second + pch comment letter recirculated draft eir

8/7/2019 Second + PCH Comment Letter Recirculated Draft EIR

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Egrets Not RegretsP.O. Box 3825 Seal Beach, CA 90740

April 25, 2011

Via Email

Craig ChalfantDepartment of Development Services333 W. Ocean Blvd, Fifth Floor

Long Beach, CA 90802

RE: Second + PCH Project Recirculated Draft RDEIR, Comment Letter

Mr. Chalfant,

Following is my comment letter on the Second + PCH Project Recirculated Draft Environmental

Impact Report (RDEIR). In short, this RDEIR is flawed and must be revised and re-circulated.

Though the RDEIR states that comments on the first Draft RDEIR were considered and

addressed through revisions as appropriate, that clearly is not the case. Many very valid

comments made on the first RDEIR were either fundamentally ignored or totally misinterpreted.

The comments below pertain to this RDEIR and are generally arranged sequentially as the

identified issues appear in the RDEIR.

II.3 Site Background and Existing Conditions

1) Paragraph 1 contains the following footnote, The SEADIP states that Subarea 17 is

developed with commercial uses in accordance with the CR Zone. Per conservation with the

Long Beach Department of Development Services, the CR Zone is equivalent to the Community

Automobile-Oriented (CCA) District. So? There is no CCA district within SEADIP and noestablished need to provide it for comparative purposes. What is the significance of the CCA

District and what bearing does it have on this Project RDEIR? Is the applicant attempting to

change the current zoning to CCA District? Either remove all references to the CCA District

(here and in the land use section), or explain its applicability for this document.


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Second + PCH Project Recirculated DEIR Comment LetterSCH No: 2009101014 Page 3

Page II-18 of the RDEIR identifies that 219,134 square feet of public open space would be

provided throughout the development (over 46%). However, of this, approximately 70,633

square feet (approximately 14.9%) is on the second and third levels of the development and

within the building footprint. Using this in the open space square footage determination is not

allowable under SEADIP. Only on the ground level square footage should be utilized in open

space calculations. ANY references to 219,134 square feet of open space should be removed

throughout the RDEIR as this number overstates the amount of available open space.

Further, page II-18 of the RDEIR identifies that approximately 148,501 square feet

(approximately 31.2%) of public open space would be located on the ground level and includes

the Wetlands Plaza, Great Space, Marina Plaza and landscaped walkways between the

buildings. However, Figure II-17 shows that the median of Marina View Lane is counted as

open space. Roadway medians are not open space. The provided open space determination is

incorrect and artificially high.

II.6 Construction Schedule/Phasing:

1) At the Bixby Village Homeowners Association (BV HOA) meeting on May 10, 2010 the

developers explained that subsequent to Project approval by the California Coastal Commission

(CCC), there would be a 6-8 month architectural design period that would precede the 30

month construction window. This 6-8 month period is not accounted for in the construction

timeline. Is there a 6-8 month architectural design period prior to the commencement of

construction? If so, the schedule/phasing needs to be reworked, and impacts re-analyzed using

the new project opening year.

2) The Project is scheduled to open in 2015. This is predicated on Planning Commission

approval in summer 2011, and City Council approval immediately thereafter. Since the RDEIR

must be revised and recirculated to address the many inadequacies, the schedule will need tobe extended out to address this additional delay.

II.7 Project Approvals:

1) The applicants began their Public Relations campaign for this Project in 2008, or thereabouts.

Since that time, they have consistently and frequently mentioned off-site improvements such

as landscaping from the project site to the 22 freeway, median/sidewalk beautification and

undergrounding of utility lines. It was also consistently mentioned that these improvements

would be addressed in the Development Agreement (DA), the production of which was in

process. That a DA was in the works was widely reported in the local media. Moreover, at the

Citys public scoping meeting (October 7, 2009) and again at the Citys community meetingabout the Project (November 16, 2009), the Director of Development Services confirmed that a

DA was in process and would likely include these off-site improvements, in addition to other

features. At the BV HOA Meeting held on May 10, 2010, the Project applicant again mentioned

the off-site improvements in conjunction with their development. During Beer & Politics on the

June 29, 2010, developer David Malmouth again explained that they would be needing a DA

(video can be downloaded here: www.beerandpolitics.org). Additionally, I raised this issue in my

comment letter on the first DEIR.


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The RDEIR does not identify that a DA and its components are part of this project, nor are any

potential off-site improvements analyzed in the subsequent resource sections. This omission is

particularly relevant given that the landscaping they seemingly want to conduct and the utility

line undergrounding they are recommending are located within and/or abutting the Los Cerritos

Wetlands.

What happened to the Development Agreement? As it was discussed at both the Citys scoping

and community meetings, and the developer continually mentions needing one, it is presumably

part of this Project.

Is the DA part of this Project? If so, it must be identified in the RDEIR, the impacts from any

potential off-site surface disturbance analyzed (particularly impacts associated with disturbance

proposed for the Los Cerritos Wetlands), and the entire document re-circulated for public

review. If the DA is not part of the current Project, but will be identified and analyzed after

Project approval, how is this not project segmentation, especially given that the applicant and

City management have consistently described the DA and off-site improvements in conjunction

with the current Project, and without the Project there is no need for a Development

Agreement?

IV.A Aesthetics and Views:

1) The RDEIR significance criteria relative to shade/shadow impacts is (top of both IV-A-15 and

16), The project would cast new shadows on off-site shadow-sensitive uses more than three

hours between the hours of 9:00 A.M. and 3:00 P.M. PDT, between early November and early

March or more than four hours between the hours of 9:00 A.M. and 5:00 P.M. PST between

early March and early November. This criterion is footnoted and described accordingly, The

City of Long Beach does not have any adopted standards or thresholds regarding shade and

shadow effects of development projects. However, the City of Los Angeles has adoptedthresholds for shade and shadow impacts that may be utilized to evaluate adverse effects on

surrounding shade-sensitive land uses, and, City of Los Angeles. L.A. CEQA Thresholds

Guide. 2006. Section A.3, Shading. Pages A.3-1 to A.3-10.

