TO: planning.envreview@lacity.org
SUBJECT: ENV-2015-2354-EIR / 2015101077 / DEIR comments re: Abode at Glassell Park

To: Karen Hoo, Environmental Review Coordinator
Environmental Review Section
Department of City Planning
200 North Spring Street, Room 750
Los Angeles, CA 90012


Dear Ms. Hoo,

This is the largest proposed development within the Mt. Washington/Glassell Park Specific Plan in 25 years. This plan was enacted to limit oversized development and to preserve the rural character of our hilly neighborhoods. The proposed Abode development violates the spirit of that plan.

We agree that there is a housing shortage in Los Angeles, and that new development is needed. But it makes more sense to us that development occur along transit corridors, rather than be shoehorned into the limited natural open space that remains – vital open space that does indeed establish the rural character of Northeast Los Angeles.

The infrastructure in our neighborhood is clearly inadequate to support this development. Throughout the report, the serious problems the Abode development introduces—traffic, runoff, emergency access, noise, damage to wildlife and trees, among others—were simply dismissed as impacts that “would be less than significant.”

We strongly disagree with the DEIR analysis in almost all respects. We feel that the DEIR is based on insufficient research and evidence, and that it ignores the damage the Abode development will wreak upon much-needed open space and to the character of our neighborhood.

It is important to note that there is not a single designated park in Glassell Park. (The irony of this fact should be apparent.) Walnut Canyon is one of the few open natural spaces in our community, and its value as open space is incalculable. It has been used by the community for decades, as the well-worn path through the canyon indicates, and has become an indispensable part of the neighborhood experience.

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AIR QUALITY and GREENHOUSE GAS EMISSIONS

Source of analysis
The DEIR does not attribute the air quality analysis (found in Appendix B) to any specific company. It appears that these figures were modeled by the developers themselves. Certainly this sort of analysis needs to be done by a certified and independent third party.

Unrealistic project calendar
The project calendar provided in Appendix B (3.0 Construction detail) states that the entire project lifecycle -- clearing, grading, street construction, retaining wall construction, the full development of 32 homes, and paving -- will be completed within 14 months. This is an entirely unrealistic estimate. (It also contradicts the estimate of 17 months found in Table 1-1 of the main DEIR.) A more credible timetable that depicts the actual scope of work will inevitably result in a significant increase in the project impact estimates found throughout the DEIR, e.g., air quality, noise, traffic. This inaccuracy requires substantial additional study.

Science has shown that greenspace lowers the air temperature for the surrounding neighborhoods, supporting Mayor Garcetti’s initiative to lower the overall temperature of Los Angeles by three degrees over the next twenty years. In contrast, the added roofs and pavement that would come with the proposed development, and the removal of vegetation, would create a significant temperature increase in our neighborhood and add to the mean temperature of Los Angeles. Adding to the Urban Heat Island Effect by removing vegetation at precisely the same moment that we should be planting more trees to shade heat-absorbing and heat-emitting pavements and roofs, is inconsistent with the Mayor's plan for our city, which could be honored more effectively by restricting large developments to areas already paved and developed.

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ARCHITECTURAL MERIT

The architectural design for this proposed development is inadequate. It has made no attempt to be eco friendly. No solar power or any alternative energy sources, and no attempt to have a sensitive footprint on the canyon. These homes are solely designed to maximize lots with exterior walls straight down to the canyon on all sides and with no sensitivity to the surrounding context of the land or architectural fabric of the neighborhood. They are generic enough to be built anywhere, and as you can see from the architect’s website it is just another slight variation from the predictable developments they have built around the country. The architectural design of the project must be revisited.

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BIOLOGICAL RESOURCES

Important wildlife corridor
Walnut Canyon is an important wildlife corridor. The Department of Fish and Wildlife refers to our area as “providing connectivity from the Santa Monica Mountains/Griffith Park to San Rafael up to the Verdugo Mountains.” Residents have noted coyotes, bobcats and foxes, as well as countless species of birds, including hawks, woodpeckers and owls. The DEIR does not adequately address the impact the loss of this corridor will have on wildlife regionally. In fact, the DEIR claims that Walnut Canyon is not a corridor at all, which is factually incorrect. There is extensive documentation that members of the community have collected over the years which show the many species of plants and animals found here: http://www.inaturalist.org/places/glassell-park-b1dd51a1-6ae1-4826-8d48-90aee26817a5

Protected trees
Walnut Canyon is covered by 160 protected California Black Walnut trees, along with other native plant species. The developer proposes the removal of 121 of these protected trees and, as mitigation, proposes a 4:1 replacement ratio, and even suggests replacing the removed Black Walnuts with other varieties. The Department of Fish and Wildlife recommends a 15:1 replacement ratio for Black Walnut trees. Clearly, the mitigation offered here is inadequate.

