PROMISES VS. REALITY
As it was also in 1993, Playa Vista is still the Wrong Development in the Wrong
Place. The floodplain of Ballona Creek is not the place for another
mega-development. There is no MetroRail line, and no way to get anywhere except
on jammed up streets.
The Big Picture for you, the Planning Commission, is: Why believe them now, as
they recycle many of the same promises they made in 1993.
They have previously promised to be self-contained, to mix jobs and housing,
to not segregate their affordable housing from the rest, to clean up the toxic
mess left behind by the Hughes Aircraft Company and also comply with City
parkland requirements, to provide police, fire and school sites and ensure their
construction, to have onsite sewage and trash recycling facilities, and to
protect and restore the wetlands.
The problem with their promises is: always read the fine print.
It has been a longstanding promise of the Playa Vista developers that their
project was not like a typical development. Phase one was sold to City
officials using this terminology: “As you know, one of the principal proposals
relating to Playa Vista is that the project be entirely self-contained.” So said
Frank Eberhard, Deputy Director of City Planning in a 3/10/93 letter.
These promises helped get the project support from politicians and some
environmental groups. However, by the time the first phase project was finalized
by the City Council, many of the promises had disappeared, or after approval,
were not enforced by the City.
Instead, Playa Vista is just another undistinguished complex of 4-story condos,
with no thematic cohesion, and little in the way of public amenities.
And worst, Playa Vista degrades the huge investment that the State’s taxpayers
have made in the Ballona Wetlands Park. From behind the scenes, Playa Vista has
asked the Bush Administration to remove pollution standards for their allegedly restored
wetlands, which were created to protect the lands now owned by the
State.
And on top of all of the corporate welfare they have received so far, they still
are using their high-priced sale of the rest of the wetlands to the state as “a
benefit from this project” which is leaving 70% of the site as open space,
claiming it outweighs any unmitigable negative impacts from phase 2. (page 32,
plan amendment staff report to planning commission; also, page 2, ordinance to
adopt Development Agreement).
In fact, these two projects have nothing to do with each other. The State land
will remain State land whether or not the Phase 2 development plan is approved.
And the taxpayers paid through the nose for this land. Playa Vista profited
massively from this land sale. And now they want to profit massively again from
the sale.
WHY HAVE SO MANY OF THE ENVIRONMENTALLY-FRIENDLY PROMISES BY PLAYA VISTA BEEN BROKEN?
When confronted with this concern by commentors on the EIR, the City’s response
is this:
“There is no evidence to suggest that any tract map conditions or mitigation
measures pertaining to the Phase 1 project are not being complied with”. (page
30, plan amendment staff report to planning commission)
THIS IS COMPLETELY FALSE!
1. False Promise of Mixed-Use and Retail in Phase 1; lack of it used to justify
OK of Phase 2
MIXED –USE: They have now constructed 2500 units (according to statement of Doug
Moreland before the West L.A. Planning Commission) which totals 3/4ths of the
development planned in the west end of Phase 1. Numerous sites that are planned
and zoned for “residential over ground floor commercial”, and “office over
ground floor retail” instead have been built entirely with residential or office
uses. There are, so far, only two sites with any mixed-use development and they
occupy only a tiny part of the development. So much for the “pedestrian
friendly, shop in your neighborhood, self-contained” project.
RETAIL:-- Phase 1 has approvals for at least 35,000 square feet of retail. Also,
Condition 96-b-5 says that the Advisory Agency may allow PV to add 7500 square
feet of retail in the west end of Phase 1, increasing the allowed retail to
42,500 square feet. They may be allowed even more retail, as much as 50,000
square feet (Phase 1 Final EIR page f-4 footnote c). The Phase 1 final EIR
states “In regard to the amount of retail proposed for the First Phase project,
the applicant believes that the amount of retail proposed is reasonable given
the number of residents within the west end of the project.” (FEIR page
w-55-16)
--and yet, the need for approval of Phase 2 is because “the missing component of
Playa Vista is the neighborhood serving retail”, said by PV senior vice
president Doug Moreland at the 5/6/04 hearing (transcript page 15, lines 5-6).
