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