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GEOLOGY AND SOILS

Groundwater in Walnut Canyon
As stated in the analysis provided in Appendix C, the soil in Walnut Canyon “has high runoff potential, very low infiltration rates, and consists chiefly of clay soils.” The DEIR acknowledges the expansiveness of this soil, but states that compliance with the City’s Building Code renders this issue insignificant.” The DEIR, however, does not address the high runoff potential and low infiltration rates that characterize the soil, and these characteristics speak directly to drainage issues outlined elsewhere in our response.

Additionally, there is geological evidence, along with observation by longtime residents, that the ground in Walnut Canyon is at times wet and spongy, which would seem to indicate groundwater seepage. The groundwater study (Appendix E) was done in March 2015, during the extended California drought and during the warmest March on record. As a result, this study may not reflect actual groundwater conditions. This is a significant observation and requires adequate additional study.

Seismic Concerns
4.F-1/4 Seismic Hazard Mapping Act The Seismic Hazard Mapping Act (SHMA)...purpose of protecting the public from the effects of non-surface fault rupture earthquake hazards,...strong ground shaking, liquefaction, seismically induced landslides, or other ground failure caused by earthquakes....minimize loss of life and property by identifying and mitigating seismic hazards....seismic hazard zones maps that identify areas susceptible to amplified shaking, liquefaction, earthquake-induced landslides, and other ground failures.

All consideration of seismicity is inadequate without references to well-known Raymond Fault zone and known/recorded seismic events with the accessible data bases (http://scedc.caltech.edu/eq-catalogs/). Initial review showed 20 recorded event with two clustered sets, April 2000: 7 events/max. 2.15RM and Aug 2010: 4 events/max. 2.57RM

Apdx F Fig. D-1 (pdf 96) includes Dibblee's geological map and shows the Raymond Fault Zone at less than one mile north of the Project site without reference throughout the DEIR.

Both the DEIR and geotechnical study (Apdx. F) do not discuss available and accessible seismic setting but outside the above referenced Raymond Fault Zone to north (<1 mile) of Project site. Both document are considered inadequate and incomplete with regard to faulting and seismicity..

Withdraw, revise, and recirculate all review and assessment pertaining to seismic setting and review of shaking impacts on the Project structures and cut/filling within and adjacent to the Project.

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HYDROLOGY AND WATER QUALITY

Existing drainage system
The existing drainage system in the neighborhood is already inadequate during heavy rains. The flood of water experienced during these times is made worse by the fact that our streets have no curbs, and, as a result, water often floods garages and other structures. The addition of any runoff resulting from Walnut Canyon hardscaping would be disastrous.

Proposed sewer and drainage systems
The DEIR states that the project site is “served by an existing wastewater conveyance system.” (DEIR, page 17) In fact, there are no sewers connected to Walnut Canyon, and some adjacent homeowners actually use septic systems because there are not adequate sewers in the area. The DEIR states that sewers will be developed, “consistent with laws and regulations,” but the document does not acknowledge the difficulties of sewer development already evident in the neighborhood. The DEIR is also inconclusive as to whether the existing local and trunk lines are in fact sufficient to accommodate the proposed development. (DEIR, page 18)

For rainwater runoff, the developer proposes the construction of north and south 24-inch drainage pipes, These pipes must pass across easements on existing properties along Division Street. The DEIR does not provide details about these easements -- it is unclear whether there is sufficient room between the properties, and unclear whether the developers have sought or have obtained agreement from the affected homeowners.

