Long Beach City Council
December 6, 2022

electric-powered, battery-powered, or hybrid construction equipment where commercially available,
13 and incorporate this requirement into the contract or contract specifications, which shall be submitted to the Los Angeles County Department of Public Works for review and approval.

Furthermore, there are additional feasible mitigation measures that the County could include to mitigate air emissions during construction. For example, the Project could adopt CARB’s recommended construction measures, including requiring off-road equipment with a power rating below 19 kilowatts be battery-powered and limiting site access during construction phases to only allow heavy-duty trucks manufactured in model year 2014 or later.

B. Mitigation of Impacts from Operation
In addition to improving the construction mitigation, further mitigation is warranted to address the Project’s impacts to air quality, greenhouse gas emissions, noise, and traffic.

First, although the MND assumes that the Project will not be a cold storage warehouse, the mitigation measures do nothing to prohibit TRUs from using the space. As mentioned above, cold storage warehouses and trucks with refrigeration emit significantly higher levels of air pollution. The County should include a restrictive covenant that prohibits the use of TRUs within the site boundaries. Without this restriction, there is not an enforceable mechanism to prevent the facility from operating in a more polluting manner not disclosed in the CEQA process.

Second, the MND finds that minimal mitigation will eliminate the Project’s significant greenhouse gas emissions impacts. For instance, the MND states that the Project is consistent with green building development measures because it will have a “cool roof,” pre-wiring for electric charging stations, and a “solar ready” roof that lacks solar panels. While these measures would allow for future improvements to the Project that could mitigate greenhouse gas emissions, they would not provide any mitigation for the Project’s impacts without such future action. The County instead should require specific, enforceable measures to mitigate its climate impact in accordance with regional policies. For instance, the Project could follow through on commitments made to the Department of Toxic Substances Control (DTSC) by the Project applicant in September 2017,14 including a commitment to construct the warehouse to Leadership in Energy and Environmental Design (LEED) standards. Constructing the building to LEED standards would involve taking a variety of specific and enforceable measures to

13 Holian & Pyeon, Analyzing the Potential of Hybrid and Electric Off-Road Equipment in Reducing Carbon Emissions from Construction Industries (2017) Mineta Transportation Institute, <https://scholarworks.sjsu.edu/cgi/viewcontent.cgi?article=1233&context=mti_ publications> (as of Jan. 21, 2020).
14 Letter from Bridge to DTSC (Sept. 7, 2017) <https://www.envirostor.dtsc.ca.gov/public/ deliverable_documents/5706785440/Bridge%20Request%20for%20Oversight%20Ltr.%20

9.1.17.pdf> (as of Jan. 21, 2020).
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reduce the climate impact of the Project.

Third, the Project’s Noise Property Design Feature 13-1 is too vague to qualify as enforceable mitigation. Noise Property Design Feature 13-1 states that “[n]o outdoor operations shall be permitted within 74 feet of the eastern property line during night and early morning hours, which are to be determined.” The MND defines “outdoor operations” narrowly to mean employee parking or driving, but it does not include outdoor trucking activity, such as trucks accessing and traversing the site. Furthermore, the MND does not specify which hours qualify as “night and early morning hours.” The County should strengthen this mitigation measure to make it clear, specific, and enforceable in order to prevent noise impacts to the residents living in close proximity to the Project.

Fourth, the Project’s traffic mitigation measures may not prevent potential harm to nearby residents. Air Quality Property Design Feature 3-3 states that trucks will be limited to use of the Normandie Avenue driveway during the Project’s operations. However, based on the renderings in the MND, the Torrance Boulevard entrances lack any structural design features or barriers that would prevent entrance by trucks, who could then drive or idle within roughly 50 feet of nearby homes. Furthermore, the MND does not require that trucks accessing the Project adhere to authorized truck routes, nor prohibit them from using streets in the nearby residential communities. This is a further commitment made by the Project applicant to DTSC in September 2017.

Given the increase in warehouse facilities and truck emissions exposing the already vulnerable surrounding community to excessive air pollution, it is critical that the County adopt all feasible measures to mitigate the Project’s potentially significant environmental impacts. The Attorney General’s Office would be happy to provide any assistance it can as the County considers how best to mitigate the Project’s impacts.

C. The Project Will Have the Significant Impact of Conflicting with Adopted Land Use Plans and Therefore the County Should Prepare an EIR Conflict with applicable land use plans, policies, or regulations, adopted to avoid or mitigate environmental effects, qualifies as an environmental impact under CEQA.15 Furthermore, whenever there is a fair argument of significant environmental impact, such as an inconsistency with a local land use plan, the lead agency should prepare an environmental impact report.16 The Project conflicts with several provisions of the Los Angeles County General Plan and Climate Action Plan. The County General Plan has several policies that require a buffer between incompatible land uses, including Policy N 1.11, Policy ED 2.2, and Policy LU 7.1.

Yet, as planned, the Project will construct an industrial warehouse on a site located 15 feet from residential homes. CARB recommends a 300-meter (1,000-foot) buffer between sensitive receptor locations and sources of truck traffic emissions, like distribution centers. A more

15 Friends of Riverside’s Hills v. City of Riverside (2018) 26 Cal.App.5th 1137, 1150. 16 Id. at p. 1151.
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substantial buffer is necessary to mitigate many of the Project’s impacts on the surrounding community and to comply with General Plan policies.

If the size of the Project were reduced, it would be possible to create a larger buffer between the warehouse and surrounding sensitive receptors. For instance, the Project could install a vegetative buffer of at least 13 feet in height and 16.4 to 32 feet in width on the east and west sides, in addition to a solid barrier, to effectively lower concentrations of ultrafine particulates.17
Furthermore, the Project is inconsistent with several measures of the Los Angeles County’s Climate Action Plan. The County’s Climate Action Plan requires encouragement of ride- and bike-sharing programs and employer-sponsored vanpools and shuttles. Yet the MND does not address this requirement. The Project is also inconsistent with the Climate Action Plan’s policy of promoting sustainability in land use design. The MND suggests that siting an industrial warehouse within feet of residences is an example of compliance with this policy.

However, this is an example of incompatible land use development rather than a diversity of urban and suburban developments that would further sustainability.

The County should study and address the Project’s conflict with the County’s General Plan and Climate Action Plan in a full environmental impact report.

IV. CONCLUSION
CEQA provides the opportunity for transparent, thoughtful governance by requiring evaluation, public disclosure, and mitigation of a project’s significant environmental impacts prior to project approval. Further, “CEQA requires an agency to prepare an EIR for a project ‘whenever it can be fairly argued on the basis of substantial evidence that the project may have significant environmental impact.’ ”
18 In evaluating the Project’s impacts, the County should consider the surrounding community’s already-high pollution burden and the cumulative impact of siting another industrial warehouse close to residences, schools, childcare facilities, and a medical center. The County needs to revise existing mitigation measures to make them binding and enforceable. In addition, further mitigation is necessary and feasible to address the Project’s potentially significant impacts. Finally, given the Project’s inconsistencies with General Plan and Climate Action Plan policies, there is a fair argument that the Project may have a significant environmental impact and warrant preparation of an EIR.

The Attorney General’s Office is available to provide assistance to the County as it works on CEQA compliance. Please do not hesitate to contact me if you have any questions or would like to discuss these issues further.

17 University of Michigan & Great Lakes Environmental Law Center, Vegetative Buffers and Tree Canopy: Promoting the Use of Trees to Improve Local Air Quality with Local Policy (2018) <http://sustainability.umich.edu/media/files/dow/VegetativeBuffersTeam1-2018-Report.pdf> (as of Jan. 21, 2020).
18 Friends of Riverside’s Hills v. City of Riverside (2018) 26 Cal.App.5th 1137, 1150. 130
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Sincerely,

JESSICA WALL
Deputy Attorney General
For XAVIER BECERRA
Attorney General
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Image of the proposed Project and adjacent land uses, with residential uses highlighted in green. 132

XAVIER BECERRA
Attorney General
State of California

DEPARTMENT OF JUSTICE
1300 I STREET, SUITE 125
P.O. BOX 944255
SACRAMENTO, CA 94244-2550
Public: (916) 445-9555
Telephone: (916) 210-7808
Facsimile: (916) 327-2319
E-Mail: [email protected]
January 31, 2019
Ms. Brandi Jones
Senior Planner
City of Irwindale, Planning Division
5050 North Irwindale Avenue
Irwindale, CA 91706
RE: Comments on the Notice of Intent to Adopt a Mitigated Negative Declaration for the 5175 Vincent Avenue Project (SCH #2018121056)
Dear Ms. Jones:

As we discussed on the phone January 30, 2019, the California Attorney General’s Office has reviewed the City of Irwindale’s Notice of Intent to Adopt a Mitigated Negative Declaration (MND) and Initial Study for the 5175 Vincent Avenue Project (the Project). On Friday, January 18, 2019, the Attorney General’s Office submitted a set of questions concerning the Project to the City. We have not yet received a response, and we understand that the City needs additional time to respond to the questions. Nonetheless, for the City’s benefit as it considers how to proceed, we respectfully submit these comments regarding the City’s compliance with the California Environmental Quality Act (CEQA).1
While we commend the City’s remediation of the former Manning Pit site, the MND and Initial Study for this large warehouse project fail to support the City’s conclusion that the Project would not have significant impacts on the surrounding low-income community of color. One of the “basic purposes of CEQA [is] to [i]nform governmental decision makers and the public about the potential, significant environmental effects of proposed activities.”2 The threshold for
determining whether an environmental impact report (EIR) is required is a low one—an EIR is needed if substantial evidence supports a “fair argument” that a project may have a significant effect on the environment.3 Here, the City’s air quality impact analysis fails to evaluate the 1 The Attorney General submits these comments pursuant to his independent power and duty to protect the environment and natural resources of the State. (See Cal. Const., art. V, § 13; Gov.

Code, §§ 12511, 12600-12612; D’Amico v. Bd. of Medical Examiners (1974) 11 Cal.3d 1, 14–

15.)
2 CEQA Guidelines, § 15002(a)(1).
3 The Pocket Protectors v. City of Sacramento (2005) 124 Cal.App.4th 903, 928; Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1399–1400.
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Project’s cumulative impacts, as required by CEQA. Nor does it analyze all of the Project’s reasonably foreseeable uses, including the use of the warehouse for refrigerated storage. It also fails to evaluate the Project's consistency with the regional air quality plan. In addition, contrary to the Initial Study’s conclusion, the traffic noise data provides substantial evidence of a significant environmental impact, warranting additional study. We therefore urge the City to prepare an EIR to fully study, disclose, and mitigate the Project’s significant environmental impacts.

