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PUBLIC COMMENT: My name is Syl Salenius and I live in the Washington Square neighborhood. I do not <br />support the staff recommendation to approve this project at this time for the following reasons: <br />1. The new traffic analysis is deficient because it only addresses a reduction in trip generation <br />rates, not the change in background traffic from the time of the original EIR, or the effect that <br />the current project’s traffic will have on today’s heavier traffic volumes and the increased <br />background traffic projected to occur during the project’s lifetime. The original EIR was prepared <br />over 15 years ago, forecast background traffic was then based on the City’s plans at that time, <br />without the recent surge in high density apartment development and future anticipated intense <br />density increases, some of which may be encouraged by this very project. As a result there may <br />be many more adverse effects beyond those identified in the EIR and addressed by Mitigation <br />Measures being considered. A new traffic study, using new data to generate and forecast <br />background traffic is essential. <br /> <br />2. The assumptions used for residential occupancy may be erroneous. A sensitivity analysis of the <br />use of different assumptions should be conducted to provide sufficient information for decision- <br />makers. An occupancy of 2.4 persons/unit may not be accurate for todays pricey rental market. <br />A potential “worst case” rate of 3 or 3.5 persons/unit should be tested. This will not only affect <br />trip generation, but also the need for parking spaces in the garage, sewer capacity, water <br />supply, waste generation, additional city parkland and demand for other utilities and services. <br />The source of this average occupancy may be proven inadequate by the upcoming census, as it <br />was likely derived from 2010 data. <br /> <br />3. Residential trip generation rates seem particularly low. Another sensitivity test for a changed <br />assumption should be run using the higher Institute of Traffic Engineers trip generation rates for <br />a general urban/suburban setting. This project is not located in a downtown core like downtown <br />Los Angeles or Manhattan. The assumptions for am and pm peak hour trips appear to also be <br />underestimated at 14% or less. A new traffic analysis, using these higher rates, along with higher <br />background traffic levels should be run for all adversely affected intersections. <br /> <br />4. The approval documentation appears to suggest that the developer plans to pay a fee in lieu of <br />including ANY affordable housing units in his building. This is not what he said at the Community <br />Meeting. The affordable units he showed in the plans were also sequestered on lower floors, <br />with 332 units served by only 2 elevators. They were not equitably mixed in with the other units <br />in the building. Paradoxically, the 83 units on the upper floors were served by 4 elevators, not 2! <br />These elevators are shown on the plans for the first floor of the building. <br /> <br />5. Water demand and wastewater generation for the project substantially increase with the <br />inclusion of residential use and would increase even more if per unit occupancy levels have been <br />underestimated. A complete engineering analysis should be done to determine the “worst case” <br />scenario, with sensitivity testing for higher occupancy, to determine whether existingmains <br />must be re-sized. <br /> <br />6. I agree with many others that this project would generate a demand for new parkland. The <br />developer should be required to mitigate this need based upon City standards.