2022-03-15 CC Agenda - Public Communications - Item #14 - Pacific Coast Commons2022-03-15 CC AGENDA PACKET
PUBLIC COMMUNICATIONS RELATED TO ITEM #14 - PACIFIC COAST COMMONS
Harada, Patricia
From: Weaver, Tracy (City Clerk)
Sent: Friday, March 11, 2022 11:59 AM
To: *ALL CITY CLERKS
Subject: Fw: Pacific Coast Commons Public Hearing March 15, 2022
Attachments: El Segundo Government Agreement with PCC Opposition.pdf
Council recieved letter attached.
Tracy
From: Bianca Mendoza <bmendoza777mendozab@gmail.com>
Sent: Friday, March 11, 2022 10:17 AM
To: ALL ELECTED OFFICIALS <ALLELECTEDOFFICIALS@elsegundo.org>
Subject: Pacific Coast Commons Public Hearing March 15, 2022
City Council of El Segundo,
In advance of the public hearing please carefully consider the wide level of agreement there is between the City's
position on LAX and the opponents of PCC.
Kindly see attached document.
Regards,
Bianca Mendoza
City of El Segundo is in agreement with
Pacific Coast Commons Opposition.
The following are 22 excerpts from El Segundo's Comment Letter to LAX (LAWA) and how
numerous arguments are the same as opposition sentiment towards Pacific Coast Commons.
This isn't an analysis of the PCC DEIR.
If El Segundo wishes LAWA to hear and act on their complaints then the City should be
motivated to do the same for PCC opponents due to the fact that many of the concerns are
identical as enumerated below.
El Segundo's email and Shute Mihaly & Weinberger LLP comments shown below in italics. The
comparison to PCC comments and opposition in blue standard font.
From City Manager's email dated Wednesday, March 17th, 2021:
1. ...serious concerns about increased noise pollution, negative affects to traffic congestion
impacts to residents...
o Exact same issues that PCC proposal brings
o Developer Lionel Uhry said it himself in the first few minutes of the ZOOM
meeting on 3/31/2021 1730hrs: "PCC is being built in this location so as not to
DISTURB the bulk of El Segundo population." So, what about the population that
is being DISTURBED, what is being done for them? If housing were spread out to
various other locations in El Segundo or moved East of PCH or in Smokey Hollow
the DISTURBED weight is spread out across broader segment of our City.
2. ...address several action items to mitigate the impacts of the expansion project
o No substantive mitigation ideas were offered in PCC DEIR for reasonably
foreseeable issues (Traffic, Safety, Noise, Population Growth spike in confined
area — Congestion, Devalued adjacent properties)
3. ...expansion project proposed in our backyard that will further exacerbate noise,
pollution and traffic congestion in El Segundo, " shared El Segundo Mayor Drew Boyles
o The high density, high impact, never attempted before proposal, in an already
populated area where alternate unpopulated areas exist puts it in many people's
backyards unnecessarily
o El Segundo doesn't like LAX expansion in their backyard and will fight tooth and
nail with LAWA, so why wouldn't the same standard be applied to the
DISTURBED population as mentioned previously? It seems like a double
standard.
4. ...City requested action items include: Reduction in size of expansion
o LAX has no room for physical boundary expansion unlike El Segundo who only
utilizes 25% of City limits for housing
o PCC site proposal was rezoned to mixed use, why can't east of PCH do the same
thing?
o Why can't Smokey Hollow be utilized?
o PCC expansion should be reduced at least, and ideally moved
From Shute Mihaly & Weinberger law firm comments on behalf of the City of El
Segundo dated March 15t", 2021 on LAX Airfield & Terminal Modernization:
5. Page 2... new facilities would create substantial noise, transportation, and air pollution
impacts affecting El Segundo residents, who already deal with the impacts from LAX
o Proposed PCC site also already dealing with impacts of high traffic volume on
Mariposa
o A standard density housing proposal in multiple areas, rezoning and utilizing east
of PCH and Smokey Hollow spreads the impact of the housing "issue" across
broader segment of population rather than forcing a few people to bear the
brunt of reasonably foreseeable impacts, one being lower quality of
life/devaluing property
6. Page 2... LAWA unnecessarily made the process of commenting on the DEIR more difficult
o City of El Segundo only notified people within 100' of project boundary made it
unnecessarily difficult for citizens to even know about the project much less
comment on it. Absurd given the scope, size and impact project has regardless of
what's defined as a "required notification".
7. Page 2... makes the public's right to comment more difficult, particularly when dealing
with a document of this DEIR's size and density
o City of El Segundo spent tax payer dollars to hire a law firm to do it, also the PCC
DEIR is 2400 pages, and how many people have read that? Who is helping the
citizens to organize and fund an opposition to PCC?
8. Page 4... LAWA does not explain why its existing terminal facilities would not be more
than adequate to accommodate these travelers
o PCC DEIR does not study the current state of housing availability, which is
numerous, nor does it study the average monthly rent has gone down approx.
25%.
9. Page 5... demand for air travel experienced a severe, unprecedented decline, but it also
was widely understood that that the road to full economic recovery and return to
"business as usual" would be long,
o PCC DEIR does not know how long business as usual will return as well
o PCC DEIR did not address the prevalent adoption of Telecommuting becoming a
norm that will last beyond the pandemic, impacting people's need to be close to
work, thereby negating need for additional housing so urgently
o LAX is the largest employer in the area, if City of El Segundo believes that there
will long road to recovery, if any for aviation (as stated in numerous locations in
Comments to LAWA) then we don't need additional housing so urgently in the
area, and this certainly would be a reason to push back to the State of California
about the immediate or short term need for housing in our particular neck of the
woods
10. Page 18... ("The DEIR fails to assess the effect of the improvements on traffic growth and
on the resulting environmental impact of this growth.").
o Traffic growth not addressed and sidestepped, especially related to Mariposa
Ave and immediate surrounding streets
o Developer claims it was studied thoroughly. To the average daily user of
impacted intersections it is obviously way off and totally misrepresents
challenges of surrounding intersections.