I. THE PROJECT WOULD SITE A LARGE WAREHOUSE ON A RESIDENTIAL STREET IN A HIGHLY-POLLUTED LOW INCOME MINORITY COMMUNITY.

The Project consists of an approximately 545,735 square-foot high-cube warehouse, 199 standard parking stalls, 181 truck parking stalls, and utility and landscaping improvements.4 The Initial Study predicts that the Project would generate 580 truck trips and 2,128 passenger car trips daily.5 The Project site totals 26.05 acres across two vacant parcels.6 While the site is zoned M-2 for Heavy Manufacturing uses, 8.07 acres of the site are currently designated Residential in the City’s General Plan, which the Project would re-designate Industrial/Business Park.7
The Project is located on Vincent Avenue at the boundary of southeastern Irwindale and Vincent, an unincorporated community in Los Angeles County.8 Vincent Avenue is a busy residential street with single-family homes across from the Project.9 Additional single-family homes are to the west, along with Irwindale Park, Irwindale City Hall, and a public library.10 Alice M. Ellington Elementary School is less than 1,000 feet to the east, and thirteen other schools are located within approximately 1.5 miles of the Project.11 North of the site is a largely industrial area.12 To the south sits the remainder of the former quarry area and more singlefamily homes.13 The surrounding community is already highly burdened by pollution. According to CalEnviroScreen 3.0, CalEPA’s screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability, the Project’s census tract ranks worse than 90-95 percent of the rest of the state overall.14 The census tract is in the 100th percentile for pollution 4 Initial Study at p. 4.
5 Id. at p. 95 Table 18.
6 Id. at p. 3.
7 Id. at p. 3-5.
8 Id. at p. 3.
9 Id. at p. 11 Fig. 3.
10 Id. at p. 9 Fig. 2.
11 Ibid. 12 Id. at p. 11 Fig. 3.
13 Id. at p. 17 Fig. 6.
14 CalEnviroScreen 3.0, available at https://oehha.ca.gov/calenviroscreen (as of January 17, 2019). CalEnviroScreen is a tool created by the Office of Environmental Health Hazard 134

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burden, meaning it is more polluted than almost all other census tracts in the entire state. The surrounding community bears the impact of multiple sources of pollution and is more polluted than average on every pollution indicator measured by CalEnviroScreen. The Project area has more solid waste sites, groundwater threats, toxic releases, hazardous waste sites, and traffic than 85 percent of the State. Furthermore, the community, which is largely Hispanic, is especially vulnerable to the impacts of pollution. The community has very high unemployment rates, which is an indication that they may lack health insurance or access to medical care. Furthermore, the community surrounding the Project has a higher proportion of babies born with low birthweights than 82 percent of the State, which makes those children more vulnerable to asthma and other health issues. The residents of neighboring Vincent are likewise majority Hispanic and bear a relatively high pollution burden according to CalEnviroScreen.

II. THE CITY’S AIR QUALITY IMPACT ANALYSIS IS INSUFFICIENT.

A. The City Failed to Analyze Cumulative Air Quality Impacts. “One of the most important environmental lessons evident from past experience is that environmental damage often occurs incrementally from a variety of small sources.”15 Consequently, CEQA requires analysis of cumulative impacts.16 Despite inclusion of a cumulative air quality impact checklist question, however, the Initial Study provides no analysis of cumulative air quality impacts. Instead, it groups the cumulative impacts criterion with its analysis of the Project’s individual impacts and proceeds to evaluate only the Project’s incremental effects.17 Because the Initial Study finds that the Project in isolation would not exceed any emissions standard, it concludes that its air quality impacts—including, without saying so, its cumulative impacts—would be less than significant.18 But an Initial Study must “[e]xplain[] the reasons for determining that potentially significant effects would not be significant.”19 A proper cumulative impacts analysis involves considering the incremental impact of the Project in combination with related impacts of other Assessment that uses environmental, health, and socioeconomic information to produce scores and rank every census tract in the state. A census tract with a high score is one that experiences a much higher pollution burden than a census tract with a low score. Office of Environmental Health Hazard Assessment, CalEnviroScreen 3.0 Report (January 2017), available at https://oehha.ca.gov/media/downloads/calenviroscreen/report/ces3report.pdf. 15 Kings Cty. Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 720. 16 CEQA Guidelines, Appendix G, §§ 15130, 15355.
17 Initial Study at pp. 30-34.
18 Id. at pp. 33-34.
19 Id., § 15063, subd. (c)(3)(C).
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past, present, and reasonably foreseeable probable future projects.20 That inquiry is distinct from considering the Project’s impacts in isolation.21
Analysis of the Project’s cumulative air quality impacts is especially crucial here because the Project is located in a community that already suffers from some of the worst pollution in the State. While the Project’s air quality impacts may not be significant in isolation, they become more concerning when combined with the pollution produced by nearby quarries, factories, oil recycling facilities, and warehouses. Moreover, sensitive receptors surround the Project site on three sides. Despite California Air Resources Board guidelines suggesting that distribution warehouses should be at least 1,000 feet away from sensitive land uses to avoid health impacts, single-family homes and an elementary school are within 1,000 feet to the west, east, and south.22 The Initial Study does not consider whether the Project’s impacts in combination with other sources of air pollution will have cumulative impacts on the nearby sensitive receptors could be significant. The City should prepare an EIR to investigate this question.

B. The City Must Consider the Air Quality Impacts of the Project’s Various Allowed Uses.

Under CEQA, the City must analyze all reasonably foreseeable Project impacts.23 That includes the Project’s various allowed uses. The project description states that “[h]igh-cube warehouses are generally grouped into five types: fulfillment center, parcel hub, cold storage facility, transload facility, and short-term storage facility,” and that “[t]he exact use of the proposed high-cube warehouse would fall into one of these five types.”24 Different types of warehouses have different environmental impacts. For example, because refrigeration functions produce substantially more air pollution and greenhouse gas emissions, cold storage warehouses have greater air quality impacts than other types of warehouses. As the California Air Resources Board explains, Transport Refrigeration Units (TRUs) are refrigeration systems powered by diesel internal combustion engines designed to refrigerate or heat perishable products that are transported in various containers, including semi-trailers, truck vans, shipping containers, and rail cars. Although TRU engines are relatively small, ranging from 20 Id., § 15355, subd. (b); Communities for a Better Env’t v. California Res. Agency (2002) 103 Cal.App.4th 98, 118 (“[T]he guiding criterion on the subject of cumulative impact is whether any additional effect caused by the proposed project should be considered significant given the existing cumulative effect.”).
21 Kings Cty. Farm Bureau v. City of Hanford, supra, 221 Cal.App.3d 692, 719-21 (holding that relatively small air quality impacts from a project do not eliminate the need to consider the project’s combined impacts with other development).
22 California Air Resources Board, Air Quality and Land Use Handbook: A Community Health Perspective (April 2005), at p. 4.
23 Laurel Heights Improvement Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 396. 24 Initial Study at p. 4.
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9 to 36 horsepower, significant numbers of these engines congregate at distribution centers, truck stops, and other facilities, resulting in the potential for health risks to those that live and work nearby.25
In its air quality analysis, the City appears to have evaluated only the impacts of an unrefrigerated warehouse, even though the Project could include refrigeration.26 The City must analyze the impacts of all reasonably foreseeable Project uses, including cold storage.

C. The City Did Not Justify its Conclusion that the Project is Consistent with the Regional Air Quality Plan.

Furthermore, the Initial Study failed to explain its finding that the Project would not conflict with the applicable air quality plan. The South Coast Air Basin’s air quality management plan surveys the region’s forecasted development and uses those projections to create a program to bring the region into compliance with federal air quality standards. Its projections are based on current land use plans, including zoning and local general plans. While much of the Project site is currently designated by the Irwindale General Plan for industrial uses, the Project involves re-designating about one-third of the site from residential to industrial. The Project’s industrial land use on this parcel would likely generate greater emissions than development based on its prior residential designation, so the Project could conflict with the air quality management plan’s projections. After acknowledging the change in land use designation, the Initial Study fails to analyze this potential impact. At minimum, the City must explain why re-designating 8.07 acres of the site from residential to industrial would not conflict with the air district’s air quality plan.27
III. THE CITY’S TRAFFIC NOISE IMPACT ANALYSIS DEMONSTRATES THAT THE PROJECT MAY HAVE A SIGNIFICANT ENVIRONMENTAL IMPACT.

The Project’s traffic noise impacts also warrant preparation of an EIR. Vincent Avenue, where the Project’s entrance points would be located, is a residential street lined with singlefamily homes.28 The Project would bring 580 daily truck trips and 2,128 daily passenger car trips to this street, subjecting the neighboring families to the attendant noise of this traffic 24 hours a day, seven days a week.29
Data from the Initial Study show that the Project may have significant traffic noise impacts. The City appears to use a 55-70 decibel significance threshold for noise impacts, which 25 California Air Resources Board webpage entitled Transport Refrigeration Unit (TRU or Reefer) ACTM, available at https://www.arb.ca.gov/diesel/tru/tru.htm. 26 Initial Study at Appendix A.
27 CEQA Guidelines, § 15063, subd. (c)(3)(C) (providing that environmental documents must “[e]xplain[] the reasons for determining that potentially significant effects would not be significant”).
28 Initial Study at p. 11 Fig. 3.
29 Id. at p. 95 Table 18.
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is a state standard for “conditionally acceptable” noise.30 The Initial Study predicts traffic noise with the Project at two nearby points to be 72 decibels and 74.4 decibels, respectively.31 Both of these measurements are well above the 70 decibel threshold used by the City, especially as the decibel scale is logarithmic (meaning a 10 decibel increase is a doubling of noise).

Despite this data, the Initial Study finds that the Project “would result in a decibel level of approximately 70 dBA at the nearest residential receptors along Vincent.”32 It then incorrectly concludes that “[t]hese scenarios fall under the conditionally acceptable standard established by the State,” such that the impacts are less than significant.33 However, at minimum, the analysis showing traffic noise would be above 70 decibels is substantial evidence of a fair argument that the Project would cause a significant impact. An EIR to fully study and mitigate the Project’s significant traffic noise impacts is thus required.34
IV. CONCLUSION
CEQA promotes public health and thoughtful governance by requiring evaluation, public disclosure, and mitigation of a project’s significant environmental impacts before project approval. While we commend the City’s efforts to remediate the Project site, an MND is not appropriate for this large warehouse Project. The City should prepare an EIR to study all potentially significant Project impacts, including cumulative air quality impacts, the impacts of all reasonably foreseeable Project uses, the Project’s consistency with the regional air quality plan, and traffic noise impacts. In evaluating the Project’s impacts, the City should consider the surrounding community’s already-high pollution burden and vulnerability to the resulting health effects. I am available to provide assistance to the City as it further studies the impacts of the Project, including providing example mitigation measures from other similar projects. Please do not hesitate to contact me if you have any questions or would like to discuss.