--in response to this, the Planning department now claims that the phase 1
retail is not enough to serve the residents of Phase 1, and therefore the
Village Commercial District is needed. But this contradicts their previous
claims in the Phase one FEIR. They then add a “strawman” type argument, stating
that they can’t put more retail in the west end of Phase 1, because it would “be
less convenient for future residents in the eastern portion of PV.” This is a
false argument as the eastern portion is planned to be all office and studio
space, not residential. (Appeal staff report to planning commission, page 8)
2. Traffic promises
Playa Vista says in the latest L.A. Times ad that they “provided $100 million in
traffic improvements”. Actually $30 million is coming directly from taxpayers.
And most of the rest of that money is building roads inside their own property.
That doesn’t benefit either the City or the communities that have to live with
gridlock everyday, nearly all day.
--another part of the “new town” concept was that there would be alleys for
access to parking areas, so that there would not be driveways on the “pedestrian
friendly” streets. There are no alleys. (phase 1 conditions 66, 70 and 84ab)
--also, a traffic signal is required on Lincoln Blvd. at the Culver Loop Road.
(phase 1 condition #118a). Has this been installed? No.
--The Phase 1 road improvements phasing schedule, requires completion of the
Route 90 bridge over Culver Blvd. after completion of 850,000 square feet of
office space OR 2401 dwelling units. Since 2500 dwelling units are nearing
completion or are finished, this condition has not been complied with.
3. Promises of Other Community Serving Uses:
--Condition #19: PV must dedicate a .7 acre site to the city for a police
substation. Has it happened? No. Their soon-to-be opened police substation is a
10 by 10 foot room.
--Condition #21: PV must give a 4 acre site to the L.A. Unified School District.
The site chosen by PV is toxic and was rejected by the school district.
-- Condition #114 says that construction of a fire station must be begun once a
maximum of 2000 residential units or 750,000 square feet of office space has
been built. Has this happened? No.
4. the false Promise of On-site recycling facilities:
These environmental facilities were a major part of the promise of a “self
contained” development. Playa Vista even set aside land for the facilities, and
then backed out of the promise to build them. They now propose just more
development on the sites.
It is stated that the City Planning director and City engineer have determined a
recycling center is not feasible. (Phase 2 DEIR page 639) How was this
determination made?
5. False Concern for “affordability”
--phase 2 does not provide any new affordable rental units. Instead, they will
shift 83 low and low-moderate income rental units from the 2 buildings in Phase
1 that have them into somewhere in Phase 2, therefore, it’s no net increase.
--Phase 1 required that “affordable housing shall be distributed throughout the
project”. (Condition #131). So when only two buildings on the far northwest end
contain all the affordable rental units, is this compliance with this
condition?
6. Locating active parks on toxic sites that may never be cleaned up
Due to the difficulties that Playa Vista is having with cleaning up the many
toxic sites on their land, It is becoming apparent that Playa Vista is building
on every available lot that has been declared “clean” by the Regional Water
Quality Control Board, and the only lots available to fulfill their parks
requirements will be lots that may or may not be cleaned up. The means that they
may not, for a long time, comply with their Phase 1 active parkland promises.
Additionally, Playa Vista’s uncharitable attitude shows in the EIR’s
discussion of complying with the City’s parkland requirement, which is 4 acres
per thousand residents. Playa Vista doesn’t want to comply, even though they
complied with the rule in the Phase 1 project.
Also, several Conditions of Approval of phase 1specify provision of active
parkland with each 800 units of housing, and yet, after construction of 2500
units, (totaling 40% of the square footage of the combined residential and
commercial project, by the way), which could house around 5500 people, the
required 22 acres of active parkland does not exist. Instead, around 5 acres is
currently available. Moreover, several areas shown as active parkland in the
Phase one approval documents have, instead, been developed with condominiums,
space for future road widening/light rail, etc.
Furthermore, the deletion of phase one active parkland lot #113 is explained
away (page 34-35 of 6/2/04 advisory agency decision letter) with the claim that
phase 1 and the campus projects include 31.14 acres of active open space. This
claim is not supported by any maps or other supporting documentation, and is
also extremely unlikely for the reasons state in the previous paragraph. Please
explain exactly which lots are now proposed as the active parkland in phase 1 in
fulfillment of Conditions 22 and 30.