However, the City of Los Angeles LA CEQA Thresholds Guide states (page A.3-2), A project

impact would normally be considered significant if shadow-sensitive uses would be shaded by

project-related structures for more than three hours between the hours of 9:00 A.M. and 3:00

P.M. PST (between late October and early April), or more than four hours between the hours of

9:00 A.M. and 5:00 P.M. PDT (between early April and late October.)

Several things:

1a) Why does the RDEIR state that it will be using the significance criterion from the LA CEQA

Thresholds Guide, then not use the criterion from the LA CEQA Thresholds Guide (differences

between the two are underlined above)?

1b) The RDEIR assumes impact analysis is only appropriate in determining significant impacts

for off-site shadow sensitive uses whereas the Thresholds Guide assumes impacts are


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significant if shadow-sensitive uses would be shaded by project-related structures. The

Threshold Guide does not restrict analysis to only off-site receptors, so why did the RDEIR?

The Threshold Guide defines shadow-sensitive uses as (p. A.3-1), routinely useable outdoor

spaces associated with residential, recreation, or institutional (e.g. schools, convalescent

homes) lands uses; commercial uses such as pedestrian-oriented outdoor spaces orrestaurants with outdoor eating areas; nurseries; and existing solar collectors. These uses are

considered sensitive because sunlight is important to function, physical comfort, or commerce.

Since the Project is providing shadow-sensitive uses, (i.e. Great Space, etc.) potential on-site

impacts from project related structures should have been analyzed. They were not. The

RDEIR significance criterion restricts impact analysis to only off-site receptors and ignores

shadow sensitive uses onsite. The criterion utilized in the RDEIR is not just inconsistent with

the criterion it stated it was going to follow, it is also inappropriately limiting. It appears as

though this RDEIR is gerrymandering the significance criterion so as to avoid identifying the

potential for significant impacts onsite, and that is not acceptable under CEQA.

1c) The time periods assumed in the RDEIR significance criterion are exactly backwards from

that contained in the Thresholds Guide (Pacific Standard Time vs. Pacific Daylight Time).

Additionally, the months identified in the time frame differ. Why the discrepancy?

The shade/shadow analysis must be revised to examine impacts during the appropriate

timeframes/seasonal periods (consistent with the LA CEQA Threshold Guide) and must also

conduct an on-site analysis to examine impacts to ALL shadow sensitive uses (not just those

off-site). The RDEIR must be revised to address these flaws and recirculated.

2) Exhibits A.3-4, A.3-5 and A.3-6 of the LA CEQA Threshold Guide (page A.3-8 through A.3-

10) present a shadow plotting methodology, shadow projection diagram and shadowcoverage diagram, respectively. Why were these not followed?

As illustrated in Exhibits A.3-5 and A.3-6, since the significance criteria establishes a range of

shadow times (i.e. from 9 P.M. to 3 P.M./5 P.M.), the diagrams present a range of coverage

(i.e. at 9 a.m., the shadow is at A point; at 10 a.m. the shadow is at B point, at 11 a.m. the

shadow is at C point, and so on until the 3 P.M./5 P.M. end of the range). Since the Project EIR

adopted the City of Los Angeles thresholds as established/defined in the Threshold Guideline,

why did it ignore the corresponding analysis methodology? Figure IV-A.16 of the Project EIR

represents a single shadow per building per season, and does not present the information as a

range, as recommended in the Threshold Guide. Only present is an arrow demonstrating which

direction the shadow will travel, it does not illustrate the shadow coverage.

This is particularly relevant given that the Project site contains shadow-sensitive uses and it

appears as though these shadow sensitive uses would be bathed in shade during all seasons

(RDEIR, Figure IV.A-16). The only way to determine if the Project would cast shadows for a 3

hour or greater period on shadow-sensitive uses is to provide the shadow coverage, per

building and per season, over the length of the study period. (i.e. from 9:00 A.M. to

3:00 P.M./5:00 P.M.).


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The RDEIR must be revised to: 1) conduct an on-site analysis, 2) use the appropriate

timeframes and 3) present the shadow coverage per building and per season for all on and off-

site shadow sensitive uses.

3) Page IV.A-36 states that, Sensitive Uses with respect to artificial or nighttime light and glare

in the project area include the Marina Pacifica residential community located northwest of theproject site, and to a lesser extent, the Alamitos Bay Marina located to the southwest of the

project site. This assessment neglects the numerous people who legally live on their boats in

the Alamitos Bay Marina. Not only are these residents closer to the project site than the Marina

Pacifica residents, but these liveaboards are frequently outside, not sheltered within the four

walls of a traditional dwelling. Liveaboards are more susceptible to lighting impacts than the

Marina Pacifica residents, not less susceptible.

The RDEIR should be revised to conduct an impact analysis on the most sensitive residential

uses, that being the liveaboards within the Alamitos Bay Marina.

IV.B. Air Quality:

1) The AB 32 scoping plan and SB 375 focus on the reduction of vehicle trips and vehicles miles

traveled. For analysis, page IV.B-37 states, The project by virtue of its location and design,

exhibits many attributes that have a positive direct and indirect benefit with regard to the

reduction of vehicle trips and vehicle miles traveled. Specifically, the project is accessible to the

I-710 freeway..With easy accessibility to a number of local and regional transit facilities with

stops roughly 100 yards away.