Sincerely,

ROBERT SWANSON
Deputy Attorney General
For XAVIER BECERRA
Attorney General
30 Id. at p. 75.
31 Id. at p. 77 Table 11.
32 Id. at p. 78.
33 Ibid. (emphasis added).
34 Gentry v. City of Murrieta, supra, 36 Cal.App.4th 1359, 1399–1400. 138

EXHIBIT B
139
Initial Study and Mitigated Negative
Declaration
Pacific Place Project
Prepared for City of Long Beach
411 West Ocean Boulevard, 3rd Floor
Long Beach, California 90802
Contact: Patricia Dienfenderfer, AICP
562.570.6261

Prepared by Psomas
5 Hutton Centre Drive, Suite 300
Santa Ana, California 92707
Contact: Jennifer Marks
714.751.7373
October 19, 2020
140
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Pacific Place Project
Initial Study/Mitigated Negative Declaration
R:\Projects\LON\3LON010101\Environmental Documentation\MND\Pacific Place MND-101920.docx 2-3 Project Location and Environmental Setting Photo 7 is taken from the southeast part of the McDonald Trust parcels looking north and shows bare land in the foreground; trees in the center of the view; and the Metro A Line tracks on the right.

Photo 8 is taken from the southeast part of the McDonald Trust parcels looking southeast and shows bare land, trees, and shrubs onsite. Pacific Place is opposite the retaining wall on the right and the Metro A Line tracks are on the left. The I-405 overpass over Pacific Place is in the background.

2.3 PROJECT SITE HISTORY
The Artesia parcels were formerly used as an oil brine water treatment facility beginning in 1926 for nearby and onsite oil production activities. Oil brine was pumped to evaporation and treatment ponds (i.e., oil sumps) located on the Artesia parcels and the majority of the Artesia parcels were used as a treatment sump. Water was allowed to evaporate from the brine or seep into the subsurface below the sumps leaving behind a sludge. Following evaporation, the remaining sludge was left in the sumps or transported to an offsite location. Evaporation operations reportedly ceased at the Project site in the mid-1950s. Fill soil was imported to the site in the 1970’s; the fill was not suitable for unrestricted use (DTSC 2020).

Between 1937 and 1981, 13 oil wells were drilled onsite; 11 of these oil wells produced oil. All 13 wells were abandoned between 1961 and 2014 in accordance with the California Geologic Energy Management Division (CalGEM) standards at their respective times of abandonment (Roux 2020; CalGEM 2020). Documentation of abandonment in accordance with CalGEM (formerly the Division of Oil, Gas, and Geothermal Resources [DOGGR]) standards is provided in appendices to the Phase I Environmental Site Assessments included as Appendix G to this IS.

A golf learning facility opened on the Project site between 1995 and 1998 consisting of driving range; putting practice and chipping areas; a snack bar; a golf shop; a maintenance building; and a paved parking lot. The learning facility was listed in the City Directory as late as 2014 (Roux 2019). The only extant remains of the facility are the parking lot, supports for an overhead structure over the putting practice area, and netting.

2.4 SURROUNDING LAND USES
The Project site is bounded to the south by a California Department of Transportation (Caltrans) maintenance station; the I-405 freeway; a ramp from Pacific Avenue to the northbound I-405 freeway; and the transition road from the northbound I-405 to the northbound I-710 freeways. The Los Angeles County Metropolitan Transportation Authority (Metro) A Line (formerly Blue Line) light rail tracks are located immediately east of the Project site. Beyond the Metro A Line tracks are Los Cerritos Park, Los Cerritos Elementary School, and single-family residential uses. The Los Angeles River (hereinafter referred to as the “River”), which exists as an engineered concrete channel, and vacant land next to the east bank of the River run along the western boundary of the Project site. West of the River are a stormwater detention basin and an equestrian club. The site is bounded to the north by undeveloped land.

2.5 ZONING AND GENERAL PLAN DESIGNATIONS
The City of Long Beach Zoning Designation for the Project site is IL, Light Industry. The General Plan designation for most of the Project site is Neo Industrial (NI); the designation for part of one of the McDonald Trust Parcels, APN 7140-014-023, is Open Space with a two-story building height limit (OS/2st) (Long Beach 2020h).
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Initial Study/Mitigated Negative Declaration
R:\Projects\LON\3LON010101\Environmental Documentation\MND\Pacific Place MND-101920.docx 5-19 Discussion of Environmental Checklist Questions However, these odors would be temporary and would dissipate rapidly from the source with an increase in distance.

The Artesia parcels portion of the Project would include a dump station for recreational vehicles.

The dump station would be connected to the City sewer system. The dump station cover would have seals to prevent the escape of objectional odors.

The Project would also be regulated from nuisance odors and other objectionable emissions by SCAQMD Rule 402. Rule 402, Nuisance, prohibits discharge from any source of air contaminants or other material which would cause injury, detriment, nuisance, or annoyance to people or the public. Compliance with Rule 402, which the Project must do, would ensure that no significant odor impacts would result. Development of an EMP per SCAQMD Rule 1150 for the former sludge ponds will provide mitigation for potential excavation of underlying oily waste. Therefore, other emissions would be considered less than significant, and no mitigation is required.

MITIGATION PROGRAM
AIR-1 For the Artesia parcels, prior to the issuance of each grading permit, the City or its designee shall provide construction plans and specifications demonstrating that, onsite equipment used for construction of the Project shall be required to meet a minimum of Tier 3 or equivalent off-road engine emissions standards. Tier 4 compliant engines can also be used, which would further reduce emissions, but are not required.

IV. BIOLOGICAL RESOURCES
Information in this Section is based on the Biological Resources Assessment for the Artesia Parcels completed by LSA on April 8, 2020 (Appendix C1) and a Biological Constraints Letter Report for the McDonald Parcels completed by Psomas on April 23, 2020 (Appendix C2), the Focused Special-Status Plant Species for the Industrial Self-Storage/RV Parking Project at 3701 Pacific Place, Long Beach, California prepared by LSA on August 21, 2020 (Appendix C3), and the Crotch Bumblebee Visual Survey for the Industrial Self Storage/RV Parking at 3701 Pacific Place, Long Beach, California prepared by LSA on September 11, 2020 (Appendix C4).

Existing Conditions
Artesia Parcels
The vegetation onsite is sparse and dominated by nonnative plants and scattered native plant species. The dominant nonnative plant species growing in the Artesia parcels is tumbling pigweed (Amaranthus albus), followed by garland chrysanthemum (Glebiones coronaria). Other nonnative vegetation growing on site includes tocalote (Centaurea melitensis), Russian-thistle (Salsola tragus), shortpod mustard (Hirschfeldia incana), and London rocket (Sisymbrium irio). Native plant species observed include mule fat (Baccharis salicifolia ssp. salicifolia), common horseweed (Erigeron canadensis), and cliff malacothrix (Malacothrix saxatilis var. tenuifolia). Ornamental vegetation (i.e., palm, pine, eucalyptus, and sycamore trees; including Mexican fan palm [Washingtonia robusta]) is interspersed among portions of the parking lot in the southern part of the site.

Eight special-status plant species with a 2B.2 California Rare Plant Rank (i.e., plants moderately threatened in California, but more common elsewhere) or rarer were determined to have a potential to occur onsite. The biological survey for the Artesia Parcels was conducted in early December 2019 within the late blooming period for one species and not within the known blooming 144
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Initial Study/Mitigated Negative Declaration
R:\Projects\LON\3LON010101\Environmental Documentation\MND\Pacific Place MND-101920.docx 5-20 Discussion of Environmental Checklist Questions period for the remaining seven species. One of the seven species, southern tarplant (Centromadia parryi ssp. australis), was observed onsite. The remaining six species, which were each determined to have low potential to occur onsite, are Coulter’s saltbush (Atriplex coulteri), Parish’s brittlescale (Atriplex parishii), lucky morning glory (Calystegia felix), decumbent goldenbush (Lasthenia glabrata var. deumbens), Coulter’s goldfields (Lasthenia glabrata ssp. coulteri), and prostrate vernal pool navarretia (Navarretia prostrata). None of these species were observed on the Artesia Parcels during the biological survey, which concluded that the probability of a habitat to support any of these species on the Artesia Parcels was very low.

Focus surveys for special-status plants Coulter’s saltbush, Parish’s brittlescale, lucky morning glory, decumbent goldenbush, Coulter’s goldfields, prostrate vernal pool navarretia, San Bernardino aster (Symphyotrichum defoliatum), and any additional southern tarplant individuals.

Between the biological resources assessment conducted in 2019 and focused surveys conducted in 2020, an estimated total of 830 southern tarplant individuals were identified within the Project limits for the Artesia Parcels. No other special-status plant species were observed.

The following special-status animal species were determined to have at least a low potential to occur onsite but none were found on the Artesia Parcels during the biological survey:
 Palos Verde blue butterfly (Glaucopsyche lygdamus palosverdesensis) has potential to forage onsite.
 Burrowing owl (Athene cunicularia) has the potential to forage onsite and/or in the surrounding area; but the habitat onsite is not suitable for nesting.  Yuma myotis (Myotis yumanensis), Mexican free-tailed bat (Tadarida brasiliensis), and western yellow bat (Lasiurus xanthinus) each have the potential to forage and/or roost onsite.

A visual survey was conducted for the Crotch bumble bee (Bombus crotchii) in August 2020. At this time, it was determined that potential Crotch bumble bee habitat on the Artesia Parcels was of poor quality due to high disturbance and low diversity of flowering plant species. A dispersing male was seen foraging within the vegetation, but no nest was identified.

No sensitive habitats were observed onsite.

The Project site was surveyed for waters or wetlands potentially jurisdictional to the United States Army Corps of Engineers (Corps), Los Angeles Regional Water Quality Control Board (LARWQCB), or the California Department of Fish and Wildlife (CDFW); no jurisdictional areas were identified.