Bike paths over Ballona creek
--With the addition of a 5th and 6th traffic lane on the Lincoln Blvd. bridge
over Ballona Creek, which is a phase 1 mitigation, it is becoming nearly
impossible for bicyclists and pedestrians to safely cross the Creek to the
Ballona Creek bike path or to destinations to the north. Playa Vista should fund
at least one and maybe two separate bike/pedestrian only bridges over the Creek,
on either side of the existing bridge.
--the City’s response to this request is that no offsite bike lanes are planned
because there are no significant impacts outside of Playa Vista identified in
the EIR. (Page 21, plan amendment staff report to planning commission, also page
9 of appeal staff report to planning commission in relation to traffic). If this
is true, why does the City then, elsewhere, claim that there are significant
unmitigable traffic impacts and that they must adopt a Statement of Overriding
Considerations?
LAND USE LIES: IS PHASE 2 A MASSIVE INCREASE IN DENSITY OR A SCALED-DOWN PROJECT?
--Final EIR response 30-5 says the Project will decrease office uses by 90% and
decrease retail by 76%;
in reality the project entails a massive zoning increase from the 108,000
square feet that is allowed by the current specific plan, as stated on Draft EIR
page 10.
--the 6/2/04 advisory agency decision letter repeats this false claim on page
32: “Development to the maximum extent permitted under the existing specific
plan would be more intense in a number of respects…as such the proposed project
represents a substantial decrease in traffic generation…”
--The Plan Amendment staff report to the Planning Commission continues with this
false claim on page 4, and on pages 11, 12, and 14 of its exhibit I
--compounding the lies, the City states that building only 108,050 square feet
of office space, as the specific plan actually allows, (also called Alternative
2), would still “continue to generate significant impacts on traffic, regional
air quality, construction noise and solid waste disposal.” (6/2/04 CEQA findings
page 162-163) How was this conclusion reached? It seems ridiculous on its face,
especially since that would equal the size of one of the two Water’s
Edge/Electronic Arts buildings.
In fact: this claim is actually contradicted by the Phase 2 traffic study in the
DEIR volume XX, pages VII-1a and VII-2.
WHY ISN'T THE ENVIRONMENTALLY SUPERIOR ALTERNATIVE CHOSEN? AND WHY ARE FALSE CLAIMS USED TO RULE OUT ALL ALTERNATIVES EXCEPT THE DEVELOPER'S PREFERRED PROJECT?
--our comment printed in the Final EIR comment #30-121 says this is one of the
few remaining open spaces available in the city that could be used to meet the
bacteria storm runoff cleanup requirements, solving the city’s liability,
providing $$ to PV by buying their land, and by providing parks and wetlands for
the public. Although such an alternative was requested at the hearing on the
Notice of Preparation for the DEIR, the City and developer’s consultants chose
not to study it.
In fact, such a natural method of cleaning runoff could save the City an
enormous amount of money. Contrast this to a coalition of L.A. County cities
that claimed for the entire County to comply with the runoff rule, the costs
could be as high as $50 to $283 billion. The purchase of the 200 acres in the
eastern part of Area D, which includes Phase 2 and the Studio/Campus area, could
be accomplished for a tiny fraction of these costs and provide an enormous
benefit. PV President Steve Soboroff recently said the 114 acre hangar complex
was for sale for $45 million. This is a bargain and could solve a big problem
for the City!
--the so-called “no project” alternative is ruled out with the claim that it
would not result in the privately funded remediation of on-site groundwater
contamination. (DEIR page 10, Final EIR page 18). This claim is absolutely
false, as the landowner is under order from the Regional Water Quality Control
Board to clean this up whether or not they do any other development of the land.
--alternatives 1 and 2, the no-project alternatives, are claimed to be worse
for plant and animal life than the proposed project, because there is no
restoration of the damage done by the landowner. This is a self-imposed choice
by Playa Vista to handicap the two more environmentally-friendly alternatives.
Also, here we have a developer creating a problem, allegedly as part of Phase 1,
then volunteering to fix it in Phase 2 as long as they get credit for it and can
use it to rule out all versions of the project except the one they want. It is a
contradiction to their longstanding claim that each project “stands alone” as
the damage is placed in Phase 1, and the mitigation is placed in Phase 2.