This analysis is written as though the Project is located in downtown Long Beach, which is

proximate to the I-710 and regional transit facilities. Whereas I realize that the size and density

of this Project are more geared for downtown, this Project is actually located in the SEADIParea on the other side of Long Beach.

The proposed Project will introduce residents and density into an area where it previously didnt

exist. After taking credit for a travel demand management plan, the project is expected to

generate an additional 11,290 vehicles (weekday) and 14,349 vehicles (weekend) over what is

currently existing.

How does this comply with SB 375?

2) Page IV.B-22 identifies the sensitive receptors and their locations. Omitted were the

liveaboards across the street from the proposed Project. As these liveaboards are primarily

outside and/or on their vessel, they are especially impacted by poor air quality. Impacts to the

liveaboards should have been analyzed, but wasnt. The RDEIR should be revised and re-

circulated.

IV.C Biological Resources

1) The RDEIR seems to imply that the project site, though on the Pacific Flyway, doesnt really

receive much use by wildlife. Yet on March 1, 2011, the Seaport Marina Hotel facebook page


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proudly boasted (complete with picture), Look who was hanging out in our courtyard.a blue

heron! (see Attachment 1 to this letter).

IV.F Hazards and Hazardous Materials

1) On August 5, 2010 representatives of the subject property requested case closure forportions of the Project site (6280 2nd Street East, Long Beach), Case No. 908030052.

On December 16, 2010 the California Regional Water Quality Control Board (RWQCB), Los

Angeles Region sent a letter to Holly Quasem of ConocoPhillips Company (see Attachment 2 to

this comment letter) in response. As contained in the letter, based on Regional Board staff

review, it was determined that additional remediation and investigation requirements must be

met and the case is not ready for low risk closure. The following reasons were identified (p. 2-3

of the referenced letter):

Residual soil concentrations remain significantly elevated and could pose both a human

health risk and continuing groundwater impacts; Residual ground concentrations remain significantly elevated;

The extent of groundwater impacts has not been adequately delineated off site to the

west for MBTE, as well as in all directions for TBA;

Historical remediation efforts have not sufficiently removed hydrocarbons from the

subsurface.

The RWQCB identified several requirements (p. 3 4 of the referenced letter):

Remediation requirements (per CCR, title 23, Sec. 2726):

o You shall continue performing DPE, or you shall submit a remedial action plan

proposing soil excavation or an alternative remediation technique. You shall

submit a report summarizing each phase of remediation.

o You shall provide a summary table listing the date range for each phase of DPE

remediation; the well locations at which remediation was performed; total influent

vapor concentration measurements; the number of pounds of hydrocarbons,

benzene, MTBE removed during each phase; the cumulative total pounds of

hydrocarbons, benzene and MTBE removed; and the volume of groundwater

removed during each phase and cumulatively.

Investigation requirements (per CCR, title 23, Sec. 2725):

o For groundwater, you shall submit a work plan for delineating the extent of

impacts.o For soil, you shall clarify the lateral extent of impacts by revising Figure 5 from

the Request for Closure to include results of all sampling points (for example

GP16 had a TPHg detection of 600 mg/kg but is not shown within the zone of

impacts above 100 mg/kg). You shall also submit a similar isoconcentration

figure for soil at 5 bgs for benzene and for TGHg.

o You shall discuss the possible source of th ecrude oil identified historically in

multiple wells.


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General requirements:

o You must continue to submit plans, reports and data to the state GeoTracker

database.

o You are required to provide proper documentation showing the name, mailing

address and phone number of the property owner.

o This case remains in the UST programs Expedited Agency Oversight Program.

To date, none of the above requirements have been met, nor have the additional due diligence

activities transpired. In fact, the RDEIR does not acknowledge the RWQCB letter at all. Instead,

the RDEIR defers production of the needed plans, reports and data until some future time

post-approval of the Project. The RWQCB is unable to recommend case closure for this site due

to the absence of specific information, so how is the RDEIR able to determine that impacts are

below a level of significance using the very same information?

Further, since the extent of groundwater impacts has not been adequately delineated off-site to

the west for MTBE how is the RDEIR able to determine that impacts are below a level ofsignificance?

IV.H Land Use:

1) Page IV.H-6 states that an LCP amendment is required for the project to allow residential

uses and to allow the proposed intensity of development on the site. This implies that the LCP

amendment must first be granted, and then once that transpires, residential uses and increased

density, as proposed and analyzed in this RDEIR, will be allowed. What is the timeframe for

processing and approval of the LCP? Doesnt the LCP amendment need to be approved by

Planning Commission, City Council and the California Coastal Commission for it to be in effect,

and only after that happens can the EIR be certified?

Further, language in the RDEIR about the amendment is vague and lacks specifics. How,

specifically, would the SEADIP be amended?

2) Table IV.H-3 compares the project with applicable provisions of the SEADIP and the following

comments pertain to the consistency analysis presented in the referenced table.

2a) Provision 1 addresses the orientation of homes and offices. As the specific zoning for the

parcel prohibits residential and office uses, the correlating analysis should state not applicable.

In fact, provision 2 below pertains to single family detached dwellings and the project

consistency analysis indicates that the provision is not applicable given that the project site is

not designated for these uses. Given that both provisions pertain to land uses for which theproject site is not currently designated, why is the analysis for provision 1 partially consistent

while the analysis for provision 2 not applicable?

2b) Provision 4 requires that the Project provide 30% usable, public open space and the

analysis indicates that the project would be consistent. Not true. The Project provides less than

the required amount of open space (see comment 1 in section II.5.d above). The Project is not

consistent with the open space required under SEADIP and a significant impact exists.