McDonald Trust Parcels
The McDonald Trust parcels is composed entirely of disturbed vegetation types; no native vegetation types are present. Ruderal vegetation occurs in the northern portion of the McDonald Trust parcels; these areas are composed of weedy species indicative of past disturbance. Nonnative species observed included black mustard (Brassica nigra), field mustard (Brassica rapa), shortpod mustard (Hirschfeldia incana), sourclover (Melilotus indicus), common castor bean (Ricinus communis), wild radish (Raphanus sativus), tree tobacco (Nicotiana glauca), redstem filaree (Erodium cicutarium), common dandelion (Taraxacum californicum), ripgut grass (Bromus diandrus), and foxtail chess (Bromus madritensis). Ornamental vegetation occurs throughout the McDonald Trust parcels and consists of non-native trees and shrubs planted for ornamental purposes. Ornamental species observed included Mexican fan palm, queen palm (Syagrus 145
Intentionally Blank
146
Pacific Place Project
Initial Study/Mitigated Negative Declaration
R:\Projects\LON\3LON010101\Environmental Documentation\MND\Pacific Place MND-101920.docx 5-22 Discussion of Environmental Checklist Questions The McDonald Trust parcels was surveyed for waters or wetlands potentially jurisdictional to the United States Army Corps of Engineers (Corps), LARWQCB, or CDFW; no jurisdictional areas were identified.

IMPACT ANALYSIS
Would the Project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Less than Significant Impact with Mitigation Incorporated.

Artesia Parcels
Project development would impact one special status plant species identified onsite — southern tarplant. According to the 2020 focus survey results, due to the high level of ongoing disturbance within the Artesia Parcels, and the prevalence of ruderal, nonnative plant species on site, it is highly unlikely that any of the other special-status plant species would occur on the site.

Project development could impact all the special-status animal species listed above: crotch bumblebee; Palos Verde blue butterfly; burrowing owl; Yuma myotis, Mexican free-tailed bat, and western yellow bat. Myotis species frequently roost in palm trees. In addition, western yellow bats have been documented using palm trees as maternity roosts, so it is possible that the palm trees could be used for maternity roosting. Impacts to the special-status southern tarplant and animal species would be potentially significant. Implementation of Mitigation Measures BIO-1 and BIO-5 would reduce these impacts to less than significant.

McDonald Trust Parcels
Project development would impact one special status plant species identified onsite — southern tarplant. Project development also has the potential to impact the special status plant species determined to have low potential to occur onsite: Horn’s milk-vetch, Coulter’s saltbush, Parish’s brittlescale, lucky morning-glory, decumbent goldenbush, Coulter’s goldfields, prostrate vernal pool navarretia, coast woolly-heads, estuary seablite, and San Bernardino aster.

Project development could impact all the special-status animal species listed above: crotch bumblebee; western tidal-flat tiger beetle; sandy beach tiger beetle; western beach tiger beetle; coast horned lizard; California brown pelican; silver-haired bat; and big free-tailed bat. Most of these species are not expected to occur onsite due to lack of suitable habitat. However, potentially suitable foraging and roosting habitat for the big free-tailed bat is present on the McDonald Trust parcels. Impacts to special-status plant and animal species would be potentially significant.

Implementation of Mitigation Measures BIO-2 through BIO-5 would reduce these impacts to less than significant.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or US Fish and Wildlife Services? No Impact.
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EXHIBIT C
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4/10/2021 Exide ordered to clean up toxic substances near Vernon plant - Los Angeles Times https://www.latimes.com/local/la-xpm-2013-dec-18-la-me-exide-20131219-story.html 1/10

CALIFORNIA
Exide ordered to clean up toxic substances near Vernon plant

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4/10/2021 Exide ordered to clean up toxic substances near Vernon plant - Los Angeles Times https://www.latimes.com/local/la-xpm-2013-dec-18-la-me-exide-20131219-story.html 2/10 The state toxics agency says lead and other toxic metals have been deposited near the Exide plant in Vernon and must be cleaned up by Jan. 31. (Anne Cusack, Los Angeles Times) By JESSICA GARRISON
DEC. 18, 2013 12 AM PT
The state Department of Toxic Substances Control has issued an emergency order directing a Vernon battery recycler to clean up lead and other metals that have been deposited near the Exide Technologies plant.

In a letter released Wednesday, the agency said dust and soil samples with metals in concentrations at or near hazardous waste levels have been found near the facility and must be cleaned up by Jan. 31. The order is urgent, the agency wrote, because winter rains could wash the metals into the Los Angeles River. “DTSC considers the elevated concentrations of lead and other contaminants … an immediate threat to human health and the environment (i.e. the Los Angeles River),” regulators wrote to Exide, one of the world’s largest battery recyclers. Exide has until Dec. 31 to come up with a work plan.

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4/10/2021 Exide ordered to clean up toxic substances near Vernon plant - Los Angeles Times https://www.latimes.com/local/la-xpm-2013-dec-18-la-me-exide-20131219-story.html 3/10 The agency’s letter does not say where the high concentrations of lead were found, but notes they were within 1,500 feet of the plant and in two storm drains along Bandini Boulevard.

Agency officials also noted in a separate memo earlier this month that “lead...and arsenic was detected in several locations in residential areas.” It did not specify the concentrations near residential areas, only that they are above the Environmental Protection Agency’s regional screening levels but below hazardous waste levels.

Exide officials could not be reached for comment. But residents living near the battery plant and their advocates said they were alarmed.

Msgr. John Moretta, the pastor at Resurrection Catholic Church in Boyle Heights, where a group of residents has been pushing regulators for years to do more to curtail pollution from the plant, said this is a “reason to shut them down.” “They have not been good neighbors,” he said. “All these years of abuse, all these years of uncontained pollution … people are complaining of aggravated asthma, incidents of autism, incidents of neurological problems.”
The state’s emergency order comes as the South Coast Air Quality Management District is pursuing its own petition calling for a halt to lead smelting operations at Exide “until its air pollution control systems are improved and deemed adequate” to control toxic emissions.

A hearing board for the air district is now taking testimony on that petition, including from residents who say their health is threatened and from Exide officials who say the plant should be allowed to stay open and that emissions have plummeted in recent months.
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4/10/2021 Exide ordered to clean up toxic substances near Vernon plant - Los Angeles Times https://www.latimes.com/local/la-xpm-2013-dec-18-la-me-exide-20131219-story.html 4/10 Exide has been the focus of intense attention from elected leaders, residents and officials since a health risk assessment released earlier this year by the air district found that the plant was posing an elevated cancer risk to 110,000 people living in communities stretching from Boyle Heights to Huntington Park because of arsenic emissions.

The plant, which opened in 1922 and was taken over by Exide in 2000, has been cited several times in recent years, often for exceeding permissible levels of lead.

In April, the toxics department, which oversees the plant, moved to shut it down temporarily, citing health risks, but Exide appealed and a judge allowed the plant to resume operations.

The state entered into an agreement with the company in which Exide agreed to spend $7.7 million for a new storm water system and improvements to reduce arsenic emissions.

It also agreed to sample dust and soil in the neighborhood around its plant to determine whether dangerous metals have accumulated and are posing a health risk to the community.

Lead is a potent neurotoxin. Children are more vulnerable than adults and can suffer learning disabilities even with limited exposure. Arsenic, a carcinogen, can also cause nausea, decreased blood-cell production and abnormal heart rhythm.

Soil and dust samples were collected in August and October. Based on the results, the toxics agency this week told the company it must take more samples beyond 4,500 feet from the plant’s perimeter, to make sure toxins have not spread further.

Among the many issues with Exide is the fact that the plant has been operating for decades without a full permit as required by the 1976 federal Resource Conservation 153
4/10/2021 Exide ordered to clean up toxic substances near Vernon plant - Los Angeles Times https://www.latimes.com/local/la-xpm-2013-dec-18-la-me-exide-20131219-story.html 5/10 and Recovery Act. Instead, the plant has been on “interim status” the entire time.

Also on Wednesday, state Sen. Kevin de Leon (D-Los Angeles) said he intends to introduce legislation requiring the state toxics department to speed up permitting decisions. State Sen. Ricardo Lara (D-Long Beach) also recently announced his own proposed legislation requiring all hazardous waste facilities in the state to get a final permit by 2015 or be shut down.
“It is extremely frustrating that people in disadvantaged communities continue to suffer from high levels of pollution ... that are allowed by DTSC to continue to operate for years and even decades,” De Leon said. “It’s time to say stop. Facilities not in compliance with the law must be shut down.”
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EXHIBIT D
155
4/10/2021 Auditor slams California for Exide cleanup delays - Los Angeles Times https://www.latimes.com/california/story/2020-10-27/auditor-slams-states-management-exide-cleanup-says-it-may-cost-650-million 1/11

CALIFORNIA
Auditor slams California for Exide cleanup delays, says cost could reach $650 million

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156
4/10/2021 Auditor slams California for Exide cleanup delays - Los Angeles Times https://www.latimes.com/california/story/2020-10-27/auditor-slams-states-management-exide-cleanup-says-it-may-cost-650-million 2/11 Workers remove topsoil from homes in Boyle Heights in 2015 as part of a state-led cleanup of lead contamination from thousands of properties surrounding the closed Exide Technologies battery recycling plant in Vernon. (Irfan Khan / Los Angeles Times)
By TONY BARBOZA | STAFF WRITER
OCT. 27, 2020 3:30 PM PT
The cleanup of thousands of lead-contaminated homes, child-care centers, schools and parks surrounding the closed Exide battery recycling facility in Vernon is running behind schedule and over budget due to poor management by California regulators and has left children at continued risk of poisoning, according to a state audit released Tuesday.

The report by State Auditor Elaine Howle’s office criticized the California Department of Toxic Substances Control for delays, cost overruns, contracting problems and other shortcomings in its effort to remove lead contamination from properties across half a 157
4/10/2021 Auditor slams California for Exide cleanup delays - Los Angeles Times https://www.latimes.com/california/story/2020-10-27/auditor-slams-states-management-exide-cleanup-says-it-may-cost-650-million 3/11 dozen communities in southeast L.A. County. The audit estimated the cleanup is likely to cost hundreds of millions of dollars more than the state has set aside.

For the record:
2:55 PM, Oct. 28, 2020 A previous version of this story said the Department of Toxic Substances Control was now cleaning about 20 properties a month, and has been updated to clarify that it refers to the number of properties cleaned per month during the first six years of the project.

Among the most troubling findings, according to the auditor’s office, was Toxic Substances Control’s failure to remove lead-tainted soil from most of the 50 properties, including child-care centers, schools and parks, that it identified in the early stages of the cleanup as posing a particularly high risk to children. “Despite the risk these properties present, DTSC has yet to clean 31 of them,” the audit said. “In fact, it has cleaned only one of these properties since May 2018.” At its current pace, the department’s cleanup of the 3,200 worst-contaminated properties will not be finished “until more than one year after the expected completion

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4/10/2021 Auditor slams California for Exide cleanup delays - Los Angeles Times https://www.latimes.com/california/story/2020-10-27/auditor-slams-states-management-exide-cleanup-says-it-may-cost-650-million 4/11 date” in June 2021, the audit found, “extending the time that residents in the cleanup site are exposed to dangerous levels of lead.”
Cleaning all 7,800 contaminated properties in the pollution zone stretching 1.7 miles from the closed plant could ultimately approach $650 million, the state auditor estimated.