11. Page 24... It Is Simply Common Sense that the Project Would Expand LAX's Operational
Capacity
o Also simple common sense that LA has not for generations built adequate,
comprehensive, nor reliable mass transit. It is also common sense that LA
citizenry has not adopted mass transit at this point nor has any evidence even
pointed in that direction. Additionally, common sense that people are not going
to walk the distances the PCC DEIR believes will happen. PCC DEIR did not
provide any study, survey or anything of the like of the immediate surrounding
community to support or challenge the assumptions set forth. Project
assumptions hinge on mass transit and walking.
12. Page 49... Under CEQA, project objectives cannot be so narrowly defined that they
preclude consideration of reasonable alternatives for achieving the project's underlying
purpose.
o East of PCH and Smokey Hollow very viable alternatives but not adequately
explored
13. Page 51... The DEIR's Approach to Mitigation Violates CEQA and Provides Inadequate
Commitments to Enforceable Mitigation Measures.
o Numerous mitigation measures to the project are not explored, avoided and
factually incorrect:
■ Permanent increase in Noise
■ Population growth — obviously high density housing is an impact and no
mitigation measure identified
■ Parks — located all along development but ignored in DEIR
■ Transportation — Roadways considerably more congested
14. Page 53... The Noise Generated by LAX Is of Utmost Concern to the Public and Deserves a
Very Careful Analysis.... The FAA has established a CNEL of less than 65 dBA as being
"normally acceptable" with residential land uses, despite research and public testimony
that a CNEL threshold of 65 dBA is not sufficient to protect the public's health and
welfare
o PCC DEIR does not even study this
15. Page 66... The DEIR Fails to Adequately Analyze or Mitigate Roadway Traffic Noise.
o PCC DEIR completely ignores this, especially on surrounding roadways and
Mariposa back and forth into El Segundo Downtown
16. Page 70... The DEIR Underestimates the Project-s Transportation Impacts Because It
Incorrectly Assumes the Project Would Not Increase Passenger Activity.
o PCC DEIR underestimates number of vehicles and subsequent traffic, parking,
noise, safety and quality of life issues by relying on studies not remotely relevant
to site location
17. Page 74... This analysis is particularly important because it is the policy of the City of El
Segundo to require level of service ("LOS") analyses for the purpose of assessing traffic
impact fees; the City requires that intersections operate at LOS D or better. El Segundo
also requires LOS analyses for the purpose of assessing traffic impact fees.
o PCH/Mariposa currently inadequate, adding 263 units exacerbates this. Adding 1
right turn lane will be a drop in the bucket. Palm/Mariposa intersection not
lighted and with it immediately adjacent to PCC North, no proposal was given to
augment the intersection with traffic signals
18. Page 74... The DEIR Fails to Adequately Analyze and Mitigate the Project's VMT Impacts
o Confused because PCC DEIR is reliant on people using mass transit or willingness
to do so. Why wasn't this assumption applied in the Comment Letter to LAWA?
19. Page 75... The Liddicoat Report determines that implementation of the Project will modify
certain travel paths for traffic entering and exiting the LAX CTA... Liddicoat Report
explains, this low volume of traffic appears highly unrealistic
o PCH/Mariposa intersection as well as other intersections will certainly modify
travel paths, this was never analyzed adequately. The Transportation
intersection turn analysis of many locations were ludicrous. See Palm/PCH and
Maple/PCH for just a couple examples
20. Page 80... What are the safety impacts on Sepulveda Boulevard/Pacific Coast Highway,
particularly with regard to increased collisions due to development of Terminal 9 and its
associated traffic?
o Significant traffic increase at PCH/Mariposa begs the safety question as well.
21. Page 80... Congestion at this location has the potential to cause vehicular queues on the
eastbound intersection approach to back up onto northbound Sepulveda Boulevard
o Eastbound Mariposa Traffic currently backs up at PCH during peak times beyond
about 4 intersections. The current issue hasn't even been addressed, if we add
263 more apartments this will obviously get significantly worse. Proposal calls for
1 dedicated right turn lane, this will have marginal impact as it does nothing for
northbound traffic and will have the impact of causing south -bounders to be
caught in the backup behind north -bounders and will significantly increase
modified travel paths. None of this is addressed in the PCC DEIR.
22. Page 81... DEIR should explain whether LA WA considered other alternatives for vehicular
access to/from Terminal 9
o PCC DEIR didn't do this for their proposal, for example:
■ Direct access from parking garages to PCH
■ Expanded Northbound turn lanes from Mariposa
■ Creating Palm a lighted intersection
■ Etc.
I respectfully request that the Planning Commission and City Council carefully reflect on these
22 points of agreement and overlay it with the common ground of protests that exist with the
Pacific Coast Commons Proposal.
The City of El Segundo holds the same view as PCC Opposition, vote as you would for or
against LAX expansion, vote no.
Harada, Patricia
From:
Sent:
To:
Cc:
Subject:
Attachments:
Please see email below.
Tracy Weaver
City Clerk
Begin forwarded message:
Weaver, Tracy (City Clerk)
Friday, March 11, 2022 8:39 PM
*ALL CITY COUNCIL
*ALL CITY CLERKS
Fwd: LAEDC Letter Re: Pacific Coast Commons
Outlook-u2b3agv0.png; LAEDC Pacific Coast Commons LOS.pdf
From: "Allen, Michael" <mallen@elsegundo.org>
Date: March 11, 2022 at 3:24:54 PM PST
To: "Weaver, Tracy (City Clerk)" <tweaver@elsegundo.org>, *ALL CITY CLERKS
<ALLCITYCLERKS@elsegundo.org>
Cc: "Samaras, Paul" <PSamaras@elsegundo.org>, "Schonborn, Eduardo" <eschonborn@elsegundo.org>
Subject: Fw: LAEDC Letter Re: Pacific Coast Commons
FYI -
For circulation to City Council regarding the PCC project under consideration Tuesday night.
