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City Planning alerted to risks of increased building

Updated: Mar 30, 2023



ENV-2020-6762-EIR

EMAIL TO: HousingElement@lacity.org

USPS TO: Cally Hardy, City Planning Associate


City of Los Angeles Department of City Planning

200 North Spring Street, Room 75

Los Angeles, CA 90012





8/26/2021



Re: ENV-2020-6762-EIR

Draft Environmental Impact Report for the

Updates to the Housing Element and the Safety Element


Dear Ms. Hardy:

The Del Rey Residents Association (DRRA) is a 501(c)(4) social welfare organization that

represents the interests of the residents of Del Rey. Thank you for the opportunity to

comment on the Housing and Safety Elements.


BACKGROUND

Del Rey has about 35,000 residents in an area of Los Angeles bounded by

Lincoln Blvd., Washington Blvd., Culver City and Jefferson Blvd. It is transected by

THREE creeks: Ballona Creek, Centinela Creek and the Sepulveda Channel.

The federal Army Corps of Engineers, the Los Angeles County Dept of Public

Works and the City of Los Angeles all have different responsibilities for the

creeks.


SAFETY ELEMENT

The Safety Element must address the evacuation problems we face during power

failures or as a result of floods, fires or earthquakes.


Del Rey is in a flood plain.

In earlier years—long before modern development and density—LA experienced

catastrophic floods. The year 1862 was the largest flood in recorded history for

the area. 1


1 The Great Flood of 1862 was caused by a series of powerful storms that began over the Pacific Ocean. These storms were so strong because local temperatures were higher than normal—the winter of 1862 was unusually warm in California. ... The higher temperatures caused more ocean water to evaporate into the air. --


In the 1938 flood, the Los Angeles River was flowing at about 99,000 cubic feet

per second. Our Ballona Creek is a tributary. It is unlikely that the levees will

withstand a major flood.


We wrote about our flood concerns in our Ballona Comment letter during the

process of the State’s proposed restoration of the Ballona Creek Wetlands.


The 2018 Local Hazard Mitigation Plan (LHMP) does not include a flood map

(Figure 10-7 on page 10-14 is missing). It lists nineteen flood-related issues on

page 10-40 (see attached). What is the current status of each of these floodrelated

issues? Have any of them been satisfactorily addressed? Does the City’s

Flood Map include Del Rey and the Ballona Wetlands?


Del Rey lies within a Tsunami Zone.

Because of the creeks (Centinela Creek enters Ballona Creek at the peninsula

known as Bird Island) Del Rey has a number of cul-de-sac streets. As a result,

there are few north-south or east-west traffic corridors. We are left to count on

the 405 freeway to accommodate an evacuation. What safety plans are in place to

accommodate such an evacuation, and how are they communicated to local

residents?


Del Rey adjoins the gas storage fields and related facilities in the Ballona Wetlands.

Our gas storage concerns have been previously documented in our Ballona

Comment letter.


It has been six years since the Aliso Canyon gas incident. What is the plan for

ensuring the safety of our community and preventing a similar incident? How will

the community be kept informed during a disaster, and educated in advance?

Which pages in the 2018 LHMP address the specific concerns related to gas

storage in the Ballona Wetlands?


HOUSING ELEMENT

The housing element must face the reality that up-zoning and density building

will not alleviate homelessness. It is a specious theory for many reasons, and one

this group has written about many times.

We agree with funding permanent supportive housing and programs that keep

people from falling into homelessness. We disagree that up-zoning/increased

density is the way to accomplish this goal.

In the Housing Element and the Safety Element, please include the comments and

concerns specified in our Comment Letter on the Community Plan dated

September 14, 2020.


TIMING

The Housing Element Update is required to be adopted by October 15, 2021,

and to remain in effect through October 2029; the draft EIR Inventory of

Properties has yet to specify the parcels for rezoning.

This Housing update is being reviewed before the Planning Department has even

completed its update of the Palms/Mar Vista/Del Rey Community Plan.

There remain many issues of unintended consequences that should be addressed

in the Housing Element, including the effects of COVID-19 on housing needs,



infrastructure adequacy, existing zoning and allotment of new units, traffic,

parking, overcrowding, and general quality of life.


CALCULATION OF REQUIRED HOUSING UNITS

The Housing Element should include an assessment of the number of units

already allowed by the City’s existing zoning. Rezoning a site does not mean it

will be built; instead, it may encourage developers to wait for the next Housing

Element when the State may allow projects with ever increasing height and

density. The existing ‘allowance’ from prior re-zoning should be available to offset

the ‘shortfall’ from prior years.


Per the Initial Study, the current calculation of the required RHNA includes not

only the current eight-year projection (as in prior cycles) but also 100% of the

cumulative shortfall from prior years. This is the first Housing Element that this

calculation is in effect; instead of putting 100% of the shortfall into this cycle, the

shortfall should be spread over several cycles.


Please contact us if there are any questions about our comments. This process will have

a critical and ongoing impact on our community.


Our Land Use committee drafted this letter, and it was approved by our Board at its

meeting on Monday, August 30, 2021.


Regards,

Elizabeth Campos Layne

President, Del Rey Residents Association


cc:

Representative Karen Bass

Representative Ted Lieu Lieu.staff@mail.house.gov

State Senator Ben Allen

State Assemblymember Autumn Burke

State Assemblymember Isaac Bryan

County Supervisor Holly Mitchell asargsyan@bos.lacounty.gov

Councilmember Mike Bonin councilmember.bonin@lacity.org

Vishesh Anand vishesh.anand@lacity.org

Del Rey Neighborhood Council board@delreync.org

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