California lawmakers have so far allocated more than $250 million for the cleanup of the most heavily contaminated properties, but Toxic Substances Control will exhaust that funding with 269 of those properties uncleaned, the audit found, and the department has no timeline or strategy to clean the other 4,600 properties that will remain contaminated.

Assemblyman Miguel Santiago (D-Los Angeles), who requested the audit, said “it is unacceptable that the department will run out of money that the state gave them” and demanded ”DTSC fix their mistakes and create a realistic plan to clean up every single contaminated property.”
Agency Director Meredith Williams said the department is learning from its mistakes and will implement all of the auditor’s recommendations. She acknowledged in an interview that “it did take us a while to come up to speed,” and said the department has cleaned an average of 20 properties a month during the first six years of the project. “We are efficient. We control costs carefully. We learned every step of the way on this cleanup.”

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4/10/2021 Auditor slams California for Exide cleanup delays - Los Angeles Times https://www.latimes.com/california/story/2020-10-27/auditor-slams-states-management-exide-cleanup-says-it-may-cost-650-million 5/11 About 2,000 properties have been cleaned since soil removal began in residential areas in 2014.

Among the recommendations in the report: That the department “immediately begin cleaning all childcare centers, parks, and schools,” deploy enough resources to clean the 3,200 most polluted properties on time, set a schedule for cleaning all 7,800 contaminated properties and identify the amount of additional funding needed.

In a response letter released with the audit, Williams said the department does not currently have funding to clean the remaining 4,600 properties, and “without knowing a sustained level of funding, providing people in the community with an end date for the cleanup of their properties is at best a guess.”

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Williams called it “the largest, most logistically complex residential cleanup project the state of California has ever undertaken” and said the department “has cleaned up more properties, more quickly than any other residential lead cleanup in the nation.” The state auditor countered that Toxic Substances Control “did not provide any evidence to support its assertion” about the pace of the Exide cleanup relative to other projects.
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4/10/2021 Auditor slams California for Exide cleanup delays - Los Angeles Times https://www.latimes.com/california/story/2020-10-27/auditor-slams-states-management-exide-cleanup-says-it-may-cost-650-million 6/11 The audit came less than two weeks after a federal bankruptcy court approved a plan by Exide to walk away from the heavily contaminated Vernon facility and leave the cleanup to state taxpayers.

Assemblywoman Cristina Garcia (D-Bell Gardens) said she was disappointed that the findings validated the public’s concerns that “there is no clear plan to ensure all homes with unsafe lead levels get cleaned.”

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“It’s maddening that DTSC has not prioritized cleaning of the schools, parks, and daycare centers, where children frequent, since they are the most vulnerable,” she said.

Garcia said the state should loan the toxic substances department money to keep the cleanup going and repay it using existing fees on lead-acid batteries, rather than waiting for those funds to come in over time.
“We cannot use Exide’s bankruptcy as an excuse to not clean up these homes,” Garcia said. “Our next generation will not be left with a poisoned community.”

CALIFORNIA CLIMATE & ENVIRONMENT
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EXHIBIT G
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4/8/2021 Arsenic
https://www.who.int/news-room/fact-sheets/detail/arsenic 1/6 ©
Arsenic
15 February 2018
ا
ة 中⽂ Français Русский Español
Arsenic is naturally present at high levels in the groundwater of a number of countries.

Arsenic is highly toxic in its inorganic form.

Contaminated water used for drinking, food preparation and irrigation of food crops poses the greatest threat to public health from arsenic.

Long-term exposure to arsenic from drinking-water and food can cause cancer and skin lesions. It has also been associated with cardiovascular disease and diabetes. In utero and early childhood exposure has been linked to negative impacts on cognitive development and increased deaths in young adults.

The most important action in affected communities is the prevention of further exposure to arsenic by provision of a safe water supply.

Key facts
Sources of exposure
Arsenic is a natural component of the earth’s crust and is widely distributed throughout the environment in the air, water and land. It is highly toxic in its inorganic form.

People are exposed to elevated levels of inorganic arsenic through drinking contaminated water, using contaminated water in food preparation and irrigation of food crops, industrial processes, eating contaminated food and smoking tobacco.
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4/8/2021 Arsenic
https://www.who.int/news-room/fact-sheets/detail/arsenic 2/6 Long-term exposure to inorganic arsenic, mainly through drinking-water and food, can lead to chronic arsenic poisoning. Skin lesions and skin cancer are the most characteristic effects.

Drinking-water and food
The greatest threat to public health from arsenic originates from contaminated groundwater.

Inorganic arsenic is naturally present at high levels in the groundwater of a number of countries, including Argentina, Bangladesh, Chile, China, India, Mexico, and the United States of America.

Drinking-water, crops irrigated with contaminated water and food prepared with contaminated water are the sources of exposure.

Fish, shellfish, meat, poultry, dairy products and cereals can also be dietary sources of arsenic, although exposure from these foods is generally much lower compared to exposure through contaminated groundwater. In seafood, arsenic is mainly found in its less toxic organic form.

Industrial processes
Arsenic is used industrially as an alloying agent, as well as in the processing of glass, pigments, textiles, paper, metal adhesives, wood preservatives and ammunition. Arsenic is also used in the hide tanning process and, to a limited extent, in pesticides, feed additives and pharmaceuticals.

Tobacco
People who smoke tobacco can also be exposed to the natural inorganic arsenic content of tobacco because tobacco plants can take up arsenic naturally present in the soil. Also, in the past, the potential for elevated arsenic exposure was much greater when tobacco plants used to be treated with lead arsenate insecticide.

Health effects
Inorganic arsenic is a confirmed carcinogen and is the most significant chemical contaminant in drinking-water globally. Arsenic can also occur in an organic form. Inorganic arsenic compounds (such as those found in water) are highly toxic while organic arsenic compounds (such as those found in seafood) are less harmful to health.

Acute effects
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4/8/2021 Arsenic
https://www.who.int/news-room/fact-sheets/detail/arsenic 3/6 The immediate symptoms of acute arsenic poisoning include vomiting, abdominal pain and diarrhoea. These are followed by numbness and tingling of the extremities, muscle cramping and death, in extreme cases.

Long-term effects
The first symptoms of long-term exposure to high levels of inorganic arsenic (for example, through drinking-water and food) are usually observed in the skin, and include pigmentation changes, skin lesions and hard patches on the palms and soles of the feet (hyperkeratosis). These occur after a minimum exposure of approximately five years and may be a precursor to skin cancer.

In addition to skin cancer, long-term exposure to arsenic may also cause cancers of the bladder and lungs. The International Agency for Research on Cancer (IARC) has classified arsenic and arsenic compounds as carcinogenic to humans, and has also stated that arsenic in drinking-water is carcinogenic to humans.

Other adverse health effects that may be associated with long-term ingestion of inorganic arsenic include developmental effects, diabetes, pulmonary disease, and cardiovascular disease. Arsenicinduced myocardial infarction, in particular, can be a significant cause of excess mortality. In China (Province of Taiwan), arsenic exposure has been linked to “Blackfoot disease”, which is a severe disease of blood vessels leading to gangrene. This disease has not been observed in other parts of the world however, and it is possible that malnutrition contributes to its development.

Arsenic is also associated with adverse pregnancy outcomes and infant mortality, with impacts on child health (1), and exposure in utero and in early childhood has been linked to increases in mortality in young adults due to multiple cancers, lung disease, heart attacks, and kidney failure (2).

Numerous studies have demonstrated negative impacts of arsenic exposure on cognitive development, intelligence, and memory (3).

Magnitude of the problem
Arsenic contamination of groundwater is widespread and there are a number of regions where arsenic contamination of drinking-water is significant. It is now recognized that at least 140 million people in 50 countries have been drinking water containing arsenic at levels above the WHO provisional guideline value of 10 μg/L (4).
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4/8/2021 Arsenic
https://www.who.int/news-room/fact-sheets/detail/arsenic 4/6 Arsenic in Bangladesh has attracted much attention since recognition in the 1990s of its wide occurrence in well-water in that country. Since this time, significant progress has since been made and the number of people exposed to arsenic exceeding the Bangladesh drinking-water quality standard has decreased by approximately 40%. Despite these efforts, it was estimated that in 2012 about 19 million and 39 million people in Bangladesh were still exposed to arsenic concentrations above the national standard of 50 μg/L and the WHO provisional guideline value of 10 μg/L respectively (5). In a highly affected area of Bangladesh, 21.4% of all deaths in the area were attributed to arsenic levels above 10 μg/L in drinking-water (6). A similar dose-response function has been found in other parts of Bangladesh, and these results have been combined with national survey data to estimate an annual death toll of nearly 43 000 (7). The US National Research Council has noted that as many as 1 in 100 additional cancer deaths could be expected from a lifetime exposure to drinking-water containing 50 μg/L (8).

The symptoms and signs caused by long-term elevated exposure to inorganic arsenic differ between individuals, population groups and geographical areas. Thus, there is no universal definition of the disease caused by arsenic. This complicates the assessment of the burden on health of arsenic.

Similarly, there is no method to distinguish cases of cancer caused by arsenic from cancers induced by other factors. As a result, there is no reliable estimate of the magnitude of the problem worldwide.

In 2010, the Joint FAO/WHO Expert Committee on Food Additives (JECFA) re-evaluated the effects of arsenic on human health, taking new data into account. JECFA concluded that for certain regions of the world where concentrations of inorganic arsenic in drinking-water exceed 50–100 μg/L, there is some evidence of adverse effects. In other areas, where arsenic concentrations in water are elevated (10–50 μg/L), JECFA concluded that while there is a possibility of adverse effects, these would be at a low incidence that would be difficult to detect in epidemiological studies.

Prevention and control
The most important action in affected communities is the prevention of further exposure to arsenic by the provision of a safe water supply for drinking, food preparation and irrigation of food crops.

There are a number of options to reduce levels of arsenic in drinking-water.

Substitute high-arsenic sources, such as groundwater, with low-arsenic, microbiologically safe sources such as rain water and treated surface water. Low-arsenic water can be used for drinking, cooking and irrigation purposes, whereas high-arsenic water can be used for other purposes such as bathing and washing clothes.

Discriminate between high-arsenic and low-arsenic sources. For example, test water for arsenic levels and paint tube wells or hand pumps different colours. This can be an 167
4/8/2021 Arsenic
https://www.who.int/news-room/fact-sheets/detail/arsenic 5/6 effective and low-cost means to rapidly reduce exposure to arsenic when accompanied by effective education.

Blend low-arsenic water with higher-arsenic water to achieve an acceptable arsenic concentration level.