Michael Allen, AICP
Development Services Director
City of El Segundo
350 Main Street, El Segundo, California 90245-3895
(o) 310-524-2345
(c) 310-529-0227
www.elseeundo.or I ElSeaundoBusiness.com I Destination EISeQundo.com
From: David Herbst <dherbst@vectisstrategies.com>
Sent: Friday, March 11, 2022 3:18 PM
To: Allen, Michael <mallen@elsegundo.org>
Cc: Lionel Uhry <lionel.uhry@marventures.com>
Subject: LAEDC Letter Re: Pacific Coast Commons
Hi Michael, Melissa at the LAEDC asked me to send forward this letter re: Pacific
Coast Commons. Would appreciate you having it circulated.
Have a good weekend. Thanks, David
Melissa Kham, MPA I Vice President, Strategic Relations
Los Angeles County Economic Development Corporation
444 S. Flower Street, 37th Floor, Los Angeles CA 90071
Office: (213) 236-4815 1 Cell: (818) 298-7702 Email: Melissa.Khamalaedc.org I www.laedc.org
Twitter I Facebook I Linkedln
P LOS ANGELES COUNTY
ECONOMIC DEVELOPMENT CORPORATION
March 11, 2022
Honorable Drew Boyles, Mayor
Members of the City Council
City of El Segundo
350 Main St.
El Segundo, CA 90245
Re: Pacific Coast Commons - SUPPORT
Dear Mayor Boyles & Members of the City Council:
The City of El Segundo has the rare distinction of twice receiving the Los Angeles Economic
Development Corporation's Most Business -Friendly City Award. This is in large measure
because the City does an outstanding job balancing the needs of its residents and its
businesses. Pacific Coast Commons, a mixed -use, multifamily residential development proposed
on the site of parking lots and a shuttered restaurant and small conference facility, is yet
another opportunity for the City Council to show how it balances the needs of its residents and
businesses.
In our Economic Forecast for 2022, the LAEDC called out what you and everyone already knows
—housing in the Los Angeles region has significantly increased in value, thereby making it very
difficult for those who want to buy their first home or rent in Los Angeles County. Our research
showed the heavy rent burden that residents of the county face with many spending more than
a third of their income on housing.
We have called on local cities and the county to incentivize the building of new and affordable
housing that strikes a balance by locating new multifamily housing in smart growth areas — on
major transportation corridors, close to public transit options and in walking distance of
employment centers. Pacific Coast Commons accomplishes this. And with 12% of the units set
aside as affordable, the development answers an important need for housing that our essential
workers can afford.
Housing is an economic development issue. A recent survey of business executives showed that
88% cite the high cost of housing and real estate as one of the primary reasons for not locating,
not expanding, or leaving California. We need housing to keep jobs. We need jobs to keep our
economies and cities thriving. We encourage you to follow your Planning Commission's
recommendation in approving Pacific Coast Commons.
Thank you.
Sincerely,
Bill Allen
President & Chief Executive Officer
Los Angeles County Economic Development Corporation
Harada, Patricia
From: Weaver, Tracy (City Clerk)
Sent: Monday, March 14, 2022 1:42 PM
To: ALL ELECTED OFFICIALS
Cc: *ALL CITY CLERKS
Subject: FW: Comment re: Pacific Coast Commons SP
Attachments: 2022.03.10 CC Hrg Cmt on FEIR for PCC SP - with exhibit.pdf
Council,
Please see attached letter.
Thank you,
Tracy Weaver I City Clerk
City of El Segundo
350 Main Street El Segundo CA 90245
310.524.2305 1 tweaver@elegundo.org I www.elsegundo.org
ELIEGUNDG
Where big ideas talce ul%
From: Samaras, Paul <PSamaras@elsegundo.org>
Sent: Monday, March 14, 2022 1:34 PM
To: Weaver, Tracy (City Clerk) <tweaver@elsegundo.org>
Cc: Allen, Michael <mallen@elsegundo.org>; Schonborn, Eduardo <eschonborn@elsegundo.org>; Gregg Kovacevich
<gk@hensleylawgroup.com>
Subject: FW: Comment re: Pacific Coast Commons SP
Hello Tracy,
We received the attached correspondence regarding item No. 14 on tomorrow's Council agenda (Pacific Coast Commons
project). Can you please forward to Council?
Thank you,
Paul Samaras, AICP I Principal Planner
City of El Segundo Development Services Department
350 Main Street, El Segundo, CA 90245
www.elsegundo.org I E1SegundoBusiness.com I DestinationElSegundo.com
ELSE GUNDQ
blivre hig ideas nike nff_
From: Amalia Bowley Fuentes <amalia@lozeaudrury.com>
Sent: Friday, March 11, 2022 9:47 AM
To: Samaras, Paul <PSamaras elsegundo.org>; Jennings, Mishia <MJennings@elsegundo.or >
1
Cc: Victoria Yundt <victoria@lozeaudrury.com>; Rebecca Davis <rebecca Iozeaudrury.com>; Molly Greene
<moliYWozeaudrury.com>; Colby Gonzalez <colb lozeaudru .com>
Subject: Comment re: Pacific Coast Commons SP
Dear Mr. Samaras:
On behalf of Supporters Alliance for Environmental Responsibility, attached please find comments on the FEIR for the
Pacific Coast Commons SP Project, SCH 2O20050508. (Item C.14. for the City Council meeting on 3/15/22).
