technician
Southern Region Office
California Emergency Management Agency
4671 Liberty Avenue
Los Alamitos,CA 90720
(562)795-2954 DIRECT
(562)795-2900 MAIN OFFICE
(562)795-2963 FAX
(916)845-8911 24-HR EMERGENCY
lanette.long@calema.ca.gov EMAIL
3
2-251
LADOT response to MND comments for
Marymount College San Pedro Campus
2-252
CITY OF LOS ANGELES
INTER-DEPARTMENTAL MEMORANDUM
1600 Palos Verdes Dr North
LADOT Case No.HRB11-008
Date:
To:
From:
Subject:
November 30,2012
Marc Woersching,City Planner
Department of City Planning
.AI.U.B1~C~
Mohammad H.Blorfroshan,Transportation Engineer
Department of Transportation
Response to traffic"related comments from the City ofRancho Palos
Verdes for the proposed Marymount College San Pedro Campus Project,
1600 Palos Verdes North [DEPARTMENT OF CITY PLANNING CASE NO.
ENv..2011 ..2478;oMND]
The Los Angeles Department of Transportation (LADOT)issued a traffic assessment report for
the proposed Marymount College San Pedro Campus-Project on July 24,2012.On October 17,
2012,Mr.Kit Fox,Senior Administrative Analyst at the City of Rancho Palos Verdes (RPV),
issued a letter to your Department commenting on the republished Mitigated Negative
Declaration (MND)andLADOT's assessment report for this Project.In his letter,Mr.Fox
referenced to the traffic and circulations impacts in the Environmental Impact Report (EIR),
certified by the City of RPV in May 2010,for the Marymount College Facilities Expansion Project
for the College's main campus in the City of RPV.LADOT has carefully reviewed these
comments and provided a response to these comments as follows:
Response to Comments
1.Based on LADOT's review of the Marymount College San Pedro Campus Project traffic
study report,the installation of traffic signal at the intersection of Palos Verdes Drive
East and Miraleste Drive is not required until-Phase II of the Project,which is anticipated
to be completed by the year 2019.It is understood that this new traffic signal is also a
mitigation measure for the Phase II of the MarymountCollege Facilities Expansion
Project on the RVP Campus,which is currently conditioned to occur by June 2015.
Because these are separate and distinct projects,there is no need to revise LADOT's
assessment report to address the scheduling conflict for the installation of this traffic
signal.In our report,we indicated that the College shall work with the City of RPV to
seek the final approval of the traffic signal at this intersection.Therefore,Marymount
College will simply coordinate with the City of RPV to implement a new traffic signal at
this intersection prior to completion of Phase /I of the RPV Campus's Expansion Project
or Phase /I of the San Pedro Campus Project,whichever occurs first
2.The EIR for the Marymount College Facilities Expansion Project in RPV was prepared to
identify impacts associated with that project,which was approved in May 2010 and has
not been subsequently modified.The republished MND for the San Pedro Campus
Project,which is located approximately 3.5 miles northeast of the RPV Campus,was
prepared to identify impacts associated with San Pedro Campus.Since these are two
separate and distinct projects,it is not unusual that the potential traffic impacts
2-253
Marc Woersching -2-November 30,2012
associated with the two projects would be different.It shoUld also be noted that the traffic
impact study for the San Pedro Campus Project,prepared by the KOA Corporation,
based assumptions from the traffic impact study for the RVP Campus,where
appropriate.As part of the process,KOA collected additional updated empirical data at
the RVP Campus and the San Pedro Campus that was used for the San Pedro Campus
study.The empirical data included current vehicle counts at the driveways on both
.campuses.A license plate survey was also conducted to determine trip distribution
patterns between campuses.This data provides the most accurate information to
estimate trip generation and distribution for the San Pedro Campus Project.The traffic
study assumptions were discussed and approved by LADOT.KOA's traffic study for the
San Pedro Campus did not identify any significant traffic impact at the intersection of
Capitol Drive,Trudie Drive,and Western Avenue.Therefore,there is no need for
LADOT to revise the assessment report to indicate the significant traffic impact at this
intersection.