It is also a very interesting contrast to the claims of Playa Vista’s
lawyers in the 1994 Phase 1 CEQA lawsuit. Attorney Robert Crockett told the
court “The City has not split approvals for the same physical property.”
(4/11/94 Real Party’s Opposition Memorandum, page 29)
THE FALSE CLAIM OF “INDEPENDENT UTILITY”: ARE PHASE 1 AND 2 INEXTRICABLY LINKED
AND THEREFORE WAS THE PHASE 1 APPROVAL AN ILLEGAL ‘PIECEMEALING’ AND A BREAKING
OF THE BIGGER PLAYA VISTA PROJECT INTO SMALLER PIECES IN ORDER TO MAKE IMPACTS
APPEAR SMALLER?
As our discussion of the alternatives analysis shows, the claim by Playa Vista
and the City that Phase 1 was a “stand alone” project, which did not have to
rely upon any other development for its viability, was a lie, a false legal
strategy designed to fool the Court.
In our Phase 1 CEQA lawsuit, the City stated “Project splitting could not
occur since the first phase is a stand alone project” (6/8/94 Closing Brief page
4).
The claim is repeated in the Phase 2 appeal staff report to the planning
commission, page 10 & 11, “The First Phase project is currently under
construction, and is functioning independently of the Proposed Project.”
Phase 1 was approved with the claim that it was a stand-alone project, and
not an integral part of a “master plan”, such that it could function acceptably
and keep its commitments even if no second phase was ever approved. This
argument was advanced by the City and Playa Vista in order to avoid performing
the required full California Environmental Quality Act analysis of the entire
master plan and revealing and committing to mitigations for the master plan’s
impacts.
The main argument put forth by Playa Vista to support approval of Phase
2 is that the “missing component is the neighborhood serving retail”, which is
allegedly absent from Phase 1. This statement was made by Doug Moreland,
representing Playa Vista, at the Advisory agency hearing on May 6, 2004. In
fact, as response W55.18 in the Phase 1 FEIR states, “in regard to the amount of
retail proposed in the first phase project, the applicant believes that the
amount of retail proposed is reasonable given the number of residents within the
west end of the project.” So, while this justification for approving Phase 2 is
bogus and contradicted by their previous statements, the developer’s claim also
contradicts their claim that Phase 1 is “stand alone” and has “independent
utility”, since they now claim that Phase one can’t keep its promise of being a
“self contained” project unless Phase 2 is also built.
The “stand alone” claim is further contradicted by Playa Vista’s scraping
and draining of vegetation and ponds that have covered much of the Phase 2 site
in order to construct stormwater management facilities for Phase 1. This
scraping and filling, which actually facilitates the development of phase 2 by
creating the manufactured illusion that the site is a barren wasteland, is still
claimed to be part of phase 1. Yet, in the Phase 1 approval process, when the
City’s public works department in comment and response number W-4.4 asked for
more explanation of a hydrology report’s discussion of putting in a temporary
detention basin, the phase 1 final EIR’s response was to describe it as a two
acre foot capacity basin located just west of the Phase 1-F, and just east of
the aircraft hangars. This map, on page F-37 of the Phase 1 Final EIR, Part 2
Corrections and Additions, shows the detention basin as nowhere near where the
Phase 2 detention basin actually has been constructed. In fact, the size of the
basin on this map is around 1 acre, which is nowhere near the huge amount of
land that was graded for the basin that actually was built. Therefore, when the
City and Playa Vista were asked about the location of a future detention basin
to serve Phase 1, they did not respond that they would need to flatten, drain
and scrape the Phase 2 site in order to construct it. Therefore, the basin they
have constructed was not described or reasonably expected to be part of the
Phase one development.
In response, the City claims that the “map on page F-37 of the Final EIR shows a
potential rather than a specific site and does not specify a particular size for
the temporary detention basin.” (appeal staff report to planning commission
page 11)
This is simply false and unsupported by any evidence, and is refuted by the
evidence in the previous paragraph.