Thank you for your assistance. If you could please confirm receipt of this e-mail and the attached comments it would be
appreciated. Thank you for considering these comments.
li�
T 510.836 4200 1939 Harrison Street, Ste 150 www.lozeaudrury.com
F 510.836.4205 Oakland, CA 94612 Amalia@lozeaudrury.com
Via Email
March 11, 2022
Drew Boyles, Mayor
Honorable Members of the City Council
City of El Segundo
350 Main Street
El Segundo, CA 90245
dbo les else undo.or
Mishia Jennings
Executive Assistant to City Council
City of El Segundo
350 Main Street
El Segundo, CA 90245
rn ienn in gs&,e lsegundo.org
Paul Samaras, AICP
City of El Segundo
Development Services Department
350 Main Street
El Segundo, CA 90245
p,Lamaras@elsegundo.org
elsegundo.org
Re: Supplemental Comment on Final Environmental Impact Report, Pacific
Coast Commons Specific Plan (SCH# 2020050508)
Dear Mayor Boyles and Honorable Members of the City Council:
I am writing on behalf of Supporters Alliance For Environmental Responsibility
("SAFER") regarding the Final Environmental Impact Report ("FEIR") prepared for the
Project known as Pacific Coast Commons Specific Plan, aka SCH# 2020050508, including
all actions related or referring to the proposed demolition of existing surface parking lots and
construction of a new mixed use development located at 401-575 N. Pacific Coast Highway
(PCH) and the parking lot on 600-block of PCH in the City of El Segundo ("Project").
On February 10, 2022, the Planning Commission considered this Project and
approved it despite issues raised regarding recirculation, health risk impacts, and growth -
inducing impacts from the Project. SAFER maintains that changes made to the DEIR require
recirculation, and that there is still substantial evidence of a growth -inducing impact from the
Project that requires analysis in a Revised Environmental Impact Report ("REIR"). SAFER
therefore requests that the City Council not approve this Project so that the Development
Services Department can address the February 2022 FEIR's shortcomings in an REIR, and
recirculate the REIR prior to considering approvals for the Project.
March 11, 2022
Supplemental Comment on Final Environmental Impact Report
Pacific Coast Commons Specific Plan (SCH# 2020050508)
Page 2 of 6
I. DISCUSSION
A. The City Has Added Significant New Information to its EIR and is Therefore
Required to Recirculate the FEIR.
CEQA requires re -circulation of an EIR when significant new information is added to
the EIR following public review but before certification. (PRC § 21092.1). The CEQA
Guidelines clarify that new information is significant if "the EIR is changed in a way that
deprives the public of a meaningful opportunity to comment upon a substantial adverse
environmental effect of the project" including, for example, "a disclosure showing that ... [a]
new significant environmental impact would result from the project." (14 CCR § 15088.5).
As mentioned in our letter to the Planning Commission, the City added three
additional related projects to its cumulative impacts analysis in the FEIR. These projects are
all located just blocks from the proposed Project site and have the potential to add a
substantial increase in severity to numerous environmental impacts, such as air quality and
noise. The public must be given the opportunity to review and comment on the substantial
new information which includes additional pages of tables, charts, maps and new analysis
that resulted from the inclusion of the new projects in the FEIR's cumulative impacts
analyses. The public has a right for their comments, and the comments of their experts, to be
responded to in the FEIR, as required by CEQA.
The DEIR should be recirculated for full public review to address the impacts
identified above and to propose feasible mitigation measures.
B. The FEIR Fails to Properly Account for the Project's Growth -Inducing
Impacts.
CEQA standards require EIRs to assess growth -inducing impacts of a proposed
project. (PRC § 21100(b)(5)). The CEQA Guidelines provide that a project will have a
significant growth -inducing impact if it would "induce substantial unplanned population
growth in an area, either directly (for example, by proposing new homes and businesses) or
indirectly (for example, through extension of roads or other infrastructure)." As explained in
CCR Tit. 14 § 15126.2(e), this analysis is important because "[i]ncreases in the population
may tax existing community service facilities, requiring construction of new facilities that
could cause significant environmental effects." This includes potential impacts on public
services, transportation, and greenhouse gases, among others.
In its discussion of population projections, the DEIR states that Southern California
Association of Governments ("SCAG") and the Department of Finance estimate the
following population numbers for the City of El Segundo: 16,777 residents by 2020 and
17,200 residents by 2045. (DEIR, p. 4.11-13 to 14). The DEIR claims that "the City is not
expected to meet the populations growth expectations set forth in the General Plan [of 17,200
March 11, 2022
Supplemental Comment on Final Environmental Impact Report
Pacific Coast Commons Specific Plan (SCH# 2020050508)
Page 3 of 6
people] until after 2045." (DEIR, p. 4-11.5.) Based on data from the U.S. Census, however,
these statements are false.
Census data reveals that as of April 1, 2020, El Segundo's population was 17,272
people — 72 more than SCAG's projected 2045 population.' The EIR states that the Project
will add an additional 618 people from this one project alone. In total, together with existing
population, the Project would cause the City's population to exceed the population relied on
in the 2020-2045 RTP/SCS by 690 people, not taking into account any additional residential
development. In addition to exceeding SCAG's projections, the population increase is also
greater than projections in the currently applicable General Plan. (DEIR, 4.11-13.) The
additional population stemming from this Project, as well as other cumulative residential
projects, is unplanned growth because it exceeds the population levels planned for. This
unplanned growth constitutes a significant impact that the City has failed to analyze and
mitigate.
The DEIR claims that "[i]t is likely that the proposed residential units would
accommodate a combination of existing residents and new residents that either currently
work within the City and/or new residents that would be hired as a result of projected
employment generation within the City." (DEIR, p. 4.11-13). However, the DEIR provides
no evidence to support this claim. The DEIR also states that the City of El Segundo has a
housing vacancy rate of 4.7%, which is less than that of Los Angeles County, and that
therefore the Project is expected to be growth -accommodating rather than growth -inducing.
(Id.). The DEIR similarly provides no evidence to support this claim.