3..RPV's comment asserts that the MND (i.e,the Traffic Study)for the San Pedro Campus
Project has not adequately addressed the potential Project's impacts at the intersection
of Palos Verdes Drive East and Palos Verdes Drive South.RPV did not provide any
detailed information or explanation to.supportits.assertion that the San Pedro Campus
ProJect will generate significant numbers of new trips impacting this intersection.As
indicated before,the San Pedro Campus is approximately 3.5 miles northeast of the
RPV Campus and the most direct route from the SanPedro Campus to the RPV
Campus,and vice versa,is coming from the northerly direction along Palos Verdes Drive
East.If a driver decides to travel from the San Pedro Campus to the RPV Campus
coming from the south along Palos Verdes Drive South,this would add an additional 2.2
miles to the trip along a very circuitous route.Since this is unlikely to occur,this
intersection was not analyzed in the traffic impact study for the San Pedro Campus
Project.
4.In response to a request from the Northwest San Pedro Neighborhood Council
(NWSPNC),the Marymount College agreed to perform traffic analysis at eight (8)
additional study intersections along the Western Avenue and Gaffey Street,KOA
prepared the cOLirtesy traffic analysis (CTA)at these intersections in December 2011.
The CTA was not required by the City of Los Angeles,the lead agency for the San
Pedro Campus Project,therefore,this study.was not included as part of the traffic impact
analysis for this project.The CTA utilized trip generation assumptions that were current
at the time the study was prepared.In early 2012,however,Maryrnount College
representatives recommended adjustments to the trip generation discount assumptions
in the traffic impact analysis in order to provide a more conservative estimate of the San
Pedro Campus Project's trip generation.The adjusted trip generation estimates were
used for the final traffic impact study dated July 2012.For the sole purpose of
responding to the City of RPV's comment,KOA has revised the CTA using trip
generation assumptions that are consistent with those found in the final traffic impact
study for the San Pedro Campus Project.The updated traffic impact study,reviewed by
LADOT,revealed that the proposed San Pedro Campus Project will not cause any
significant traffic impact at any of the eight studied intersections (see attached tables).
The Marymount College is developing a comprehensive sustainability plan to reduce all of its
environmental impacts.As part of the San Pedro Campus Project,the College will implement
the measures listed below in order to reduce both traffic and pollution caused by campus
vehicle trips.These measures are expected to minimize traffic impacts in the study area.
2-254
Marc Woersching -3-November 30,2012
•Provisions of an enhanced shuttle service between campuses by increasing bus
frequency during peak periods of usage
•Provisions of on-campus housing at the San Pedro Campus
•Limitations of the number of student residents who may have a car on the San
Pedro Campus
•Schedule morning peak period classes on the San Pedro Campus primarily for
on-campus resident students
•Restrict the number of resident students driving to the RPV Campus during the
morning peak period
•Implement parking permit/decal system to restrict parking by students on the
RPVCampus
•Implement a carpool system
If you have any questions,please feel free to call me at (213)485-1062.
MB:mhb
Attachments
c:Jay Kim,Sean Haeri,Crystal Killian,DOT
Karen Hoo,David Weintraub,DCP
Jonathan Louie,KOA Corporation
2-255
KOA CORPORATION
PLANNING &ENGINEERING
Table 6 -Intersection Level of Service Summary -Existing Plus Project
Existing (2012)Existing Plus Project
Midday Midday Change in VIC
Analysis Afternoon PM Peak Hour Afternoon PM Peak Hour Significant
Study Intersections City Methodology Peak Hour Peak Hour Impact?
Mid-PMVICLOSVICLOSVICLOSVICLOSAfternoon
Peak Hour
Peak Hour
I Western Ave &Green Hills Dr Rancho Palos Verdes ICU 0.503 A 0.569 A 0.511 A 0.578 A 0.008 0.009 No
2 Western Ave &Avenida Aprenda Rancho Palos Verdes ICU 0.519 A 0.613 B 0.527 A 0.623 B 0.008 0.010 No
3 Western Ave &Delasonde DrlWestmont Dr Rancho Palos Verdes ICU 0.731 C 0.746 C 0.739 C 0.754 C 0.008 0.008 No
4 Western Ave &Toscanini Dr Rancho Palos Verdes ICU 0.587 A 0.658 B 0.595 A 0.668 B 0.008 0.010 No
5 Western Ave &Caddington Dr Rancho Palos Verdes ICU 0.624 B 0.752 C 0.632 B 0.761 C 0.008 0.009 No
6 Gaffey St &Westmont Dr Los Angeles CMA 0.488 A 0.704 C 0.489 A 0.707 C 0.001 0.003 No
7 Gaffey St &Capitol Dr Los Angeles CMA 0.531 A 0.682 B 0.532 A 0.684 B 0.001 0.002 No
8 Gaffey St &Channel St Los Angeles CMA 0.512 A 0.665 B 0.513 A 0.666 B 0.001 0.001 No
Note:
leu ~Intersection Capacky Utilization Method;CMA ..Critical Movement Analysis Method
Courtesy Traffic Study for Marymount College San Pedro Campus
November 14,2012
Page 18
2
-
2
5
6
KOA CORPORATION
lJ PLANNiNG &ENGINEERING
Table 7 -Intersection Level of Service Summary -Future With Project
Future Without Project Future With Project
Midday Midday Change in VIC
Afternoon PM Peak Hour Afternoon PM Peak Hour
Study Intersections City
Analysis
Peak Hour Peak Hour
Significant
Methodology
Mid·I Impact?