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2c) Provision 9 speaks to the goal of having all development designed and constructed to be in

harmony with the surrounding environs so as to create community unity. The analysis indicates

that the proposed project would be consistent with this provision. Seriously?

The table below compares the existing hotel with the proposed Project:

Maximum

Building Height

Square

Feet

Open Space

Provided

Number of

Buildings

Current

Seaport Marina Hotel35 feet 164,756 30% 1

Proposed

Second + PCH Project150 feet 822,500 Less than 30% 5

The proposed Project is 428% taller than the current hotel, 499% larger with respect to square

footage, includes less open space and has 5 times the number of buildings compared to the

current hotel. The current hotel, built within the confines of SEADIP, is in harmony with thesurrounding developments, also built within the confines of SEADIP. The proposed Project,

egregiously inconsistent with SEADIP, absolutely dwarfs the current hotel and will dwarf the

surrounding developments. The proposed project would not be in harmony with the surrounding

developments.

2d) Provision 14 pertains to curb cuts on Pacific Coast Highway, and justifies the consistency

determination by indicating that the curb cut is necessary (at Driveway B for Marina View Lane)

for adequate ingress/egress. However, construction of this project also requires that the

Marketplace (subarea 18) redesign their access point on Pacific Coast Highway. The project

consistency analysis does not address the additional curb cut needed at the Marketplace site.

3) When the LCP was adopted, a tradeoff was made. Density was to be concentrated downtown

and the SEADIP area was to remain low rise and respectful to the water. That tradeoff has been

respected since inception of the LCP and that is why the Downtown and SEADIP areas look as

they do: the former is dense and buildings reach for the sky, whereas the latter is exactly the

opposite (most buildings dont exceed the 35 foot height limit). Allowing this Project to proceed,

as proposed, ignores the tradeoff made years ago and would essentially obliterate the

comprehensive master plan in place for the SEADIP area.

This LCP amendment serving to increase density and allow for uses that have never been

considered is just another attempt at spot zoning and should not be allowed.

IV.K.1 Public Services Police Protection

1) The RDEIR states, as of 2009, the LBPD has a budgeted staff of approximately 1,000

officers plus support staff (page IV.K-2). Whereas those staffing levels may have been accurate

in 2009, those numbers are nowhere near accurate currently. As has been WIDELY reported in

the media throughout the past year, the LBPD currently has 867 sworn police officers. At a

November 11, 2010 media briefing, Police Chief McDonnell told Long Beach media


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representatives that the LBPD has 867 sworn officers, is losing about 40-50 officers per year

due to normal retirements/attrition, and he hoped for a sizeable replenishment Police Academy

Class in October 2011. In March 2011 the City Council voted to cancel the academies for police

recruit for Fiscal Year 2011 (see Attachment 1 to this letter for substantiating press material).

This will effectively lower the amount of budgeted officers to below the current level of 867

officers. And that drop will continue until the City opts to fund a replenishment class. It isnt

pretty, but it is the reality and it must be looked at in the document.

The RDEIR states, potential impacts related to police protection were evaluated based on the

adequacy of existing and planned LBPD staffing, equipment and facilities to meet the additional

demand for police protection resulting from development of the proposed project (p. IV-K-3).

Since the existing LBPD staffing assumption used in the RDEIR is totally inaccurate and

artificially high, the resultant analysis is fatally flawed.

Further, based on the hugely overestimated budgeted staff assumptions, it was determined that

2 additional police officers would be required to respond to the additional calls for service

generated by the proposed Project. The RDEIR needs to revise this estimation based on current

and anticipated staffing levels. And the RDEIR needs to state where in the City these officers

will come from North Long Beach, Central Long Beach, etc. If the officers are not available

from elsewhere in the City, then a significant impact exists with respect to police protection.

Additionally, the analysis in the RDEIR (using 2009 assumptions) states that, the LBPD has not

indicated that the existing East Division Patrol Station is operating at or over capacity, the

existing facility would be sufficient to accommodate the 2 additional officers and any associated

field equipment.(p. IV.K-8). This is in direct contradiction to the information shared by Police

Chief McDonnell at the aforementioned November 11, 2010 media briefing, [O]ur people right

now are stretched very thin, so when we have [cites example of a "Critical Mass" bicycle ride] or

some kind of a major event, we pull people from the rest of the city which is not in any way

something we want to do. We want to be able to have beat integrity so that the officers assigned

to beats stay on those beats and provide service to the people as well as being proactive...

(see Attachment 1 to this letter).

Clearly the background information contained in the RDEIR is stale and inaccurate, and the

resultant analysis is flawed. Why didnt the RDEIR preparers use accurate and current data? To

determine the Police Facilities Impact Fee, the associated footnote (page IV.K-8) indicates that

that information was accessed February 9, 2011. Why didnt the RDEIR use similarly current

data for the estimations of the police force, and instead relied on communications from

November 2009? More current information was certainly available.

IV.L Traffic and Circulation

1) Bay Shore Drive between Ocean Blvd and Second Street is closed to thru traffic from

9 a.m. 5 p.m., June 15 September 15. Cars traveling westbound on Second Street are

prohibited from making a left turn onto Bay Shore Drive and typically use the next available

intersection (Santa Ana and Second Street) to turn left. During these summer months when Bay

Shore is closed annually, cars typically back up in the short, dedicated left turn lane on Second


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Street and spill over into the left most thru lane, blocking thru traffic in that lane. Since the

RDEIRs Saturday traffic analysis is assumed to reflect summer conditions, why were potential

traffic impacts not studied at the intersection of Santa Ana and Second Street, given that this

intersection is currently a problem in the summer months and the problems will be exasperated

with the addition of Project related vehicle travel?