ILLEGAL SITE SCRAPING/GRADING WAS DONE TO WIPE OUT THE BASELINE FOR BIOLOGICAL IMPACTS ANALYSIS
The natural biology of the site was illegally altered by the landowner after the
filing of the notice of preparation for the EIR, in order to create a false
“baseline” and to make the site look like a barren wasteland, instead of the
wetlands vegetation and ponds that covered much of the site before the illegal
grading;
--the 6/2/04 advisory agency decision letter states on page 33: “There are no
onsite wetlands beyond the .7 acres of wetland previously permitted for filling
that would be impacted by the project…currently there are approximately 1.5
acres of habitat area with native species…”. But this is only due to the
illegal grading of the entire Phase 2 site, and is in fact contradicted by the
photos of ponds and vegetation on a large part of the site taken in January of
1997. (submitted in response to the notice of preparation by Kathy Knight for
the Spirit of the Sage Council)
--“This highly disturbed area still provides foraging opportunities for raptors,
(like Cooper’s Hawk), and some marginal nesting habitat for common migrant
birds.” –(DEIR p. 52, and 6/2/04 advisory agency letter, CEQA findings page 45)
--the justification for the illegal grading of Phase 2 reads word-for-word the
same as Playa Vista’s attorney George Mihlsten’s speech to the Building and
Safety Commission when these after-the-fact permits were appealed by the Ballona
Wetlands Land Trust. This is why we believe much of the EIR was written by
attorneys, and that the City planners merely rubber-stamp OK’d the work.
--By illegally scraping the Phase 2 site bare, Playa Vista hopes to avoid
having to replace wetlands and wildlife habitat because they are claiming the
scraping was authorized and analyzed as part of an earlier project. We believe,
however, that major parts of the site would likely be considered wetlands under
the Army Corps standard due to the substantial areas of ponding and vegetation
during wet winters. PV is trying to rely on a wetland delineation from 1991,
which was done after a 5 year drought. Playa Vista’s 1991 delineation of other
parts of their land was widely criticized for the under-reporting of wetlands by
the State Department of Fish and Game and others.
THE PHASE ONE PROJECT APPROVED IN 1993 AND 1995 MUST BE BUILT FIRST AND KEEP ITS COMMITTMENTS BEFORE PHASE 2 APPROVAL
Making certain Phase 1 keeps its commitments is the heart of what condition 116
is about. In response to questions about Phase 1’s Condition 116, the city
claims that Phase 1 would have to more than double its office space trip cap
before any reduction would be required in phase 2. (FEIR p. 471) How is this
ambiguous interpretation reached, since this is not what condition 116 says?
It is obvious that Phase 2 should not be considered for approval
before Phase 1 is completed and has kept its many commitments, commitments that
were made in exchange for being allowed to build in such an environmentally
sensitive area. One needs to look at the “legislative intent” behind the
splitting of the master plan into phases.
In a letter from Councilmember Ruth Galanter to City Planning
dated June 18, 1990 sent as a pre-draft comment, and contained on page 15423
through 15426 of the Phase 1 administrative record, she stated:
“Analyze a phasing program with reporting milestones that can be used to
determine project’s success in reducing trip generation, VMT, water consumption,
solid waste generation, etc; such a phasing program should include prescribed
reductions in buildout or specific uses within subsequent phases if milestones
are not achieved.”
Later, when asked about this by the Daily Breeze newspaper,
Galanter stated (in the April 7, 1991 edition) “Nearly one year ago I proposed
that Playa Vista be built in phases so that if the first stage causes any
negative impacts, those impacts must be eliminated before a future phase could
be built.”
It is therefore obvious that consideration and approval of Phase
2 with so little of Phase 1 actually constructed, and the actual impacts
unknown, shows that Phase two cannot be legally approved given the commitments
that were made as part of Phase 1.
SEVERELY UNCERTAIN SUPPLY OF DRINKING WATER
Please explain how an adequate water supply is available given the
announcement by scientists at the United States Geological Survey on June 17,
2004, that “the drought gripping the west could be the biggest in 500 years”.