PMVICLOSVICLOSVICLOSVICLOSAfternoonIPeakHourPeakHour
I Western Ave &Green Hills Dr Rancho Palos Verdes ICU 0.857 D 0.771 C 0.864 D 0.781 C 0.007 0.010 No
2 Western Ave &Avenida Aprenda Rancho Palos Verdes ICU 0.720 C 0.761 C 0.727 C 0.771 C 0.007 0.010 No
3 Western Ave &Delasonde Dr/Westmont Dr Rancho Palos Verdes ICU 0.885 D 0.897 D 0.893 D 0.905 E 0.008 0.008 No
4 Western Ave &Toscanini Dr Rancho Palos Verdes ICU 0.699 B 0.771 C 0.706 C 0.780 C 0.007 0.009 No
5 Western Ave &Caddington Dr Rancho Palos Verdes ICU 0.756 C 0.885 D 0.763 C 0.895 D 0.007 !0.010 No
6 Gaffey St &Westmont Dr Los Angeles CMA 0.651 B 0.876 D 0.653 B 0.878 D 0.002 0.002 No
7 Gaffey St &Capitol Dr Los Angeles CMA 0.678 B 0.832 D 0.680 B 0.834 D 0.002 0.002 No
8 Gaffey St &Channel St Los Angeles CMA 0.645 B 0.795 C 0.646 B 0.795 C 0.001 0.000 No
Note:
ICU -Intersection Capadty Utilization Method,CMA -Critical Movement Analysis Method
Courtesy Traffic Study for Marymount College San Pedro Campus
November 14,2012
Page 19
2
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2
5
7
Staff report for Marymount College San Pedro Campus
2-258
PARCEL MAP No.AA-2011-2479-PMLA (stamped map dated)
HEARING DATE:December 12,2012
PLANNING DEPARTMENT STAFF REPORT
DEC 1 7 2012
PURSUANT TO ORDINANCE 164,845,IF A CERTIFICATE OF POSTING HAS NOT
BEEN SUBMITIED BEFORE THE DATE OF THE PUBLIC HEARING,IT MUST BE
PRESENTED AT THE HEARING,OR THE CASE MUST BE CONTINUED.
REQUEST Preliminary Parcel Map to be re-subdivide and merge a strip of land,(1.47
acres)to be vacated by the City of Los Angeles,along the south side of Palos Verdes
Drive into the main portion of the site,11.66 aCres of land owned by Marymount College.
ADDRESS
1600 Palos Verdes Drive North
San Pedro,CA 90732
APPLICANT/REPRESENTATIVE
James R.Krause
Non-Profit Ventures
4007 Coogan Cercle
Culver City,CA 90232
(310)839-5455
RELEVANT CASES
ON-SITE:
CPC-2011-2480-CU - A five phase planned,college campus with an ultimate seating
capacity of 520 students,800 residential units,a student service building with dining hall,
50 facility and administrative offices,nine classrooms and 342 parking spaces.
CPC-2004-6012-CU-ZV -On March 25,2005,the City Planning Commission approved a
Conditional Use to permit a child care facility,a private elementary school,and a private
high school and 62 housing units.
OFF-SITE:There are no previous or existing cases relevant to this subdivision.
PUBLIC RESPONSES
No letters have been received from the public.
2-259
Case No.AA-2011-2479-PMLA
GENERAL COMMENTS
Page 2
The project involves the merger of a 1.47 acre strip of land owned by the City of Los
Angeles into a larger 59-acre property,a former Palos Verdes Navy housing site,to
develop an education park,which will include a five-phase master planned college campus,
including residents,administration buildings and a preparatory school,supporting pre-k
through grade 12.