For that matter, why werent all intersections through Belmont Shore studied? The blocks

through Belmont Shore are very short and as there is a significant impact at the entrance

intersection, there are likely impacts at all intersections through the Shore. As the entire traffic

analysis must be revised to address the numerous flaws, additional intersections through

Belmont Shore should be included in a revised analysis.

2) Second Street through Belmont Shore presents a unique traffic situation: the sharrows. On

both sides of Second Street, the right most vehicle thru lane is also a dedicated bike lane, in

that both bikers and vehicles have use of this lane. As bikers do not typically travel at the same

speed as vehicles, cars travelling behind the cyclists do so at a reduced speed. How did the

traffic analysis address this local situation, and how are the reduced vehicle speeds through the

area addressed?

3) The RDEIR traffic analysis assumed that the future growth in traffic volumes is one percent

(1%). When applied to existing Year 2009 traffic volumes, this results in a six-percent (6%)

increase of growth in existing volumes to horizon year 2015.

Given that the factor is applied on an annual basis, the growth should be compounded annually,

not applied as a straight 6% multiplier to the base year. By that, the growth percentage applied

to year 1 creates a new base for year 2, to which the X% should be applied. Failing to

compound the growth results in an artificially low opening year baseline as it does not capture

the actual annual growth. The traffic analysis must be redone and the annual growth factorapplied appropriately in the recalculations.

4) To assist in off-setting the potential traffic impacts associated with the proposed project, the

project applicant has indicated that a Travel Demand Management (TDM) Plan will be

implemented to encourage site employees to use alternatives to single-occupancy vehicles to

travel to the project site (p. IV.L-26). Somehow, this magically translates to a daily reduction of

492 vehicles (4.2%) during the week, and 569 vehicles (3.8%) during the weekend. How was

this determined? No specifics were contained in the RDEIR and these numbers just appear.

5) The trip generation potential of the proposed Project was estimated using trip rates from ITE

trip manual. The RDEIR used ITE Land Use 931: Quality Restaurant for all restaurantcomponents of the Project. This is not supportable. There are absolutely no commitments that

any quality restaurant will occupy the Project. It is equally possible that a Dennys type of

establishment (i.e, sit down/high turnover), or a Carls Jr. (i.e. fast food) will occupy a site as

will a quality restaurant. In fact, the only reference to any specific type of eating

establishment presents on page II-24 of the RDEIR, an indoor/outdoor caf will be associated

with the Coastal Cycling Center. For the traffic analysis, is it assumed that the bike shop caf

falls into the Land Use category of quality restaurant (if not, how was the trip generation


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associated with this caf reflected in the analysis)? Given that the cycling center services would,

include custom fitting, repairs, storage, and locker and changing rooms; opportunities for

sports education and therapy, coaching, individual assessment and training..., it seems an

extremely infeasible assumption that the associated caf would fall into the category of quality

restaurant.

Additionally, page II-6 of the RDEIR identifies that various restaurant uses would be

constructed at the podium level of the development. Also, Table 12-1, Appendix J identifies

parking needs associated with taverns. If the Project Description of the RDEIR is disclosing

that various types of restaurants are proposed and the Traffic Appendix identifies that taverns

are part of the Project, why does the resource specific analysis only reflect the single Land Use

category of quality restaurants?

Given that there is less trip generation associated with a quality restaurant as there is less

patron turnover and consequently less vehicular associated trips, assuming that all restaurants

fall into the Land Use category of quality restaurants underestimates potential trip generation

associated with the proposed development. As the applicant is proposing various restaurant

uses and taverns, to conduct a Project-specific analysis, and given the absence of any

commitments from any specific restaurants, the ITE Land Uses of High Turnover (sit down)

restaurant, Fast Food Restaurant without Drive Thru Window, and Drinking Place should

have also been utilized. The traffic analysis must be redone and the appropriately conservative,

and arguably more realistic, ITE Land Use factors utilized.

6) Table IV.L-9 shows the project traffic generation forecast. It assumed that there is only

21,092 SF of restaurant associated with the Project. Why did the traffic generation forecast and

resultant analysis ignore the restaurant square footage associated with the hotel, an additional

4,368 SF? Also, the 3,510 SF of proposed meeting space was another land use omitted from

the traffic generation forecast and analysis. The traffic analysis must be redone and all traffic

generating project components used in the forecast.

7) Though an internal circulation plan has not been submitted, the RDEIR states that the

development phases would not restrict or preclude access for emergency vehicles and therefore

the proposed project would not result in inadequate emergency access (p. IV.L-60). Since

detailed (to scale) site plans have not been submitted and reviewed, how is this a credible

determination?

8) To determine the amount of parking required, the Traffic Impact Analysis (TIA) states that,

the parking demand was calculated using parking code requirements per the City of Long

Beach Municipal Code Chapter 21.41, Off-Street Parking and Loading Requirements.

However, code was not followed and this assertion is not supportable.

Section 21.41.216 of the Municipal Code, Table 41-1A, Required Number of Parking Spaces

for Residential Uses clearly identifies that within the Coastal Zone, 0 bedrooms (not more than

450 sq. ft) require 1 parking space and 1 or more bedrooms (or zero bedrooms, 451 sq. ft. or

more) require 2 parking spaces. Additionally, 1 spot per 4 units is required as guest parking.


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The Project is providing 325 residential units, all 1 bedroom or greater. As such, and per City

code, 731 parking spaces are required (650 resident spaces + 81 guest spaces). The RDEIRs

City Code Parking Analysis assumed that the residential parking need was 1 dedicated spot

per unit, for a total of 406 parking spaces (325 residential spaces + 81 guest spaces).

