David Somers

Environmental Review Section

Department of City Planning

200 N. Spring Street, Room 750

Los Angeles, CA 90012

ENV-2005-4516 DRAFT EIR COMMENTS: PONTE VISTA PROJECT

26900 S. Western Ave., San Pedro

Thank you for the opportunity to respond to the Draft EIR for the proposed Ponte Vista project. The project falls within the boundaries of the Northwest San Pedro Neighborhood Council. We represent approximately 20,000 residents and numerous businesses and community organizations. At our Board and Community Meeting on January 22, 2007 the Council adopted the comments contained herein.

Bisno Development proposes to build a 2,300 unit residential project on Western Avenue in Northwest San Pedro. This represents a five to nine percent increase in the population of San Pedro which would be “accommodated” on less than one-tenth of one percent of San Pedro’s land area. Additionally, this population increase would be concentrated on Western Avenue, one of the most overburdened stretches of public roadway in the region.

The current R-1 and Open Space zoning of this property fits well in the community and is appropriate zoning. The density proposed for Ponte Vista fundamentally alters, for all time, the nature of the immediate neighborhood and the entire north side of San Pedro.

The DEIR implies that there will be a change in the current zoning. A change of this magnitude should be considered as a part of the Community Plan update process, not as an isolated request. Additionally, we oppose the gated nature of the development. It is already isolated from the community by its location and lack of amenities. Gating would further isolate its residents from our community. It will also make emergency services to senior citizens more difficult.

One of the most frustrating aspects of the DEIR is its lack of specificity. It is impossible to tell what is actually proposed - how many of each size unit etc. - so that it is difficult to determine what population, student generation rate, trip generation rates, and economic impacts should be considered. Frankly, we wonder if there is enough specificity for the DEIR to support a specific plan. We are also disturbed by the lack of “readability” of the DEIR documents. If the purpose of the environmental review process is to provide the community with the opportunity to review and comment, then the DEIR should be written in a more “reader friendly” manner.

We have many problems with the underlying assumptions and conclusions in the DEIR. These relate mostly to traffic, population, housing, and economic impact. Because the analysis is built on faulty assumptions, it is in effect a “house of cards,” and all conclusions based on the analysis are also faulty. Among the fundamental deficiencies are the following:

· The project description lacks sufficient specificity to adequately evaluate the environmental impacts.

· The traffic study was conducted while substantial portions of Western Avenue were under repair. The resulting counts are significantly lower than counts from the prior year and have distorted every subsequent calculation, such as LOS, V/C, and necessary mitigation.

· The project used an incorrect trip generator so that traffic impacts are significantly under-reported. The trip generation rates for comparable City projects are 40% higher.

· The number of persons projected per household (1.88) significantly underestimates the projected population resulting in an underestimate of impacts and of the costs for City services.

· The impact on schools is miscalculated because the developer used the wrong data to determine student enrollment.

· The student generation rate is significantly lower than the appropriate rate. It is half the rate used for Playa Vista and almost 90% lower than the rate used in the CRA Pacific Corridor DEIR.

· The economic impacts are based on an average household income of $144,000, over $100,000 more than San Pedro’s average household income of $42,667. As a result the tax revenue from the project is inflated.

· The economic impacts based on purchasing of goods and services overstate the revenue to the City of Los Angeles since the majority of the available goods and services to be purchased are located outside of the City boundaries.

· LAUSD’s proposed 2000+ seat high school, and the developer’s stated willingness for a 500 seat high school to be located at this site, should have been evaluated as project alternatives.

The community represented by NWSPNC has significant concerns about the project as proposed. We included a survey question about the proposed project in a newsletter which we mailed to the approximately 9,000 households in Northwest San Pedro as part of our regular outreach. We received 680 responses, of which fewer than 4% indicated that they “support the developer’s proposal for 2300 condominiums”, 72% want to maintain the existing zoning, and 21% said they might consider “some additional homes” in exchange for specific mitigation measures. The remainder wanted more information.

Our specific comments are attached hereto and are listed in the order presented in the DEIR. Thank you for this opportunity to submit our comments and concerns. Please feel free to contact me at 310-831-1975 if you have any questions.

Diana Nave, President

Northwest San Pedro Neighborhood Council

CC: Councilwoman Janice Hahn

Mayor Antonio Villaraigosa

Gail Goldberg, Director of City Planning

Bisno Development Corp.

Ponte Vista Community Advisory Committee