The current 11,66 acre Marymount campus consists of 86-units offormer Navy housing,
landscaped yards,and roadways.A laundry facility,small student meeting rooms,outdoor
basketball and volleyball courts,a covered picniclrecreational area,play field,and a
vending machine area round out the existing facilities and uses.
The topography of the subject property is an irregular lot on a hillside mountainous terrain
overlooking the Marymount College's Waterfront campus to the east and fronts
approximately 743 feet along Palos Verdes Drive North to the North.The property area is
approximately 11.66 acres,zoned RD6-1XLlOS-IXL,with a Low Residential designation in
the Wilmington-Harbor City Community Plan.There are no protective trees nor any known
hazardous conditions on the site.
REPORTS RECEIVED
BUREAU OF ENGINEERING:Reports that the Preliminary Parcel Map application and
layout is unsatisfactory as submitted and recommends that the applicant submit a revised
map.
DEPARTMENT OF BUILDING AND SAFETY,GRADING DIVISION:Preliminarily approval
subject to conditions stated in the memo dated May 2,2012.See recommended conditions
under Parcel Map Report with Conditions under department.
DEPARTMENT OF BUILDING AND SAFETY,ZONING DIVISION:A clearance letter will
be issued stating that no Building and Zoning Code violations exist on the subject site once
the items identified in the memo dated January 30,2012 have been satisfied.Submit map
dimensions to agree with Zimas map,Specify on the map portion to me merged,provide
proof of lot cut and show street dedications.See recommended conditions under Parcel
Map Report with Conditions under department.
DEPARTMENT OF TRANSPORTATION:Recommends that the project be subject to
condition in memo dated,December 7,2012.See recommended conditions under Parcel
Map Report with Conditions.
DEPARTMENT OF WATER AND POWER:Reports that this parcel map can be supplied
with water from the municipal system subject to LADWP's Water Services Organizations'
2-260
Case No.AA-2011-2479-PMLA Page 3
FIRE DEPARTMENT:No comments were available at the writing of the staff report.
LOS ANGELES UNIFIED SCHOOL DISTRICT:No comments were available atthewriting
of the staff report.
BUREAU OF STREET LIGHTING:Recommends that the project be subject to conditions
stated in the memo dated February 22,2012.See recommended conditions in Parcel Map
Report with conditions under department.
BUREAU OF SANITATION:Wastewater Collection System Division of the Bureau of
Sanitation has inspected the sewer/storm drain serving the subject tract and found no
potential problems to their structures or potential maintenance problem.
ENVIRONMENTAL CLEARANCE
Planning Staff issued Mitigated Negative Declaration ENV-2011-2478-MND on
September 19,2012.However,the Mitigated Negative Declaration did not discuss potential
impacts of the lot merger and resubdivision (Parcel Map).As such the Advisory Agency
cannot certify the Mitigated Negative Declaration.
STAFF RECOMMENDATIONS
The Planning Department staff recommends that Preliminary Parcel Map AA-2011-2479-
PMLA be continued until such time the applicant submits a revised map to address the
concerns outlined by the Bureau of Engineering and the reconsideration of the
environmental clearance.
Prepared by:
Dwayne Wyatt
Subdivision Unit
Note:Recommendation does not constitute a decision.Changes may be made by the
Advisory Agency at the time of the public hearing.
2-261
Case No.AA-2011-2479-PMLA
James R Krause
Non-Profit Ventures
4007 Coogan Circle
Culver City,CA 90232
Page 4
Case No.AA-2011-2479-PMLA
Related Case:CPC-2011-2480-CU
1600 W.Palos Verdes Dr N
Wilmington-Harbor City
Zone :RD6-1XL
D.M.:030B193
C.D.:15
CEQA:ENV-2011-2478-MND
Legal Description:Lot PTH,TRACT Partition of
Rancho Palos Verdes
DRAFT PRELIMINARY PARCEL MAP DECISION LETTER WITH CONDITIONS
In accordance with provisions of Section 17.53 of the Los Angeles Municipal Code,the
Advisory Agency approved the Mitigated Negative Declaration ENV-2011-2478-MND as
the environmental clearance and Parcel Map AA-2011-2479-PMLA composed of two (2)
lots being combined into one (1)lot,as shown on map stamp-dated October 24,2011.
The subdivider is hereby advised that the Municipal Code may not permit this maximum
approved density.Therefore,verification should be obtained from the Department of
Building and Safety which shall legally interpret the Zoning Code as it applies to this
particular property.For an appointment with the Advisory Agency or a City Planner call
(213)473-9919.The Advisory Agency's approval is subject to the following conditions.