Additionally, it is intended that all runoff from the Abode development will be channeled between residencies on Division Street and dumped into the open street, where it will flow down to the catch basin at Jessica and Division. Significant water already flows down Division to this catch basin during storms. The DEIR does not address the condition of Division Street when this substantial runoff from Walnut Canyon is added to the existing flow. Rather than add to an already challenging situation, the developer should address the possibility of piping runoff directly to the underground drainage system beneath Division Street.

Need to consider climate change
The hydrology calculations in the study are based on past 10, 25 and 50 year intervals. This analysis does not take the impact of climate change into account. Moving forward, we could likely experience stronger storms and greater rainfall. Calculations that do not take future weather patterns into account are inadequate.

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LAND USE AND PLANNING

Impact on Glassell Park population
There are many other developments underway in more appropriate areas in our community—one need only look at the massive housing complexes underway along Eagle Rock Boulevard. The report does not address the fact of these developments, and is incomplete in that respect. This report should include new and planned developments throughout the community when calculating Abode’s impact on the population in Glassell Park.

Estimate of residents in Abode household
The DEIR provides an estimate of 2.74 residents per Abode household, based on a 2015 study for the City of Los Angeles. This figure is not accurate for this project. Census data and population studies of the Glassell Park area reveal higher persons-per-household numbers than the city-wide rate. (The Los Angeles Times, for instance, reports 3.3 residents per household in our community.) New data needs to be gathered that accurately reflects Glassell Park.

Given the square footage of each of proposed homes, this estimate seems extremely low, inadequate for a proper estimate of the population impact this development will have. Most of the homes in our neighborhood are much smaller, with more residents. The estimates of household size and overall population in the Abode development impact many other estimates in the DEIR, including traffic and other land use. As such, the city-wide population study cited appears to be inadequate for this project, and the resulting estimate—and the use of that estimate to make other determinations within the DEIR—is invalid.

Promoting further development
The DEIR states that the project is not growth-inducing, but the proposed streets are designed with growth-inducing stub ends, rather than ending as cul-de-sacs. This implies and encourages future development. This contradiction needs to be adequately addressed.

Street extensions
The report describes the extension of both Haverhill and Brilliant Drive, but it does not indicate whether the roadwork for these extensions would be carried out by the City of Los Angeles or by Project's independent contractors. The DEIR also not indicate whether these extensions would be constructed at the 24-foot width in 30-foot right-of-way, compared to the existing road connections, which are extremely narrow. These specifics must be addressed.

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NOISE

Noise pollution from construction and residents
Construction work is inherently noisy. The noise generated by the development of 32 additional homes will be significant, both during their construction and once they are inhabited. The added sound will significantly affect wildlife and current residents.

The structure of the canyon itself, with sound reflecting off the hill, and the structures to be built within the proposed development, with sound bouncing off the proposed retaining wall, will adversely affect the entire neighborhood. Furthermore, since the canyon amplifies sounds, all construction noise will be magnified. There will also be additional significant noise from the added traffic. The DEIR states that operational noise would be “less than significant,” but this analysis does not appear to have considered the points listed here, and so this analysis must be considered inadequate.

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TRANSPORTATION AND TRAFFIC

The analysis provided in the DEIR regarding traffic—both construction traffic and the eventual traffic load produced by resident passenger vehicles—is woefully inadequate. In fact, it is difficult to see how the concerns here can be adequately mitigated, and we hold that the DEIR in this area violates a good faith effort to provide sufficient analysis.

Construction traffic
Haverhill Drive and Brilliant Drive are the only streets that provide ingress and egress for the proposed development. These streets are so narrow that they cannot even sustain current two-way traffic—cars must pull aside behind parked cars for opposing vehicles to pass. The DEIR does not provide an explanation for how construction traffic will access the Abode development, given the narrow streets. Will residents be required to vacate these streets during construction? If so, it is not clear where these residents will park, as neighboring streets are congested and parking is at a premium.

Construction traffic will also need to negotiate hairpin turns along Cazador Street and Ave. 42, turns that are difficult even for passenger cars. Similar turns in other streets in our neighborhood have proven impossible for construction vehicles, resulting in multiple instances of overturned trucks. Other community members will be submitting further comments on this point along with photographic evidence of the narrow and inadequate streets, and overturned vehicles, including concerns about how this will affect the ability of emergency vehicles to reach hillside homes in extremely high fire risk areas.