The parking analysis drastically understates the parking need associated with the residentialcomponents of the proposed Project, and also incorrectly states that Municipal Code was

followed, when it was not. The total parking need for the project, as required by city code,

should be 2,020 spaces, NOT the 1,695 spaces assumed in the RDEIR.

9) The first line of Section 12.0 (Parking Analysis) of the TIA states, the parking analysis for the

proposed project involves determining the expected parking needs, based on the size and type

of the proposed development components, versus the parking supply (p. 57).

The needs assessment in the TIA (incorrectly) concluded that per City code 1,695 spaces are

needed, and per the shared parking analysis methodology 1,440 spaces are needed. Since the

TIA did not conduct an analysis of parking supply and an internal circulation plan (to scale) hasnot been submitted yet for the project, how was it determined that 1,440 spaces are going to be

supplied by the Project? Contained in the RDEIR is simply a declarative statement that the

Project will supply 1,440 spaces. How was this determined since a supply analysis was not

conducted?

10) The RDEIR assumes that with a proposed parking supply of 1,440 parking spaces, the

proposed project would be considered deficient by 255 parking spaces when compared to the

Citys parking requirements. This is incorrect. Even if the project is supplying 1,440 spaces (and

there certainly isnt documentation that this is the case), the proposed project would be deficient

by 580 parking spaces.

11) Based on the analysis in the RDEIR, it appears that it is the developers ultimate intention to

dedicate 1 parking spot per unit regardless of unit size. Because of this, multiple bedroom units

(likely purchased by couples) will be extremely unattractive to buyers given that most adults

have at least 1 car, and there is seemingly no place to park. Where will the additional vehicle(s)

be parked when the 1 dedicated spot is taken by the other occupant(s) of the unit?

Further, and from an economic (and practical) perspective, it is distinctly possible that given the

severe parking shortage associated with the Project, the multi bedroom units will be vacant for

extended periods as many home buyers will look elsewhere as their needs will not be met by

the Project (who wants to drop a lot of cash for a home if they cant park there?). This should

factor into an economic analysis, especially as a lack of parking would serve to drive down theselling price of the units.

12) Since the Project is drastically underparked and there is free, available parking across the

street at the Marina, it is extremely likely that visitors to the development will utilize the Marina

parking lot (especially as the proposed pedestrian footbridge will allow for easy access from the

Marina to the Project site). Removing parking associated with coastal/marine dependent uses

would impede public access to the coast/marine environment and violate the Coastal Act. Also,


14/31


given that the amount of parking available to residents (1 dedicated spot per unit) is half of what

is required, it is distinctly possible that residents will be utilizing the coastal resource for their

own personal use, further in violation of the Coastal Act.

13) Mitigation Measure L-2 (Shuttle Service) is lacking in specifics. Absent is any information

about how many shuttles will run, what hours they will operate, and how frequently will they run.In spite of the lack of any input information, the RDEIR asserts that this shuttle will reduce

impacts to below a level of significance. How was this quantified?

14) Mitigation Measure L-2 (Shuttle Service) must provide more specifics with respect to the

shuttle route. For instance, the intersection of Second St. and Bayshore Avenue is too narrow

for a shuttle bus to make a U-turn. To turn around, will it go up and down the residential side

streets in Belmont Shore? This route needs to be identified and any potential impacts to the

residents on these streets must be addressed (especially since these narrow, one way

residential streets were not designed for continuous shuttle traffic multiple times per day).

Alternatively, to avoid driving through the Belmont Shore residential streets (and avoid theBelmont Shore community), the shuttle would have to travel through Livingston Dr. However,

this would nearly double the length of the shuttle route. To maintain the same service level as

was assumed in the original mitigation, will the number of shuttles double? Or will the number of

shuttles remain the same, and the service level decline by half? Additionally, the traffic area

study boundary extended only as far west as Livingston Dr. If the shuttle goes past Livingston,

then the traffic study boundary needs to be stepped out to include it, as all aspects of the

proposed project must be included in the analysis.

15) The developers have stated that they have a 10 year deal with LB Transit for this shuttle

service. Is LB Transit able to staff additional drivers (if the route is doubled, as explained

above)? And, what would happen after 10 years? This mitigation needs to last the life of theProject, not just 10 years.

16) Mitigation Measure L-5 (intersection PCH and Second St.) states that the applicant will

purchase a right-of-way (ROW) from the Mobil gas station located on the southeast corner of

the intersection and construct an exclusive right turn lane. Does the applicant own this ROW

currently? If not, then it isnt feasible mitigation and must be removed from the RDEIR. Further,

if the applicant doesnt own this, the City has no ability to enforce this as mitigation. This was

substantiated by Judge Toribios decision on the Home Depot, an EIR cannot validly require a

neighbor to mitigate the projects significant impacts.

16) Implementation of Mitigation Measure L-5 (intersection PCH and Second St.) would result insignificant impacts to the Mobil Station. The exclusive right turn lane would encroach into the

Mobil Station property. As the station is currently designed, the only way for cars to circulate

from the southeast area of the station (the PCH side) to the northwest area (the Second St.

side) and vise versa, is via a pass through lane that parallels PCH (between the outer most

line of pumps and the landscaped median/sidewalk). Much of that pass through lane will be

consumed with the exclusive right turn lane and/or other infrastructure (i.e. sidewalk). Internal


15/31


circulation at the Mobil station would be very compromised, especially since this is a fairly busy

gas station given the lack of stations around it.

Further, this new right turn lane would seem to necessitate the removal of the parking spaces in

the front coroner of the Mobil station (at the intersection of Second St and PCH). Where are

vehicles supposed to park once this new lane is constructed? Is the parking that would remainadequate to serve the stations needs?