NOTE on clearing conditions:When two or more agencies must clear a condition,subdivider should
follow the sequence indicated in the condition.For the benefit of the applicant,subdivider shall
maintain record of all conditions cleared,including all material supporting clearances and be
prepared to present copies of the clearances to each reviewing agency as may be required by its
staff at the time of its review.A copy of the first page of this grant and all conditions and/or any
subsequent appeal of this grant and its resultant conditions and/or letters of clarification shall be
printed on the building plans submitted to the Department of BUilding and Safety for purposes of
having a building permit issued..
BUREAU OF ENGINEERING
1.This map has been filed for a one-parcel college campus purposes over a parcel of
land in the existing RD6-1X1L10S-1XL Zone.The layout of the subdivision map and
language within the application will have to be satisfactorily resubmitted for the
follOWing reasons:
a.The applicant on the submitted "Master Land Use Permit Application"stated
"surplus land owned by the City of Los Angeles will be vacated and
transferred to Marymount through a quitclaim deed".The applicant continued
to state "transfer from the U.S.Department of Education into a parcel map
via a concurrent merger and resubdivision".
2-262
Case No.AA-2011-2479-PMLA Page 5
b.There is no street vacation filed for that portion of Palos Verdes Drive
North adjoining the property at this time and even if the City is determined to
be the underlying fee owner,surplus land cannot be transferred through
quitclaim deed.
c.If the intention of the applicant is for merger of a portion of right-of-way area,
then both the application and the preliminary map have to specifically state
that a merger of a portion of Palos Verdes Drive North is being requested.
d.As a result and based on the submitted application and preliminary parcel
map,it is unclear what the applicant is applying for and what the intent of the
applicant is in filing for the preliminary parcel map.
NOTES:Any questions regarding the aforementioned report be directed to Ray Saidi of the
Land Development Group,located at 201 North Figueroa Street,Suite 200,or by calling
(213)202-3492.
DEPARTMENT OF BUILDING AND SAFETY,GRADING DIVISION
2.That prior to issuance of a grading or building permit.or prior to recordation of the
final map,the subdivider shall comply with any requirements with the Department of
Building and Safety,Grading Division.
DEPARTMENT OF BUILDING AND SAFETY,ZONING DIVISION
3.That prior to recordation of the final map,the Department of Building and Safety,
Zoning Division shall certify that no Building or Zoning Code violations exist on the
subject site.In addition,the following items shall be satisfied:
a.The submitted Map dimensions do not agree with ZIMAS.Revise the Map to
address the discrepancy or obtain approval from Department of City
Planning.
b.Specify on the map the proposed of the project.Indicate on map portion to
be merged.
c.Provide proof of legal lot cut for portions of lot cut after July 29,1962.
d.Show all street dedication as required by Bureau of Engineering and provide
net lot area after all dedication."Area"requirements shall be re-checked as
per net lot area after street dedication.Front yard requirement shall be
required to comply with current code as measured from new property lines
after dedication.
2-263
Case No.AA-2011-2479-PMLA Page 6
Notes:Any proposed structures or uses on the site have not been checked for and shall
comply with Building and Zoning Code requirements.Plan check will be required before
any construction,occupancy or change of use.
An appointment is required for the issuance of a clearance letter from the Department
of Building and Safety.The applicant is asked to contact Laura Duong at (213)482-
0434 to schedule an appointment.
DEPARTMENT OF TRANSPORTATION
4.A minimum of 60-foot reservoir space be provided between any security gate(s)and
.the property line.
5.Parking stalls shall be designed so that a vehicle is not required to back into or out
of any public street or sidewalk.
6.Project shall comply with LADOT Traffic Assessment letter (Case No.HRB 11-008)
dated July,24,2012.Driveways and vehicular access to projects shall be provided
to the satisfaction of the Department of Transportation.
7.This determination does not include approval of the projects's driveways and
internal circulation or parking scheme.Adverse traffic impacts could occur due to
access and circulation issues.A parking area and driveway plan be submitted to the
Department of Transportation for approval prior to submittal of building permit plans
for plan check by the Department of Building and Safety.Final DOT approval
should be accomplished by submitting detailed site/driveway plans at a scale of
1"=40'to DOT's West LAlCoastal Development Review Section located at 7166 W.
Manchester Ave.,Los Angeles,90045.