The roads on Haverhill Drive, Brilliant Drive and Sundown Drive are blacktop poured on top of dirt roads. They are not fully engineered roads. Heavy machinery will impact the structural integrity of these narrow and already unstable roads. The DEIR does not address this issue, nor does it address who will assume responsibility for repairing the damage and wear caused by construction traffic. Other community members will be submitting photographic evidence of the damage to roadways we have already experienced from a relatively smaller volume of heavy construction equipment in recent years (the Abode Development will bring many more trucks, and at shorter intervals, and for much lengthier periods).

While the DEIR states that the developers will “implement a Construction Traffic Management Plan (CTMP),” (DEIR, page 15) this plan is not offered in the DEIR. Given the numerous and severe issues related to construction traffic, this lack of a CTMP does not instill confidence. We should not simply assume that the developer will be able to create a plan that resolves these issues.

Passenger traffic estimates flawed
The traffic estimate provided by the DEIR is fatally flawed, as it is based on an incorrect estimate of residents per household, and so an incorrect estimate of the total population of the Abode development. Given the large square footage of each home, it is likely that the number of residents—and the number of resident vehicles—will be much higher, bring as many as 500 additional car trips into the neighborhood each day. The existing traffic analysis in the DEIR is simply inadequate.

The report does not offer a comprehensive traffic flow analysis that encompasses the larger neighborhood. There is only one direct traffic route from the two closest freeway exits to the Abode site. Virtually all traffic into the Glassell Park and Mt Washington hillside areas comes from the Verdugo Rd. exits off the 2 Freeway, causing constant major congestion at the Verdugo/Ave. 40/Eagle Rock Blvd. intersection and at the El Paso/Eagle Rock Blvd. intersection. The new traffic generated by the Abode development will significantly impact traffic along this already congested route. Data needs to be gathered on the impact of this project on the traffic flows between the project and the 2 Freeway.

Traffic study obsolete
The traffic counts offered in Appendix H-1 are dated December 2014 and so are over two years old. There has been significant development in Glassell Park since that date, and traffic in the neighborhood has increased, based on the observations of long-time residents. As a result, the traffic study upon which the DEIR is based is inadequate.

Existing roads unsafe
Additionally, the public roads directly around the proposed development site have no sidewalks, gutters, curbs or clearances. The current volume of traffic on these streets is already dangerous for pedestrians, bike riders and dog-walkers.

Many roads in our neighborhood are narrow, allowing only one lane of traffic to pass at a time. Dangerous hairpin turns on Ave. 42 and Cazador Street add even more difficulty.

Vehicles on our streets already commonly ignore stop signs and speed limits. Neighborhood Councils that serve our area have heard these complaints for years, and traffic calming measures are needed to manage even the present flow of traffic. Additional traffic from the Abode development will create even more dangerous streets.

Fire, EMT and Police access
20-foot-wide hillside streets -- the size of the existing streets leading into the proposed development -- are standard for hillside developments, but this width does not work for dense developments with significant traffic. Even now, emergency vehicles have difficulty reaching destinations in the hills -- at times, EMT personnel have had to get out of their vehicles and walk to their destination. The increased density that Abode will bring to the neighborhood—both during its construction phase and after completion —will add to these difficulties, creating unsafe conditions.

As stated in the DEIR, the proposed project is in a “very high fire hazard severity zone.” Overpopulating narrow roads with construction and resident traffic will clearly hamper fire and police access. The existing streets around the project were simply not designed to accommodate the amount of traffic that will be introduced by this development.

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CONCLUSION

While there might be ways to mitigate some of these issues, many of the key problems we raise above cannot be successfully mitigated. We feel strongly that Walnut Canyon is an inappropriate site for a housing development of this scale, and that the land should remain natural open space.

We feel that the developers have been misleading throughout the DEIR, consistently underestimating important issues and declaring them “insignificant.” We insist that the Final EIR complies with CEQA guidelines, offering a “sufficient degree of analysis to provide decision makers with information that allows them to make a decision that intelligently takes into account… what is reasonably feasible.”

Specific comments are somewhat generalized as a requested extension of the comment deadline of one week was not granted which would have allowed greater detail and improved grammar. The many contradictions and confusing DEIR structure have delayed thorough review and more complete comments and recommended mitigation and alternatives.


Sincerely,