Install arsenic removal systems – either centralized or domestic – and ensure the appropriate disposal of the removed arsenic. Technologies for arsenic removal include oxidation, coagulation-precipitation, absorption, ion exchange, and membrane techniques.

There is an increasing number of effective and low-cost options for removing arsenic from small or household supplies, though there is still limited evidence about the extent to which such systems are used effectively over sustained periods of time.

Long-term actions are also required to reduce occupational exposure from industrial processes.

Education and community engagement are key factors for ensuring successful interventions. There is a need for community members to understand the risks of high arsenic exposure and the sources of arsenic exposure, including the intake of arsenic by crops (e.g. rice) from irrigation water and the intake of arsenic into food from cooking water.

High-risk populations should also be monitored for early signs of arsenic poisoning – usually skin problems.

WHO response
Arsenic is one of WHO’s 10 chemicals of major public health concern. WHO’s work to reduce arsenic exposure includes setting guideline values, reviewing evidence, and providing risk management recommendations. WHO publishes a guideline value for arsenic in its Guidelines for drinking-water quality. The Guidelines are intended for use as the basis for regulation and standard setting worldwide.

The current recommended limit of arsenic in drinking-water is 10 μg/L, although this guideline value is designated as provisional because of practical difficulties in removing arsenic from drinking-water.

Every effort should therefore be made to keep concentrations as low as reasonably possible and below the guideline value when resources are available.

However, millions of people around the world are exposed to arsenic at concentrations much higher than the guideline value (100 μg/L or greater), and therefore the public health priority should be to reduce exposure for these people. Where it is difficult to achieve the guideline value, Member States may set higher limits or interim values as part of an overall strategy to progressively reduce risks, while taking into account local circumstances, available resources, and risks from low arsenic sources that are contaminated microbiologically.
168
4/8/2021 Arsenic
https://www.who.int/news-room/fact-sheets/detail/arsenic 6/6 The WHO/UNICEF Joint Monitoring Programme for Water Supply, Sanitation and Hygiene monitors progress towards global targets on drinking water. Under the new 2030 Agenda for Sustainable Development, the indicator of "safely managed drinking water services" calls for tracking the population accessing drinking water which is free of faecal contamination and priority chemical contaminants, including arsenic.
(1) Association of arsenic with adverse pregnancy outcomes/infant mortality: a systematic review and meta-analysis.

Quansah R, Armah FA, Essumang DK, Luginaah I, Clarke E, Marfoh K, et al. Environ Health Perspect. 2015;123(5):412-21.
(2) In utero and early life arsenic exposure in relation to long-term health and disease.

Toxicol Appl Pharmacol. Farzan SF, Karagas MR, Chen Y. 2013;272(2):384-90. (3) The developmental neurotoxicity of arsenic: cognitive and behavioral consequences of early life exposure.

Tolins M, Ruchirawat M, Landrigan P. Ann Glob Health. 2014;80(4):303-14. (4) Arsenic Pollution: A Global Synthesis.

Ravenscroft P, Brammer H, Richards K. Wiley-Blackwell; 2009. (5) Multiple Indicator Cluster Survey 2012-13: Final Report.

BBS/UNICEF. Dhaka: Bangladesh Bureau of Statistics/UNICEF, 2015. (6) Arsenic exposure from drinking water, and all-cause and chronic-disease mortalities in Bangladesh (HEALS): a prospective cohort study.

Argos M, Kalra T, Rathouz PJ, Chen Y, Pierce B, Parvez F, et al. The Lancet. 2010;376(9737):252-8. (7) Arsenic in tube well water in Bangladesh: health and economic impacts and implications for arsenic mitigation.

Flanagan SV, Johnston RB, Zheng Y. Bulletin of the World Health Organization. 2012;90:839-46. (8) Arsenic in Drinking Water.

NRC. Washington: National Research Council, 1999. ISBN-0-309-06333-7 169

EXHIBIT H
170
Toluene
108-88-3
Hazard Summary
Toluene is added to gasoline, used to produce benzene, and used as a solvent.  Exposure to toluene may occur from breathing ambient or indoor air affected by such sources.  The central nervous system (CNS) is the primary target organ for toluene toxicity in both humans and animals for acute (short-term) and chronic (long-term) exposures. CNS dysfunction and narcosis have been frequently observed in humans acutely exposed to elevated airborne levels of toluene; symptoms include fatigue, sleepiness, headaches, and nausea.  CNS depression has been reported to occur in chronic abusers exposed to high levels of toluene.  Chronic inhalation exposure of humans to toluene also causes irritation of the upper respiratory tract and eyes, sore throat, dizziness, and headache.  Human studies have reported developmental effects, such as CNS dysfunction, attention deficits, and minor craniofacial and limb anomalies, in the children of pregnant women exposed to high levels of toluene or mixed solvents by inhalation. EPA has concluded that that there is inadequate information to assess the carcinogenic potential of toluene.

Please Note: The main sources of information for this fact sheet are EPA's Integrated Risk Information System (IRIS) (2), which contains information on inhalation chronic toxicity of toluene and the RfC, oral chronic toxicity and the RfD, and the carcinogenic effects of toluene, and the Agency for Toxic Substances and Disease Registry's (ATSDR's) Toxicological Profile for Toluene. (1)
Uses
The major use of toluene is as a mixture added to gasoline to improve octane ratings. Toluene is also used to produce benzene and as a solvent in paints, coatings, synthetic fragrances, adhesives, inks, and cleaning agents. (1)
Toluene is also used in the production of polymers used to make nylon, plastic soda bottles, and polyurethanes and for pharmaceuticals, dyes, cosmetic nail products, and the synthesis of organic chemicals. (1)
Sources and Potential Exposure
The highest concentrations of toluene usually occur in indoor air from the use of common household products (paints, paint thinners, adhesives, synthetic fragrances and nail polish) and cigarette smoke. The deliberate inhalation of paint or glue may result in high levels of exposure to toluene, as well as to other chemicals, in solvent abusers. (1)
Toluene exposure may also occur in the workplace, especially in occupations such as printing or painting, where toluene is frequently used as a solvent. (1)
Automobile emissions are the principal source of toluene to the ambient air. Toluene may also be released to the ambient air during the production, use, and disposal of industrial and consumer products that contain toluene. (1)
Levels of toluene m
3 easured in rural, urban, and indoor air averaged 1.3, 10.8, and 31.5 micrograms per cubic meter (µg/m ), respectively. (1)
Assessing Personal Exposure
Toluene and its breakdown products can be detected in the blood 171
or urine to determine whether or not
Toluene and its breakdown products can be detected in the blood or urine to determine whether or not exposure has occurred. Metabolites measured in the urine are not specific to toluene, and testing must occur within 12 hours of exposure. (1)
Health Hazard Information
Acute Effects:

The CNS is the primary target organ for toluene toxicity in both humans and animals for acute and chronic exposures. CNS dysfunction (which is often reversible) and narcosis have been frequently observed in humans acutely exposed to low or moderate levels of toluene by inhalation; symptoms include fatigue, sleepiness, headaches, and nausea. CNS depression and death have occurred at higher levels of exposure. (1)
Cardiac arrhythmia has also been reported in humans acutely exposed to toluene. (1) Following the ingestion of toluene a person died from a severe depression of the CNS. Constriction and necrosis of myocardial fibers, swollen liver, congestion and hemorrhage of the lungs, and tubular kidney necrosis were also reported. (1)
Acute exposure of animals to toluene has been reported to affect the CNS as well as to decrease resistance to respiratory infection. (1)
Acute animal tests in rats and mice have demonstrated toluene to have low acute toxicity by inhalation or oral exposure. (1)
Chronic Effects (Noncancer):

CNS depression has been reported to occur in chronic abusers exposed to high levels of toluene.

Symptoms include drowsiness, ataxia, tremors, cerebral atrophy, nystagmus (involuntary eye movements), and impaired speech, hearing, and vision.  Neurobehavioral effects have been observed in occupationally exposed workers. (1,2)
Effects on the CNS have also been observed in studies of animals chronically exposed by inhalation. (1,2) Chronic inhalation exposure of humans to toluene causes irritation of the upper respiratory tract and eyes, sore throat, dizziness, headache, and difficulty with sleep. (1,2) Inflammation and degeneration of the nasal and respiratory epithelium and pulmonary lesions have been observed in rats and mice chronically exposed to high levels of toluene by inhalation. (1) Mild effects on the kidneys and liver have been reported in solvent abusers chronically exposed to toluene vapor.  However, these studies are confounded by probable exposure to multiple solvents. (1,2) Slight adverse effects on the liver, kidneys, and lung and high-frequency hearing loss have been reported in some chronic inhalation studies of rodents. (1)
The Reference Concentration (RfC) for toluene is 5 milligrams per cubic meter (5 mg/m3) based on neurological effects in humans. The RfC is an estimate (with uncertainty spanning perhaps an order of magnitude) of a continuous inhalation exposure to the human population (including sensitive subgroups) that is likely to be without appreciable risk of deleterious noncancer effects during a lifetime.  It is not a direct estimator of risk but rather a reference point to gauge the potential effects.  At exposures increasingly greater than the RfC, the potential for adverse health effects increases.  Lifetime exposure above the RfC does not imply that an adverse health effect would necessarily occur. (2) EPA has high confidence in the RfC, the studies on which the RfC was based, and in the overall toluene database.  There are many high quality chronic human studies available including a subset of studies presenting a cluster of NOAELs for neurological effects below reported LOAELs for all available endpoints.

In addition, there are numerous supportive animal studies including those showing reproductive and developmental effects at doses higher than that identified as the point of departure. (2) The Reference Dose (RfD) for toluene is 0.08 milligrams per kilogram body weight per day (0.08 mg/kg/d) based on increased kidney weight in rats. (2)
EPA has medium confidence in the study on which the RfD was based because it was considered an adequate gavage study of subchronic duration.  The confidence in the database is also medium because of a lack of chronic oral data, and a lack of adequate data on end 172
points of potential concern for toluene
a lack of chronic oral data, and a lack of adequate data on endpoints of potential concern for toluene including neurotoxicity  . For these reasons, there is medium confidence in the RfD. (2) Reproductive/Developmental Effects:

CNS dysfunction, attention deficits, minor craniofacial and limb anomalies, and developmental delay were observed in the children of pregnant women exposed to toluene or to mixed solvents during solvent abuse.  Growth retardation and dysmorphism were reported in infants of another study.  However, these studies were confounded by exposure to multiple chemicals. (1,2) Children born to toluene abusers have exhibited temporary renal tubular acidosis. (1) Paternal exposure (in which the mothers had no occupational exposure to toluene but the fathers did) increased the odds ratio for spontaneous abortions; however, these observations cannot be clearly ascribed to toluene because of the small number of cases evaluated and the large number of confounding variables.