8.That a fee in the amount of $197 be paid for the Department of Transportation as
required per Ordinance No.180542 and LAMC Section 19.15 prior to recordation of
the final map.Note:the applicant may be required to comply with any other
applicable fees per this new ordinance.
Notes:PI~ase contact this section at (213)482-7024 for any questions regarding
the above.
FIRE DEPARTMENT
9.Submit plot plans for Fire Department review and approval prior to recordation of
2-264
Case No.AA-2011-2479-PMLA Page 7
this Parcel Map Action.Access for Fire Department apparatus and personnel to
and into all structures shall be required.
DEPARTMENT OF RECREATION AND PARKS
10.That the Quimby fee be based on the RD Zone.
LOS ANGELES UNIFIED SCHOOL DISTRICT (LAUSD)
11.That prior to the issuance of any demolition or grading permit or any other permit
allowing site preparation and/or construction activities on the site,satisfactory
.arrangements shall be made with the Los Angeles Unified School District.
DEPARTMENT OF CITY PLANNING-SITE SPECIFIC CONDTIONS
12.Prior to the recordation of the final map,the subdivider shall prepare and execute a
Covenant and Agreement (Planning Department General Form CP-6770)in a
manner satisfactory to the Planning Department,binding the subdrvider and all
successors to the following:
a.Use.Limit the proposed development to a maximum of one (1)lot.
b.Indemnification.Upon the effective date of this conditional approval,the
applicant shall defend,indemnify and hold harmless the City,its agents,
officers,or employees from any claim,action,or proceeding against the City
or its agents,officers,or employees to attack,set aside,void or annul this
approval which action is brought within the applicable limitation period.The
City shall promptly notify the applicant of any claim,action,or proceeding
and the City shall cooperate fully in the defense.If the City fails to promptly
notify the applicant of any claim action or proceeding,or if the City fails to
cooperate fully in the defense,the applicant shall not thereafter be
responsible to defend,indemnify,or hold harmless the City.
FINDINGS OF FACT (CEQA):
2-265
Case No.AA-2011-2479-PMLA Page 8
Staff of the Planning Department issued a Mitigated Negative Declaration No.ENV-2011-
0247-MND on September 19,2012,with condition to mitigate environmental impacts
associated to the related Conditional use permit.However,the MND did not asses the
impacts of the proposed re-subdivision and merger.As such,the Advisory Agency cannot
certify Mitigated Negative Declaration No.ENV-2011-0247 -MND,that the project would not
have a significant effect upon the environment.
Figueroa Plaza
201 N.Figueroa Street,4th Floor
Los Angeles,CA 90012
.(213)482-7077
Marvin Braude San Fernando
Valley Constituent Service Center
6262 Van Nuys BI.,Room 251
Van Nuys,CA 91401
(818)374-5050
*Please note the cashiers at the public counters close at 3:30 PM.
Appeal forms are available on-line at www.lacity.org/pln.
Pursuant to Ordinance 176,321,effective January 15,2005,Parcel Map determinations
are only appealable to the Area Planning Commission.There is no longer a second level
of appeal to the City Council for Parcel Map actions of the Advisory Agency.
The time in which a party may seek judicial review of this determination is governed by
California Code of Civil Procedure Section 1094.6.Under that provision,a petitioner may
seek judicial review of any decision of the City pursuant to California Code of Civil
Procedure Section 1094.5,only if the petition for writ of mandate pursuant to that section is
filed no later than the 90th day following the date on which the City's decision becomes
final,including all appeals,if any.
No sale of separate parcels is permitted prior to recordation of the final parcel map.The
owner is advised that the above action must.record within 36 months of the date of
approval,unless an extension of time has been requested in person before 5:00 p.m.
No requests for time extensions or appeals received by mail shall be accepted.
If you have any questions,please call Parcel Maps staff at (213)973-9919.
2-266
Case No.AA-2011-2479-PMLA
Michael J.LoGrande
Advisory Agency
GARLAND CHENG
Deputy Advisory Agency
ML:JT:GC:DW:
cc:.Bureau of Engineering -4
Community Planning Bureau
Planning Office &1 Map
D.M.030B193
Bureau of Street Lighting
Street Tree Division & 1 Map
CP-1809 (03-01-01)
Page 9
Dept.of Building &Safety,Zoning & 2 Maps
Department of Building &Safety,Grading
Department of Fire
Department of Recreation &Parks & 1 Map
Department of Transportation,cpe Section
Room 600,221 N.Figueroa Street
2-267