A revised EIR is necessary to analyze and mitigate this significant impact based on
the readily available 2020 census population data.
C. The FEIR Fails to Analyze and Mitigate Significant Land Use and Planning
Impacts.
The CEQA Guidelines provide that a project has a significant environmental impact if
it would "[c]onflict with any applicable land use plan, policy, or regulation of an agency with
jurisdiction over the project (including but not limited to the general plan, specific plan, local
coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an
environmental effect." (CEQA Guidelines Appendix G, Section X.b.) Pursuant to the
Guidelines, a conflict with a plan adopted to avoid or mitigate an environmental impact is
itself a significant impact.
In 2008, California enacted the Sustainable Communities and Climate Protection Act
(SB 375), requiring Metropolitan Planning Organizations and Regional Transportation
Planning Agencies to include a Sustainable Communities Strategy (SCS) element as part of
1 https.//www.census.eoyfauickfacts/elsegundocitycalifornia; also attached as Exhibit A.
March 11, 2022
Supplemental Comment on Final Environmental Impact Report
Pacific Coast Commons Specific Plan (SCH# 2020050508)
Page 4 of 6
their Regional Transportation Plan (RTP) update for the purpose of identifying policies and
strategies to reduce per capita passenger vehicle -generated GHG emissions. (Connect SoCal
PEIR, 2.0-1.) The EIR for SCAG's 2020-2045 RTP/SCS (known as Connect SoCal) explains
(Connect SoCal Draft PEIR, p. 2.0-1):
The SCS is required to identify the general location of land uses, residential densities,
and building intensities within the region; identify areas within the region sufficient to
house all the population of the region; identify areas within the region sufficient to
house an eight -year projection of the regional housing need; identify a transportation
network to service the regional transportation needs; gather and consider the best
practically available scientific information regarding resources areas and farmland in
the region; consider the state housing goals; set forth a forecasted development
pattern for the region; and allow the regional transportation plan to comply with the
federal Clean Air Act (CAA) of 1970 (42 USC. § 7401 et seg.) (Gov. Code, § 65080,
subd. (b)(F)(2)(B)), of which, when integrated with the transportation network, and
other transportation measures and policies will reduce the GHG from automobiles
and light duty trucks to achieve, if there is a reasonable way to do so, the GHG
emission reduction targets approved by the California Air Resources Board (ARB).
Beginning in 2012, SCAG adopted its first Regional Transportation Plan/Sustainable
Communities Plan, described as "a long-range plan for transportation in the region that links
air quality, land use, and transportation needs." (Connect SoCal Draft PEIR, p. 2.0-2.) The
most recent RTP/SCS was updated in 2020, and includes a growth forecast with population,
household and employment growth anticipated to occur by 2045, a transportation network
and planned projects, and a forecasted development pattern with land use and transportation
strategies. The 2020-2045 RTP/SCS "was developed to achieve targets for greenhouse gas
(GHG) emissions reductions, consistent with SB 375 and other regional goals." (Connect
SoCal Draft PEIR, p. 2.0-2.) "The Plan details how the SCAG region can achieve several
outcomes essential to the success of the region's long-range transportation and land use
goals." (Connect SoCal Draft PEIR, p. 2.0-10.)
The EIR concludes that the Project will not have a significant land use and planning
impact because the "Project would not conflict with the applicable goals in the RTP/SCS
adopted for the purpose of avoiding or mitigating an environmental effect." (DEIR, 4.9-11.)
But the threshold of significance is not limited to consistency with a plan's goals. Here, the
Project is inconsistent with the 2020-2045 RTP/SCS because it permits population growth —
and related additional vehicle use, GHG emissions, etc. — beyond what was forecast and
planned for in the RTP/SCS. Growth beyond the assumptions used in the RTP/SCS will have
impacts on transportation, air quality, land use, and greenhouse gas emissions. This is a
significant impact that must be disclosed, analyzed, and mitigated in a revised EIR.
The EIR ignores this potential impact in part by relying on a modified threshold of
signficance that asks "[w]ould the project cause a significant environmental impact due to a
March IL , 2022
Supplemental Comment on Final Environmental Impact Report
Pacific Coast Commons Specific Plan (SCH# 2020050508)
Page 5 of 6
conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or
mitigating an environmental effect? (DEIR, p. 4-9.11.) This threshold of significance fails to
acknowledge that, where a plan or policy is adopted for the purpose of avoiding or mitigating
an environmental effect, the conflict itself is an environmental impact.
D. The FEIR Fails to Analyze and Mitigate the Project's Cumulative Impact on
Population Growth and Land Use and Planning Impacts.
EIR's must discuss a Project's significant cumulative impacts. 14 CCR § 15130(a).
This requirement flows from CEQA section 21083, which requires a finding that a project
may have a significant effect on the environment if "the possible effects of a project are
individually limited but cumulatively considerable.... `Cumulatively considerable' means
that the incremental effects of an individual project are considerable when viewed in
connection with the effects of past projects, the effects of other current projects, and the
effects of probable future projects."
The CEQA Guidelines allow two methods for satisfying the cumulative impacts
analysis requirement: the list -of -projects approach, and the summary -of projects approach.
Under either method, the EIR must summarize the expected environmental effects of the
project and related projects, provide a reasonable analysis of the cumulative impacts, and
examine reasonable mitigation options. 14 CCR § 15130(b). The EIR's cumulative impacts
analysis does not comply with either of these requirements.
The EIR's analysis of cumulative population impacts lists two other residential
projects proposed in the area, but does not discuss the additional population growth expected
from those projects. Without this information, there is no way to know the impact of the
Project on population growth, together with the impact of the cumulative projects. Similarly,
without this information, there is no way to know the cumulative impact on land use and
planning as a result of population levels that exceed projections. The Project's cumulative
impact on unplanned growth and land use and planning must be disclosed and its impacts
analyzed in a Revised EIR.