An increased incidence of spontaneous abortions was also reported among occupationally exposed women.

However, these studies are not conclusive due to many confounding variables. (1) Several inhalation studies have shown toluene to be a developmental toxicant, but not a reproductive toxicant, in rodents. (1)
Cancer Risk:

Available studies in workers have reported limited or no evidence of the carcinogenic potential of toluene.

Similarly, the few available  epidemiological studies have failed to demonstrate  increased risk of cancer due to inhalation exposure to toluene.  However, these studies were limited due to the size of the study population and lack of historical monitoring data. (1)
Chronic inhalation exposure of rats did not produce an increased incidence of treatment-related neoplastic lesions. (1,2)
Under the Guidelines for Carcinogen Risk Assessments (US. EPA, 2005), the EPA considers that there is inadequate information to assess the carcinogenic potential of toluene. (2) Physical Properties
The chemical formula for toluene is C H CH , and its molecular weight is 92.15 g/mol. (1) Toluene occurs as a colorless, flamma6ble5, re
3 fractive liquid, that is slightly soluble in water. (1) Toluene has a sweet, pungent odor, with an odor threshold of 2.9 parts per million (ppm). (1,4) The vapor pressure for toluene is 28.4 mm Hg at 25 °C, and its log octanol/water partition coefficient (log K
ow
) is 2.69. (1)
Conversion Factors:

To convert concentrations in air (at 25 °C) from ppm to mg/m 3 : mg/m
3 = (ppm) × (molecular weight of the
compound)/(24.45). For toluene: 1 ppm = 3.77 mg/m
3 .

Health Data from Inhalation Exposure
173
AIHA ERPG --American Industrial Hygiene Association's emergency response planning guidelines.  ERPG 1 is the maximum airborne concentration below which it is believed nearly all individuals could be exposed up to one hour without experiencing other than mild transient adverse health effects or perceiving a clearly defined objectionable odor; ERPG 2 is the maximum airborne concentration below which it is believed nearly all individuals could be exposed up to one hour without experiencing or developing irreversible or other serious health effects that could impair their abilities to take protective action.

ACGIH TLV --American Conference of Governmental and Industrial Hygienists' threshold limit value expressed as a time-weighted average; the concentration of a substance to which most workers can be exposed without adverse effects.

LC
50 (Lethal Concentration
50 )--A calculated concentration of a chemical in air to which exposure for a specific length of time is expected to cause death in 50% of a defined experimental animal population.

LOAEL--Lowest-observed-adverse-effect level.

NIOSH IDLH  -- National Institute of Occupational Safety and Health's immediately dangerous to life or health concentration; NIOSH recommended exposure limit to ensure that a worker can escape from an exposure condition that is likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from the environment.

NIOSH REL --NIOSH's recommended exposure limit; NIOSH-recommended exposure limit for an 8- or 10-h timeweighted-average exposure and/or ceiling. 174
weighted-average exposure and/or ceiling.

NIOSH STEL --NIOSH's recommended short-term exposure limit; a 15-minute TWA exposure which should not be exceeded at any time during a workday.

OSHA ceiling --Occupational Safety and Health Administration's permissible exposure limit ceiling value; the concentration of a substance that should not be exceeded at any time.

OSHA PEL--OSHA's permissible exposure limit expressed as a time-weighted average; the concentration of a substance to which most workers can be exposed without adverse effect averaged over a normal 8-h workday or a 40-h workweek.

The health and regulatory values cited in this factsheet were obtained in September 2005. a
Health numbers are toxicological numbers from human studies, animal testing or risk assessment values developed by EPA.
b
Regulatory numbers are values that have been incorporated in Government regulations, while advisory numbers are nonregulatory values provided by the Government or other groups as advice. OSHA numbers are regulatory, whereas NIOSH, ACGIH, and AIHA numbers are advisory.
c
This NOAEL average from several co-critical studies was used as the basis for the EPA RfC.

References

1. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile for Toluene. U.S. Public Health Service, U.S. Department of Health and Human Services, Atlanta, GA. 2000.

2. U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Toluene. National Center for Environmental Assessment, Office of Research and Development, Washington, DC.  2005.

3. American Industrial Hygiene Association (AIHA).  The AIHA 2010 Emergency Response Planning Guidelines and Workplace Environmental Exposure Level Guides Handbook. 1998.

4. J.E. Amoore and E. Hautala. Odor as an aid to chemical safety: Odor thresholds compared with threshold limit values and volatilities for 214 industrial chemicals in air and water dilution. Journal of Applied Toxicology, 3(6):272-290. 1983.

5. American Conference of Governmental Industrial Hygienists (ACGIH).  2009 Guide to Occupational Exposure Values.  Cincinnati, OH.  2009.

6. National Institute for Occupational Safety and Health (NIOSH).  Pocket Guide to Chemical Hazards.  U.S.

Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention.  Cincinnati, OH.  1997.

7. Occupational Safety and Health Administration (OSHA).  Occupational Safety and Health Standards, Toxic and Hazardous Substances.  Code of Federal Regulations 29 CFR 1910.1000.  1998.

Summary created in April 1992, updated in July 2012
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Pages Intentionally Omitted
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EXHIBIT K
177
TELEPHONE: (310) 820-2322
FACSIMILE: (310) 820-1452

LAWYERS FOR CLEAN WATER
11777 SAN VICENTE BOULEVARD
SUITE 555
LOS ANGELES, CALIFORNIA 90049
email: [email protected]
June 21, 2000
Via Facsimile and U.S. Mail
Ms. Emily Gabel-Luddy
Deputy Advisory Agency
Charlie Rausch
City Zoning Administrator
221 North Figueroa Street
Los Angeles, CA 90012-2601
Re: Comments on Mitigated Negative Declaration (MND-1999-2762- SUB(SPR)) for Vesting Tentative Tract Map and Site Plan Review for Lennar-Taylor Yard Project.

Dear Ms. Gabel-Luddy and Mr. Rausch,
On behalf of the Friends of the Los Angeles River (“FOLAR”), we submit the following comments regarding water quality and quantity impacts upon the Los Angeles River associated with Lennar Partners’ (“Lennar”) Application for Vesting Tentative Tract and Site Plan Review and the proposed Mitigated Negative Declaration and supporting documents (collectively referred to as “MND”) for the Taylor Yard development, Parcel “D” (“Project”). These comments are in addition to those submitted by Chatten-Brown and Associates, and incorporate those comments by reference.

A. THE PROJECT WILL RESULT IN SIGNIFICANT WATER QUALITY AND HYDROLOGY IMPACTS.

The Initial Study concludes that the hydrology and water quality impacts associated with the Project will be less than significant with mitigation measures. This conclusion is without substantial basis, as water quality and hydrology impacts were inadequately addressed. FoLAR believes the design standard for pollution from urban runoff must be for water quality standards to be met. The MND does not provide a meaningful discussion of the water quality of the runoff entering the Los Angeles River, nor the Best Management Practices to be incorporated into the Project as mitigation measure to achieve water quality standards to the maximum extent practicable.

1. The MND Fails to Adequately Analyze Whether the Project’s Urban Runoff Will Violate Water Quality Standards.
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The Initial Study concludes there will be a “less than significant impact” in terms of violations of water quality standards. However, the MND fails to identify what water quality standards, if any, are being applied to reach this conclusion. The available data regarding urban runoff impacts from commercial developments supports the conclusion that several water quality standards may be violated as a result of the Project. This is because the types and levels of pollutants that are likely to discharge from the Project’s urban runoff will likely be above the numeric and narrative levels set forth in: (a) the National Toxics Rule (40 C.F.R. § 131.36); (b) the California Toxics Rule (65 Fed. Reg. 31682, 31683 (U.S. EPA, May 18, 2000) (“Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic Pollutants for the States of California”)); (c) the Water Quality Control Plan for Ocean Waters of California (“California Ocean Plan”) (State Board Resolution No. 97-026), (d) the Water Quality Control Plan for the Los Angeles Region (“Basin Plan”); (e) Total Maximum Daily Load requirements (40 C.F.R. 122.4(i)), (f) the Los Angeles Regional Water Quality Control Board’s (“LARWQCB”) Standard Urban Storm Water Mitigation Plan; and (g) Proposition 65. Additionally, as set forth more fully below, the Project will likely violate federal and state Antidegradation provisions (40 C.F.R. 131.12; State Board Order 68-16) and will likely exceed accepted thresholds for impervious cover.

Section 303 of the Clean Water Act defines water quality standards as consisting of both the uses of the surface (navigable) waters involved and the water quality criteria which are applied to protect those uses. 33 U.S.C. Section 1313; Basin Plan, p. 3-1.

Under the Porter-Cologne Water Quality Control Act (California Water Code, Division 7, Chapter 2, Section 13050), these concepts are separately considered as beneficial uses and water quality objectives. Id. Several of the water quality standards applicable to the Project are discussed below.
a. National Toxics Rule.

Under the Clean Water Act, the states are primarily responsible for the adoption, and periodic review of water quality standards. 33 U.S.C. Section 1313. However, where a state does not act to adopt or update a standard, EPA can promulgate standards.

Id. Pursuant to this authority, in 1992, EPA promulgated the National Toxics Rule (“NTR”), to bring noncomplying states, such as California, into compliance with the Clean Water Act. 40 C.F.R. 131.36.

Data set forth in the Los Angeles County 1998-99 Stormwater Monitoring Report makes it clear that the levels of priority pollutants that would likely be discharged from the types of land uses envisioned by the Project would exceed the numeric water quality standards set forth in the NTR. The Report sets forth the types and levels of priority pollutants that are typically discharged from a commercial and industrial use site such as the Project. See Los Angeles County 1998-1999 Stormwater Monitoring Report (“County Stormwater Report”), July 14, 1999, prepared by the Los Angeles County of Public Works, URS Greiner Woodward Clyde, and Southern California Coastal Research 179
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Project. The County Stormwater Report. The NTR sets forth a chronic toxicity limit of

2.5 ug/l for lead, while the county data indicates the commercial land uses exceed these standards with levels at 12 ug/l. Similarly, the NTR sets forth a limit of 11 ug/l for copper chronic toxicity (and 17 ug/l for acute toxicity), while the county data reveals levels of 26 ug/l for commercial.1
b. The California Toxics Rule.

The federal government also recently enacted the California Toxics Rule (“CTR”) after California failed to do so. See 65 Fed. Reg. 31682, 31683 (U.S. EPA, May 18, 2000) (“Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic Pollutants for the States of California”). Pursuant to the CTR, any runoff discharging from the Project must meet the pollutant levels set forth in the CTR. Runoff that exceeds CTR standards should not be allowed to be discharged into the already impaired Los Angeles River. Despite this fact, the MND fails to even discuss the CTR, let alone specify that the levels of pollutants identified in the CTR be met by the Project Applicant for runoff discharging from the Project site.
c. The California Ocean Plan and the Los Angeles Basin Plan.