(L.A. Times June 18, 2004, Page A-23)
SURFACE WATER IMPACTS
The EIR Overstates Surrounding Area Surface water pollution, so Playa Vista
Pollution looks Benign
Surface water pollution from the tract will degrade water quality
in wetlands, creekbed wildlife habitat and other areas originally promised as
mitigation in Phase 1, tracts 49104 and 52092;
The phase 2 project is claimed to cause “no net increase” in pollution loads
(DEIR page 479), “due to significant natural pollutant removal provided by the
freshwater wetlands system of offsite drainages.” However, the claim that
offsite drainages produce such huge volumes of pollutants compared to those from
Phase 1 and 2 development is suspect because, as the Phase 1 DEIR reveals on
pages V.C.2.B-5 & 6, “build-out to current zoning was used for the calculation
of off-site pollutant loadings.” This analysis assumes that the largely R-1
zoned single-family neighborhoods that make up the bulk of the “offsite
drainages” are built out to the maximum legally allowed lot-coverage, with
minimal yard widths. The fact that most of these 1950’s-era homes have large
unpaved backyards, allowing absorption rather than running-off, indicates that
a significant over-assumption of runoff pollution may have occurred, especially
if such methodology was used in the Phase 2 EIR. Again, due to the confusing way
the Phase 2 EIR water quality sections are written, it is impossible to
determine how off-site drainage pollutant loads were computed.
It is impossible to determine how many pounds of additional pollutants such as
Total Suspended Solids and others will be added into the Riparian Corridor due
to the development of Phase 2. Instead, pollution loads are revealed only for
after runoff has flowed through the Riparian Corridor and been cleaned up. This
prevents the public and decision makers from knowing the impacts of Phase 2
development on this creekbed which is serving as mitigation for loss of natural
wildlife habitat. In contrast, the Phase 1 EIR revealed exactly how much
additional pollutants would be created by the development compared to
pre-development conditions. See Phase 1 administrative record volume 16, pages
10193, 10214, 10235, and 10256.
WHY DOES THE EIR SHOW TWO MYSTERY FLOOD CONTROL BASINS IN THE BALLONA WETLANDS STATE PRESERVE?
The EIR contains a map showing two new detention basins in the State-owned
Ballona Wetlands that do not exist currently. On Phase 2 DEIR page 371, the
“Playa del Rey Detention Basin”, and the “SCCG Detention Basin” are shown as
part of the proposed project. There is no other text describing these basins, or
the environmental impacts from their construction and location in the fragile
wetlands. Is this another attempt to sneakily approve a project feature under
the public’s nose, as Playa Vista has tried to accomplish with the floodwater
basin inside the Phase 2 site?
PLAYA VISTA IS ATTEMPTING TO EXEMPT THEIR RIPARIAN CORRIDOR AND FRESHWATER MARCH FROM THE U.S. CLEAN WATER ACT
--The Friends of Ballona Wetlands urged the City to require that storm water
runoff “meets or exceeds all regional water quality control board urban storm
water standards before reaching the Riparian Corridor and the Freshwater marsh.”
(transcript, 12/12/02 hearing on Phase 2 Notice of Preparation of EIR, page 62).
Similar comments are made by Santa Monica Baykeeper on page 85 & 86 of that
transcript. Why, instead, has the City and Playa Vista attempted to back down on
their promises to give these two wetlands the full protection of the Clean Water
Act?
GROUNDWATER TOXICS: NO ASURANCE THAT CLEANUP WILL OCCUR
Why does the City continue to hide the map of the toxic groundwater plumes? Why
do they keep referring us to maps that don’t exist? (FEIR page 966)
We submitted very detailed comments on the toxic groundwater
issue and most of the City’s responses were non-responsive or evasive. I will
restate my comments and questions that were ignored:
“Missing from the baseline analysis is a map showing the groundwater
contamination plumes under the site……The final EIR must show how much progress
has been made in the cleanup of the groundwater plumes since their discovery in
the mid-1980s. The public and decision makers have a right to know how much
contamination was in the groundwater when it was discovered, how much has been
cleaned up thus far, and how much is projected to be cleaned up with current
available technology by 2010 or longer.”
For example, the City’s Final EIR response number 30-41 refers to a “figure 10
in Draft EIR appendix J-3”. This document does not exist in any version of this
document, either in print, on the CD-rom, or on the internet. Furthermore,
response 30-42 refers to an August 6, 2003 report which is currently under
review by the Regional Water Quality Control Board. Because the water board has
not responded to this report, and no remediation plan exists, how can the City
Council make any conclusion on whether this site is safe for people to live, or
for public parks to be located there?