II. CONCLUSION
For the foregoing reasons, SAFER believes that the EIR is wholly inadequate.
SAFER urges the City Council to refrain from certifying the FEIR or recommending
approval of the Project in order to allow staff additional time to address the concerns raised
herein. Thank you for considering our comments and please include this letter in the record
of proceedings for this project.
March 11, 2022
Supplemental Comment on Final Environmental Impact Report
Pacific Coast Commons Specific Plan (SCH# 2020050508)
Page 6 of 6
Sincerely,
Pnialiauntes
Lozeau Drury LLP
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Harada. Patricia
From:
Sent:
To:
Subject:
Council received email below.
Tracy
Sent from my iPhone
Begin forwarded message:
Weaver, Tracy (City Clerk)
Tuesday, March 15, 2022 7:12 AM
*ALL CITY CLERKS
Fwd: Pacific Coast Commons Meeting on March 15
From: Matthew Klemp <elmdatte@gmail.com>
Date: March 14, 2022 at 11:24:22 PM PDT
To: ALL ELECTED OFFICIALS <ALLELECTEDOFFICIALS@elsegundo.org>
Subject: Pacific Coast Commons Meeting on March 15
3/14/2022
Greetings City of El Segundo,
I live directly neighboring the proposed site of this development. The size, scope and potential impact of
PCC on neighboring single family neighborhoods warrants engaging with local community site adjacent.
To date, very few if any substantive mitigation measures have been put forth.
This being said, my view is:
1. Don't build any of it on proposed site.
2. Eliminate the northern portion of the project.
3. Whatever portion is passed, implement the following mitigating measures:
a) Local resident only parking on all streets in a 2 block radius.
b) Change adjacent local park hours from 24 hr to something like sunup to sundown.
c) Parking next to city parks can't be "residents only" I understand that, but it could be
restricted to something like "5 hr max" parking. I've seen this at other parks. This would
still enable park enjoyment for the public and deter vehicle owners from using it as a
personal parking spot. (Actually is a win - win, opening up space for more legitimate
park usage)
d) Erect fencing around all adjacent parks. Some park areas along Washington st have
fencing others do not. Fencing all of it, again deters non -park goers from using it as a
personal parking spot, it is safer for park goers and their children as they have this
physical boundary from what are busy streets now that will undoubtedly become busier
with thousands more people living and driving on local streets.
e) 3 way stop at intersection of Illinois and Mariposa and signage that deters
shortcutting on residential streets. Traffic backups should occur within PCC garage
parking and NOT City streets. The Development should bear the impact of traffic
backups not the City and its current residents. If people walk as much as the Developers
claim they will, this would be a non -issue anyhow.
fl Speed bumps along common shortcut streets like Washington between Mariposa
and Maple which will become more prevalent if PCC is built. I know PCC developers
swear none of this will happen but I'd bet my life on it that it does. It's just common
sense.
g) Stricter noise ordinance surrounding property. If it is not going to be impactful as
developer claims then there shouldn't be a problem enacting various types of
ordinances as insurance and just for well-being of ALL citizens.
h) Developer paid fund for mitigation of impacts known and unknown, refundable at
set time period if their proposal promises hold up.
To summarize, local residents want to feel like they matter. All of the mitigation measures cost next to
nothing. Any POTENTIAL for adverse impacts should be shouldered by the developer now and in
perpetuity via current design or regulatory stipulations made for future consideration.
Sincerely,
Matthew Klemp
Harada, Patricia
From: Weaver, Tracy (City Clerk)
Sent: Tuesday, March 15, 2022 12:50 PM
To: *ALL CITY CLERKS
Subject: FW: Pacific Coast Commons Comments for ES City Council Meeting 3/15/22
Attachments: parking congestion impact Feb 22 mtg.pdf, Feb 10 planning mtg re PCC and more
pg1 jpg; Feb 10 planning mtg re PCC and more rev2 pg2jpg
Council received the email below.
Thank you,
Tracy Weaver I City Clerk
City of El Segundo
350 Main Street El Segundo CA 90245
310.524.2305 1 tweaver@elegundo.or www.elsegundo.or�
EL,EGUNDO
Where lei- id4nv!. lapse off.
From: Cheryl Smith <hollykansasneighbors@gmail.com>
Sent: Tuesday, March 15, 2022 12:48 PM
To: ALL ELECTED OFFICIALS <ALLELECTEDOFFICIALS@elsegundo.org>
Subject: Pacific Coast Commons Comments for ES City Council Meeting 3/15/22
Dear El Segundo City Council Team,
I am sorry that I cannot attend the meeting tonight, but once again, I have a conflict with running the middle school
PTSA meeting.
I would like to ask for your consideration of the impact that the Pacific Coast Common project will have on the
Holly/Kansas/Washington area of town with respect to congestion and traffic. I feel that the proposed building
specifications when it comes to parking is not adequate.
As you know from the residents on California and Holly Streets, there is already a street parking issue, as you have
granted them a parking permit for their streets.
Please find attached my letter to the Planning Commission, as well as a couple of graphics about the impact of all of the
known projects (as of Feb 22, 2022) that are happening in this little 5 block neighborhood square (since 2/22/22, 1 have
become aware of the mini condo complex going in near Mariposa & Nevada - adjacent to the Mormon Church - again
adding congestion & traffic to our corner of town).
I would like to ask for your support of our community by:
• stipulating that more parking is needed for the Pacific Coast Commons project.
• instituting permit parking for residents for Kansas, Washington, Illinois, Indiana, and maybe even as far north as
Elm and Palm.
• creating a flow of traffic through this part of town that makes it undesirable for people to use the neighborhood
streets as an alternative to the major thoroughfare, like cutting through Kansas to get from Mariposa to E Grand,
rather than taking the major roads which were created to handle the traffic.
