5 - PUBLIC COMMENT_SALENIUS - Laserfiche WebLink

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