Implementation of this mitigation necessitates the relocation of the stations signage. Where is

that going to be re-located? And all landscaping, including the mature trees, would be removed.

This mitigation measure is lacking in details and cannot feasibly be constructed without

significant impact to the Mobil Station, which must be addressed in this analysis document

(since this is a connected action and failure to do so is project segmentation).

17) The Mobil Station is located at 6401 E. Pacific Coast Highway. This address is contained on

the State Leaking Underground Storage Tank (LUST) lists. Additionally, the groundwatermonitoring wells at 6401 E. Pacific Coast Highway found concentrations of tertiary butyl alcohol

(TBA), methyl tert-butyl ester (MTBE), total petroleum hydrocarbon as gasoline (TPHg), and

benzene, per the SWRCB GeoTracker website.

The potential for significant impacts from construction and implementation of Mitigation Measure

L-5 exists due to the seemingly hazardous nature of the parcel. This should have been analyzed

in this RDEIR (per CEQA 15126.4). It was not. Why werent impacts from construction and

implementation of this mitigation measure analyzed?

18) The installation of a traffic signal at Driveway B will require modification of the access and

on-site circulation of the Marketplace retail center across the street (p. IV.L-22). Does the

applicant have permission from the Marketplace to conduct this work? If not, then it isnt

feasible. This position is reiterated in a comment letter on the first DEIR from the owners of the

Marketplace (Pacific Castle), see RDEIR Appendix A.

Alternatively, why didnt the applicant just design a project where Driveway B lined up with the

long-existing Marketplace access point?

19) For the Second + PCH project to be constructed, the Marketplace must modify its access

and produce a new on-site circulation plan. Since this is a connected action, why didnt the

RDEIR address these connected components specifically? The modified access and circulation

plan must be provided in this environmental analysis document and any potential impacts

analyzed. Failure to do so results in project segmentation.

20) Since the entire traffic analysis must be redone to address the many inadequacies, the

baseline traffic trip counts must be retaken, to remain consistent with direction in the LA County

Congestion Management Plan (Oct 2010).

IV.M.1 Utilities Water


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1) The Water Supply Assessment (WSA) is flawed and does not take into account all water

uses by the proposed Project. For instance, the WSA does not assume any water use

associated with the theater. Really? No sinks, toilets, etc.? Also, the first DEIR assumed that

0.56 acre-feet per year (AFY) were needed [5 gallons per day (gpd) per seat * 99 seats = 495

gpd = 0.56 AFY] (p. IV.M-17 first DEIR). Why does the RDEIR assume that no water will be

used?

Additionally, the first DEIR assumed that outdoor water use would be 31.48 AFY (28,101 gpd).

This was estimated to be 28% of total retail, restaurant and office uses, and 18% of residential

and hotel uses (p. IV.M-17 first DEIR). The RDEIR assumes that zero outdoor water is needed

for the Project as it is not accounted for in Table IV.M-15. What will the fountains and outdoor

pools associated with the Project contain? How will the sidewalks within the Project site be

cleaned? The landscaping wont need any water? Zero water use for outdoor purposes seems

infeasible.

The Long Beach Water Department staff must prepare a new WSA which accounts for all water

use associated with the Project. The Board of Commissioners must approve this new WSA at a

regular or special meeting before it can be given to the Lead Agency (City of Long Beach), per

Water Code Section 10910(g)(1). The RDEIR must be revised to include this approved WSA,

and recirculated.

V. Alternatives

1) What happened to the hotel only alternative? Though the RDEIR provides for an existing

zoning alternative, it assumes that it would be exclusively commercial, as though that is the

only allowed use for the site. A hotel is also an allowed use and should have been considered

(as would be a hotel/commercial development). Further, vehicle trips associated with a hotel are

radically lower than vehicle trips associated with a commercial development, so traffic impactswould be less under a hotel alternative (or any combination of the two which reduces the

amount of commercial).

The point of an alternatives analysis is to design alternatives which reduce significant impacts.

Instead, the RDEIR selected a land use that produced the greatest impacts, and then used that

selection as rationale to declare existing zoning uses as less attractive than the Proposed

Action. If the RDEIR is going to make a declarative statement about existing zoning vs. the

Proposed Action, then it needs to look at other existing zoning options to see if all are equally

infeasible. The RDEIR needs to be revised to provide for an adequate alternatives analysis and

recirculated.

2) In accordance with CEQA Guidelines Section 15126.6(c), an EIR should identify any

alternatives that were considered for analysis but rejected as infeasible and briefly explain the

reasons for their rejection. The RDEIR identified only 1 alternative which was considered and

rejected: alternative locations distant from the project site. It did not consider the hotel only

alternative. This alternative was considered in the first DEIR as a feasible alternative. How did it

go from being a feasible alternative in the first DEIR to disappearing entirely in the RDEIR, not

even making the list of, alternatives considered and rejected. It was clearly considered as it


17/31


was contained in the first DEIR! The RDEIR needs to be revised to provide for an adequate

alternatives analysis and recirculated.

VI. Growth Inducing Impacts

1) The RDEIR states that, there are unique characteristics that apply to the proposed projectand its location that support increased building heights and intensity. (p. VI-2). Really? When

the LCP was formed a tradeoff was made: make downtown Long Beach dense and keep the

SEADIP area low-rise. In 2008, the City initiated the SEADIP revision process, beginning with a

community survey. In this survey, 60% of respondents stated that they would not support an

increase in height in exchange for additional public amenities. It would seem as though the only

unique characteristics driving this increase in height and density are those associated with the

developers desire to increase profitability, as this is certainly not an action driven by community

input.