METHANE AND SOIL GAS:
the City gives a Non-Response to the complaint that “the 50 foot gravel zone
methane mitigation is a failure”—(page 25, Plan Amendment staff report to
planning commission).
UNACCEPTABLE AND UNCERTAIN TRAFFIC MITIGATION
As other groups will show today, the traffic study uses neighborhood streets to
carry Playa Vista’s traffic, a violation of the L.A. General Plan policies
16-1.1 a & b, and 16-2.1 (see Mar Vista Community Council comments dated
12/9/03)
--traffic mitigation would require removal of some of the Culver Blvd. median
park which is owned by the MTA. What is the compensation for this?
--another traffic mitigation is removing a roadblock by making Centinela a
public street all the way south to Teale/Bluff Creek Dr. This roadblock was
added to the project in 1995 as part of the DreamWorks project, as the road was
open in the 1993 version.
Often, the traffic analysis in the EIR tries to have things both
ways. First, they say that all traffic will be "mitigated to a level of
insignificance". Then the staff report concludes that there still will be a
significant, unmitigable traffic impact and so they recommend adoption of a
statement of overriding considerations. The reality here is that there is no
right-of-way left on the roads that can be used for more lanes. There is no way
to narrow sidewalks to add more lanes, as they would become unsafe for
pedestrians. In fact, of the two places outside of Playa Vista's property where
there is land left that they can convert into a lane, one is on Centinela south
of Culver Blvd., which is feasible, but the other would chop off part of the
landscaped Culver Blvd. park median that is owned by the MTA. Cutting into the
Culver park is unacceptable. All other traffic "improvements" are lane
restriping, which means narrowing lanes, and tweaking the computers that control
traffic signals. Performing all of the mitigations that are feasible will
actually accomplish very little in the way of adding capacity to the road
system, as the system is full.
In summary, there is very little left that can be done without causing major
"pain" to neighborhoods or business districts in order to expand roads
and "mitigate" traffic. So, most of Phase 2 traffic will not be
“mitigated” at all.
VASTLY OVERSTATED RELATED PROJECTS LIST IS USED TO MAKE PROJECT IMPACTS APPEAR INSIGNIFICANT
Overstated year 2010 development numbers are used to make it appear
that other developers are planning 100 times as much commercial space and 4
times as much residential units, so therefore PV’s impacts are insignificant.
This strategy was also used in the 1993 first phase project.
Their claim that traffic impacts will be insignificant is based
on the future year 2010 scenario that includes another 30 million square feet of
office space and 9000 more residential units, and since Phase 2 is only a small
part of that, its impacts are considered insignificant. But several of the
largest projects in this "related projects" list are dead, rejected,
or have been already built. For example, the Howard Hughes Center is 80%
completed. The LMU expansion is 100% complete. The EIR treats both as unbuilt.
The LAX Northside and Continental City projects, which total 7.6 million square
feet of office space, have been approved for 20 years and have never been built.
In fact, both are owned by LAX, which has different plans for the sites relating
to airport expansion. Also, the LAX expansion itself has been dramatically
scaled back by the Mayor, Councilwoman Miscikowski and the recent unanimous vote
of the Planning Commission to approve only a tiny part of the expansion plan.
In sum: at least a third of the 30 million square feet of added office space in
the region is either built long ago or cancelled and should not be used to make
Playa Vista Phase 2 appear insignificant.
I haven't been able to check out whether the residential projects in the list
are built or not. But since commercial space creates a lot more traffic than
residential space, it is obvious that the 2010 traffic scenario is vastly
overstated, and therefore, Phase 2 will likely create a significant impact based
on what is likely to occur by 2010.
DESTRUCTION OF NATIVE AMERICAN GRAVESITES
--they City claims that the riparian corridor cannot be shifted to the north to
avoid Indian burial sites. On the basis of what evidence, besides the
developer’s own desire to develop as much land as possible, is this assertion
based upon? (6/2/04 advisory agency decision/ CEQA findings p. 79)