Thank you for the time you give to our town and for your consideration of my comments.
Sincerely,
Cheryl
416 Kansas St.
February 10, 2022
To: El Segundo Planning Commission
From: Cheryl Smith, Kansas Street neighbor
RE: Pacific Coast Commons Project and Building at El Segundo Blvd and Kansas St.
Thank you all for volunteering your time to be the team that reviews requests from developers and
listens to the community to determine what is a good fit for our town.
I would like to address two of the agenda items for your meeting today. Personally, I prefer pictures to
get an idea of the scope of what I am looking at, so I have included a couple of maps, so that you can get
the big picture of all of the changes that are being proposed in just a few blocks area of El Segundo.
These changes will impact the quiet neighborhood that we have bought into. This will change the
dynamic of congestion, traffic, parking and safety of our neighborhood streets. The commercial and
business ventures are encroaching on homes and family neighborhoods. I am asking that you be our
representatives and consider all of what is going on as you look to make your decisions today.
Concern #1: Addition of building space and building height precedent:
Per agenda G. 3. Proposed Smoky Hollow Specific Plan Amendment, Tier II Community Benefits Plans,
Site Plan Review, Master Sign Program, and Offsite Parking Covenant for the construction of
substantial additions to the existing buildings locate at 1475 East El Segundo Boulevard and 1320-1330
East Franklin Street. (BM/ES)
"Project Description: The proposed Specific Plan Amendment (SPA) would modify the Height
Development Standards for Community Benefit Plan (CBP) Tier II applicable projects in a designated 30-
acre subarea of the Smoky Hollow Specific Plan (SHSP) with a max. building height deviation up to 60
feet. The proposed Project also involves the redevelopment of two adjacent sites within the SHSP, the
South Site (aka Parcel A [EA No. 1281]) and the North Site (aka Parcel E [EA No. 1282]).
On the 1.01-acre South Site the Project would develop a 44,604-square foot addition to the existing
19,311 sf, one-story brick building that would be structurally preserved in place. This site would have a
total building area of 63,915 square feet (FAR = 1.45) and a new building height of 59' 6".
The proposed Project for the North Site would develop a 1.07-acre portion of a 4.34-
acre property with two buildings, one research and development and office building
and a coffee pavilion building. The existing 19,493 square foot (sf), one-story brick
building would be preserved and two new floors with 44,802 square feet would be
added above it. This would result in a total building area of 65,061 square feet (FAR
= 0.95) and a new building height of 59' 6". The new coffee pavilion will have 766
square feet with a maximum height of 23' 8". This site would also include construction
of a new 5,000-square foot public outdoor park with park seating, picnic tables, shade
trees and landscaping."
My comments:
Building Space: In looking at the highlighted text above, I see that there is additional building
space being added. This concerns me because of:
o the increased traffic on our streets of people coming in to/leaving town. I would like to
ask that the Planning Commission work to develop a flow into and out of the city that
does not include the neighborhood streets. For example, somehow block off or make
travel on streets like Mariposa, Kansas, California, Washington, Pine... unfavorable for
routes to be taken to get into town in order to avoid congestion on PCH.
o the increased number of cars that will need parking during the day. In researching
standard practices for commercial space (see below in references), it appears that the
commercial industry is trending towards 5-6 spaces per 1000 sq ft of office space. I
would like to ask that El Segundo adopt this guidance for all projects in an effort to
minimize parking congestion and impact on our surface streets. This is important so
that neighborhood safety and road visibility can be maintained. If these developments
were going in in an area east of PCH where there is a lot of commercial building, I could
understand the spillover onto the streets. But the proposed developments are just a
THREE blocks from the residential community of El Segundo or right next door. I
understand that this specific development is at the far end of Kansas, but it will have an
impact on the buildings north of El Segundo Blvd. As more cars come into town south,
they will push the other cars more north, which will push people work at the incoming
Catalyst building north and so on... a type of domino effect, which would result in
congestion on the streets of our quiet neighborhood and around Holly/Kansas Park.
Building Height: When the Smoky Hollow Plan was coming into existence, I had no idea that it
included the area NORTH of E Grand Ave. Smoky Hollow is south of E Grand Ave. And so the
plan went unnoticed by many and input was not given that should have been by the neighbors
in the Holly/Kansas/Washington/California streets area. I am concerned about the height that
the Catalyst building is proposing for their upcoming development. This building needs to be
inline with the surrounding buildings, not a big mirrored tower that would look better on the
east side of PCH, blocking the sun and aesthetics of our neighborhood. My point: I do not want
the 60' height of the new building at the end of Kansas (just 3 blocks away) to set a precedent or
make it easier for Catalyst to be able to build to this height. The height restriction should be 2
stories for anything that is adjacent to other single family homes.
Concern #2: Addition of building space, parking, congestion and traffic:
Per Agenda H. 4. Pacific Coast Commons Project - Street dedication waiver notice [IS "NOTICE"
NECESSARY HERE?]. (PS)
"Project Description: The Project site is currently occupied by surface parking lots,
the Fairfield Inn and Suites Hotel, and the Aloft Hotel. The Project would allow for the
redevelopment of the existing surface parking lots and a portion of the Fairfield Inn
and Suites Hotel property within the Project site through the adoption of a Specific
Plan. The adoption of a Specific Plan would allow for (1) the continued operation of
the Fairfield Inn and Suites Hotel and Aloft Hotel, which contain 596 rooms within
288,767 square feet of hotel development; (2) 327,021 square feet of residential
development for 263 new housing units, including 257 multi -family apartments and six
condominium/town homes; (3) 11,252 square feet of new commercial/retail uses; and
(4) three new parking structures containing approximately 792 parking stalls. The
Project site is bound by Palm Avenue on the north, PCH on the east, Holly Avenue on
the south, and Indiana Street on the west. Mariposa Avenue bisects the Project site.