2) The RDEIR states that, land use decisions, such as the proposed amendments to the

SEADIP and LCP do not set a precedent in as much as building heights would continue to becontrolled through LBMC, SEADIP and LCP provisions, with any exceptions or amendments to

such requiring discretionary approval and environmental review by the City (p. VI-3). So these

same zoning laws that the Project applicant has been allowed to ignore will serve to keep height

and density low? If this amendment gets approved, it will send the message to other land

owners in the SEADIP area that all they need to do is apply for an amendment and claim that

their project site is unique, therein justifying an amendment. This ignores the very fact that the

act of approving an amendment to change the zoning to allow currently inconsistent uses would

set a precedent for the SEADIP area. It is the action that would serve to open the door for

subsequent Projects to be bigger and taller than what is allowable.

If this amendment gets approved and the zoning changed to accommodate the developersrequests, a precedent will be set for the area: propose whatever you want because existing

zoning doesnt matter.well just call you unique and approve an amendment.

Miscellaneous:

1) Given the high number of retail vacancies throughout Naples and Belmont Shore, I question

the feasibility of filling the retail portion of the Project site. Additionally, should a free shuttle

extend through Belmont Shore (see comments in Traffic section above), the bus will be

removing potential shoppers from Belmont Shore and transporting them to the Project site. This

would result in a negative impact on Belmont Shore businesses/restaurants and should be

accounted for in the analysis.


18/31


Conclusion:

As evidenced by the comments in this letter (and likely comments submitted by others), this

RDEIR is fatally flawed. It must be revised and re-circulated.

Regards,

Heather Altman

Belmont Shore resident and environmental consultant

Enclosure


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Attachment 1


20/31

Long Beach - Signal Hill Geophysical Survey

Geophysical SurveyTuesday, April 19th Survey truck will

be on Burnett St. going West fromOlive to Atlantic. Then on 15th St.

(March 9, 2011, 4:30 a.m.) -- City Manager Pat West has agendized an item on March

15 seeking City Council approval to erase a FY11 replenishment Police Academy classthat management recommended and the City Council budgeted in September 2010. In

the agendizing memo, city management also says a Council budgeted replenishment Fire

Academy class isn't needed.

The text of City Manager West's agendizing memo is below:

RECOMMENDATION

Concur with the City Manager's recommendations to (1) cancel the academies forPolice Recruit and Fire Recruit budgeted in FY 11, (2) utilize the budgeted amount inthe Police Department to fund sworn officers above current budgeted position levels,

and (3) utilize the budgeted amount in the Fire Department to fund fire station capitalimprovements including, but not limited to, gender accommodations.

DISCUSSION

At the City Council Executive Session on February 1, 2011, the City Council receivedinformation and discussed the budgeted academies for the Police and Fire Departments.The academies were predicated on certain numbers of sworn personnel retiring, therebycreating vacancies that would be filled through academies. In the Police Department,the projected level of vacancies did not materialize. In fact, the Department is currentlycarrying 10 sworn officers above the budgeted number of positions. These officers arecurrently being funded through the money set aside for the academy. Given the $18.6

million General Fund deficit projected for FY 12 and the anticipated reductionsnecessary to address the deficit, any new officers hired in FY 11 would have a highprobability of being laid off in FY 12.

In the Fire Department, we did experience close to the expected number of retirements.However, given the Department's FY 12 budget limitations, only a small number ofFirefighters could be hired without facing the prospect of being laid off in FY 12. ChiefPatalano is confident the current and projected numbers of vacancies do not rise to thelevel of necessitating an academy at this time.

This matter was reviewed by Deputy City Attorney Gary J. Anderson and by Budget

BeachReport.com | LBReport.com | City Mgr. Seeks Council Approv... http://www.lbreport.com/news/mar11/pdfd

4/19/2011


21/31


22/31

academy here because experiences in the past have not always been that positive, butwe're in a different place where some organizations around the state are laying off goodpeople and in large numbers and we may be able to take advantage of that.

The ideal would be to have a full regular recruit academy and my goal is to be able towork with the city departments, and the city manager, to be able to come up with anagreement to start a new police academy October 1 of 2011...but as soon as we canpossibly do that which would be October 1, my hope is that we can start gearing up to

that over the summer months with what we have in house to be able to get us to aposition where we could kick of an academy of considerable size to be able to startlooking at replenishing some of those numbers.

[Discusses multiple factors in hiring process; background investigations; test-taking andattrition in the academy]

...In an ideal sense, it would be nice to say for public safety to start with, and maybebeyond that eventually, to be able to have a planned succession strategy, where weknow, we anticipate and we can pretty safely say we will lose those 40 to 50 [officers]every year, to have an agreement so there'd be built in every budget is a new academyto be able to replenish at least the attrition and then if we have an opportunity based on

budget to be able to build the department, then we start looking at doing that by hiringadditional people on top of the attrition number...

...[O]ur people right now are stretched very thin, so when we have [cites example of a"Critical Mass" bicycle ride] or some kind of a major event, we pull people from the restof the city which is not in any way something we want to do. We want to be able tohave beat integrity so that the officers assigned to beats stay on those beats and provideservice to the people as well as being proactive...

Further to follow on LBReport.com.

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Years back when the LBPD wanted a New Police Station (aka NLB Country club, and suggested that crime would be lowered in the community as a result of


4/19/2011


23/31

building such) Redevelopment was tapped to fund such as the city was out of General Funds.

Redevelopment's end game with the properties it has " acquired " by applying a blight label to , would be to sell these to developers.

The city should have a " Need cash for Police / Fire " FIRE sale of its newly inherited lump of " white fence " property !

Turn these assets the city now owns into productive elements for the good of the citizens of LB.

Hay city council / Redevelopment board, you don't think that that Brown administration is not clearly watching your cup and ball game ?

FA

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