The Project is required to dedicate portions of the project property frontage as public
street in compliance with the Circulation Element requirements.
My comments:
• 1 feel that I could just cut and paste what I wrote before regarding the impact to our streets in
regards to traffic, visibility and parking.
Please see the chart I created below. This information was pulled from information I have
received. It appears that Pacific Coast Commons (PCC) needs to add another 500 parking spaces
to their plan to account for the hotels, their employees, the new residents and the new
commercial developments that are being proposed.
■ Our neighborhood is being squeezed from the east by PCC, potentially by the new 60' structure
at the end of Kansas and definitely by Catalyst (right inside our neighborhood).
• I would like to point out that Pacific Coast Commons has committed to covering the
implementation cost of a resident permit parking district... what is considered the boundaries
for this parking district? Is it just Illinois? Indiana? Or will it extend west?
In summary:
Truly, this all comes down to the addition of building space, which will increase congestion and traffic on
our neighborhood streets and the reduction in parking. I think that there needs to be a better plan put
into place on how to protect our homes and neighborhoods. Those of us who live on the southeast side
of town are being bombarded by developments on the south and east sides of our quiet neighborhood.
All of this will bring in more people, more cars, more traffic, more congestion.
I would like to ask the Planning Commission to look at the Big Picture of all that is being proposed (again
see attached map for visual). How can we all win? How can our streets remain safe for kids, block
parties, families walking to school, etc.? We already have issues with people leaving cars on the streets
(as is evidenced by the California Street request for permit parking that was approved by City Council
February 2022).
Before this all goes into effect, why not do the traffic study and projections of the impact that all of
these upcoming projects will have to our neighborhoods now? Why not recommend to City Council to
put into place a parking permit system for all of Indiana/Illinois/Washington/Kansas/California streets
now? Why not look at making some of the streets in this area one-way to reduce traffic on the side
streets (making the side streets less appealing for non-residents to use)? Or increasing the ability for
people to use the main streets — like having main entrances to these big complexes only accessible from
PCH, E Grand Ave or El Segundo Blvd — not the little neighborhood streets?
Again, please consider the big picture and all that is going on in this 5 block area. Thank you so much for
your time and for taking my comments into consideration. My goal is to keep the community and
children safe.
Pacific Coast Commons Parking Concerns:
Location/Site
# of parking
# of parking
# of
# of parking
Total #
Stated Net
Name
spaces
spaces
parking
spaces
of
parking parking
needed for
neededfor
spaces
neededfor
parking
spaces spaces
new
Commercial
needed
hotel
spaces
committed
residents
use
for
employees
needed
hotel
guests
Existing
0
0
596
US avg is 1
696
Are these
+696
Fairfield &
rooms
employee/2
already in
Aloft hotels
= 596
rooms =
existence or
spaces
298
will they be
employees
torn up
= 100
during
spaces
construction
(assuming
and then
work 1/3 of
put into the
the day)
new 792
parking
structure?
Fairfield
No new
2,200 sq ft
14
792
-778
Parking
residential
= 14 spaces
Structure
structures
PCC North
137
2,223 sq ft Rolled
Rolled in to
300
+300
apartments
= 14 spaces in to
above #
& 6
above
Townhomes
#
@2
cars/home
= 286
spaces
120
5,756 sq ft Rolled
PCC South
Rolled in to
275
+275
apartments
= 35 spaces in to
above #
@ 2
above
cars/home
#
= 240
spaces
Total parking spaces that appear are not accounted for:
+493
Catalyst Project Parking Concerns:
Catalyst project (as stated on their website) is planning on a parking ratio of 3.4 to 1,000 sq ft. The
minimum industry recommended is 4 spaces with a preference of 5-6 spaces from occupants. Total
building area in the 4 buildings near the Kansas St and E Grand Ave intersection is 265,000 sq ft of space.
It appears Catalyst is planning for 900 parking spaces, when it will most likely need 1,590. So a deficit of
nearly 700 parking spaces.
References:
https://www.commercialrealestate.loans/commercial-real-estate-glossary/parking-ratio
"Office Parking Ratios May Be Increasing
Research suggests that office building tenants are asking for more parking-- and many developers are
responding by adding more parking spaces to their current developments, increasing their parking
ratios. While the most common office building parking ratio is currently around 4 (spots per 1,000 sq.
ft.), many tenants have been asking for ratios of S or 6. Though adding parking spots can be expensive
($2,000 to $6,000 per space for surface lots, $12,000 to $25,000 for garages), developers are often
seeing this as an investment that may be able to improve the long term occupancy of their projects."
httP://gcode.us/codes/redondobeach/view.phP?topic=10-5-5-10 5 1706
Redondo Beach Municipal Code
10-5.1706 Commercial, industrial, and other nonresidential parking standards.
Hotels and motels: The maximum required shall be as follows: one space for each guest room without
kitchen facilities and one and one-half spaces for each guest room with kitchen facilities; plus one space
per each 100 square feet of banquet, assembly, meeting, or restaurant seating area.
Business offices: One space for each 300 square feet of gross floor area.
Commercial uses: One space per each 250 square feet of gross floor area
Research and development offices and laboratories: One space for each 300 square feet, plus one
parking space for each truck or vehicle operated by the use.
https://www.ioptimizerealty.com/blog/what-to-know-about-parking-ratios
"What's the Right Parking Ratio?
For office space, you'll hear a rule of thumb that a ration of five spaces per 1,000 square feet is about
right, with applications like medical office and call centers requiring more parking."
https://www.codepubiishing.com/CA/StHelena/htmI/StHelena17/StHelena17124. html#:—:text=and%20
Office%20Uses.-,1.,each%20building%20or%20tenant%20space.
"Commercial and Office Uses.
1. General commercial and office: one space for each three hundred (300) square feet of building floor
area. A minimum of two parking spaces shall be provided for each building ortenant space."
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