Additional numeric water quality standards are also set forth in the Water Quality Control Plan, Ocean Waters of California (State Water Resources Control Board Resolution No. 97-026) (“Ocean Plan”). Further, water quality criteria also include those narrative and numeric objectives set forth in Basin Plan at Chapter 3. d. The Standard Urban Storm Water Mitigation Plan.

The Los Angeles Regional Water Quality Control Board recently issued Resolution No. R-00-02 providing for a Standard Urban Storm Water Mitigation Plan (“SUSMP”).2 The SUSMP requires that certain structural and treatment control Best Management Practices (“BMPs”) be implemented for all new and redevelopment that falls within certain categories. Clearly, the SUSMP requirements will apply to the Project.
e. Total Maximum Daily Loads.

Section 303(d) of the federal Clean Water Act requires the state to identify all 1 If the City believes that the proposed treatment options will reduce this level to significantly below these criteria, the City must explain the basis for its conclusion as to all different water quality criteria. Topanga, supra, 11 Cal.3d at 515; Laurel Heights I, supra, 47 Cal.3d at 404. 2 See California Regional Water Quality Control Board, Los Angeles Region, Resolution No. R-00-02 (January 26, 2000) and Final SUSMP (March 8, 2000).
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impaired water bodies in the state and to identify the pollutants causing those impairments. 33 U.S.C. § 1313(d). The Los Angeles River is listed as impaired for several pollutants. See 303(d) List of Impaired Waterways. Federal regulations implementing the Clean Water Act prohibit all new discharges of impairing pollutants to impaired waterbodies. See 40 C.F.R. § 122.4(i). Discharges of pollutants is defined to include “surface runoff which is collected or channeled by man; discharges through pipes, sewers or other conveyances owned by a State (and) municipality or other person that do not lead to a treatment works.” 40 C.F.R. § 122.2. Thus, the prohibition includes any new source such as new developments, roads, and construction sites.

In particular, § 122.4(i) imposes a new source prohibition unless certain specific conditions are met. First, all necessary pollutant load allocations must be performed, i.e., Total Maximum Daily Loads (“TMDLs”) must be established. Second, the regulations clearly state that no discharge may commence unless there are “sufficient remaining pollution load allocations to allow for the discharge.” 40 C.F.R. § 122.4(i)(1), see also Clean Water Act § 303(d) (describing requirements for TMDLs). There are currently no TMDLs to indicate there is an available load allocation which would allow the new source. Based on the fact that most TMDLs for this waterway are years away,3it would be disingenuous to even suggest that these legal conditions have been met.

Further, the MND has failed to analyze the additional gross inputs for all CWA § 303(d) listed pollutants for the Los Angeles River, a significant oversight. For example, trash is a major problem in the Los Angeles River. See CWA §303(d) List; Santa Monica Bay Restoration Project, Taking the Pulse of the Bay - State of the Bay 1998 at 6.

One TMDL that will be completed in the near term is the trash TMDL for the Los Angeles River. The current draft TMDL for the Los Angeles River has a zero loading allocation for trash. Clearly, some trash will be generated from this Project and the residents and
businesses located there. However, the MND fails to identify how the stormwater facilities at the Project will be designed to insure that no trash will leave the Project site.

Without such analysis, the Project cannot go forward. Indeed, such an analysis must be conducted for all CWA § 303(d) listed pollutants and must demonstrate compliance with 40 C.F.R. § 122.4(i) before approval can be granted.
f. Proposition 65.

Proposition 65 states that “[n]o person in the course of doing business shall knowingly discharge or release a chemical known to the state to cause cancer or reproductive toxicity into water or onto or into land where such chemical passes or probably will pass into any source of drinking water...” Cal. Health & Safety Code Section 25249.5. The Los Angeles River has been identified by the LARWQCB as a 3 See Consent Decree lodged in Heal the Bay and Santa Monica BayKeeper v. Browner, No. C 98-4825 SBA (on file with the LARWQCB and incorporated herein by reference). 181
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potential source of drinking water.4 See Basin Plan at 2-10. Thus, any proposal to discharge into the Los Angeles River must prove that compliance has been achieved for all Proposition 65 listed chemicals (see 22 C.C.R. § 12000) which include lead and other pollutants likely generated from the site. However, there has been no analysis as to whether the discharges to the Los Angeles River will comply with Proposition 65. g. Antidegradation requirements.

The Clean Water Act’s entire purpose is to improve water quality, not simply to allow degradation until a point where beneficial uses are not achieved. For this reason, the CWA specifically states that (1) “Existing instream water uses and the level of water quality necessary to protect the existing uses shall be maintained and protected,” and (2) “Where the quality of the waters exceed levels necessary to support propagation of fish, shellfish and wildlife and recreation in and on the water, that quality shall be maintained and protected unless the state finds that lower water quality is necessary to accommodate important economic or social development in the area in which the waters are located.” 40 CFR 131.12 . Notwithstanding this requirement, the MND contains no analysis whatsoever of whether the Project will violate these requirements. See 40 CFR 131.12.

An antidegradation analysis has been entirely ignored for the types of pollutants that are typical for urban runoff, which include heavy metals, pesticides, garden fertilizers, oil/grease, street litter and waste. Nor has such an analysis been conducted for all pollutants identified on the State’s 303(d) List of Impaired Waterways.

The MND contains no analysis of whether the pollution loading will change due to the Project (i.e., as a result of the change in land use). Certainly, increased traffic will bring increased cars and increased pollution from those cars. Pollutants from vehicles include many heavy metals such as lead, copper, etc. Moreover, additional pedestrian traffic will also result in trash and other debris that would not otherwise be present. Yet the MND contains no analysis on the water quality impacts associated with additional vehicle and pedestrian traffic. Nor does the MND contain an analysis of whether there will be any increase mass loading for any pollutants. If the Project does not include mass limits for pollutants based on the current “mean loading” – from the Project area itself – the permit will be in violation of the antidegradation policy. See SWRCB Order No. 90-

5. h. Impervious Surface Threshold.

The MND failed to consider or address the adverse effects of increased imperviousness on the stability of the Los Angeles River, its habitat quality, its water 4 The City may argue that the designation of the Los Angeles River as a potential drinking water source is inappropriate. However, the State of California Office of Administrative Law squarely rejected this argument. See OAL File No. 99-0602-01 (July 22, 1999). Thus, the designation remains. 182
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quality, or its aquatic ecosystems. Generally speaking, “it is extremely difficult to maintain predevelopment stream quality when watershed development exceeds 10 to 15% impervious cover.” 5 Thus, even relatively small increases in impervious area in a watershed can have major impacts on stream water quality and habitat quality.

Specifically, Schueler found that “a threshold for urban stream stability exists at about 10% imperviousness,” and “[w]atershed development beyond this threshold consistently resulted in unstable and eroding channels.”6In fact, Schueler cited similar studies that have demonstrated that a “sharp threshold in habitat quality exists at approximately 10- 15% imperviousness” and that beyond this threshold, habitat quality “is consistently classified as poor.”7 As far as water quality, Schueler noted that “[m]onitoring and modeling studies have consistently indicated that urban pollutant loads are directly related to watershed imperviousness.”8 Finally, Schueler reported that imperviousness is directly related to rising stream temperatures and loss of diversity in aquatic ecosystems.

The Project proposes to turn undeveloped land into 86% of completely impervious cover. (See Initial Study, p.II-1, specifying the Project’s lot coverage as follows: (1) Hardscape: 494,688 sq. ft (38%); (2) Building: 608,710 sq. ft (48%); and (3) Landscape: 181,912 sq. ft (14%)). This far exceeds the 10-15% threshold for impacts to the water quality of the Los Angeles River. Thus, it is clear that the Project will significantly impair the Los Angeles River, violating water quality standards and jeopardizing the ability to restore the Los Angeles River in the future. All of this points to the need for an analysis of the Project’s potential violations of water quality standards.

In sum, notwithstanding the applicability of the above listed water quality standards, no formal analysis of the water quality standards impact has been provided in the MND. There is no discussion as to whether the perceived levels of discharge exceed federal or state water quality standards. Instead, only conclusory statements are made to the effect that there is less than significant impact to violations of water quality standards.

This violates CEQA. See Topanga Assn. For a Scenic Community 11 Cal.3d 506, 515 (applied to the CEQA context in Laurel Heights Improvement Assn. v. Regents of the University of California (1988) 47 Cal.3d 376, 404 [“Laurel Heights I”]) (there must be a disclosure of “the analytic route the ... agency traveled from evidence to action”).

Contrary to the intent of the Legislature as interpreted in Topanga and Laurel Heights I, the City obscured its analytical route by failing to provide the analytical route taken to 5 See Schueler, T., “The Importance of Imperviousness,” Watershed Protection Techniques Vol. 1, No. 3 (Fall 1994).
6 Id.
7 Id. (citing to Shaver, E., et al., “Watershed Protection using an Integrated Approach” in Stormwater NPDES Related Monitoring Needs, Engineering Foundation, American Society of Civil Engineers (1994); Booth, D., “Urbanization and the Natural Drainage System Impacts, Solutions and Prognoses,” Northwest Environmental Journal (1991)).
8 Id.
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reach its conclusion of no significant violations of water quality standards. Because the MND is silent as to what analysis was performed to reach its conclusions that no violations of water quality standards will occur, the MND is insufficient.

2. The Project Fails to Adopt Best Management Practices to Achieve Water Quality Standards to the Maximum Extent Practicable.

Legal requirements require the Project to implement Best Management Practices (BMPs) to the “maximum extent practical” (see CWA § 402(p)) to achieve water quality standards. The MND’s general assurances that BMPs will be implemented and maintained is not adequate to insure that water quality standards are achieved to the maximum extent practicable.

Because the Los Angeles River is listed as impaired, and because it is now widely accepted that commercial developments such as the Project can have such significant adverse impacts on watersheds such as the Los Angeles River, FoLAR attempts to work with developers of Projects along the Los Angeles River to assist them in designing BMPs to meet water quality standards to the maximum extent practicable. Towards that end, FoLAR retained Dick Jenkins of Jenkins Environmental Associates, Michael Drennan of Montgomery Watson, Steven Barnhart and Daniel Gerken of Hunsaker and Associates, Phillip Pommier of Phillip Williams and Associates, and Verna Jigour to advise FoLAR of those BMPs which would achieve water quality standards to the maximum extent practicable.

Based on the advise of these consultants, FoLAR recommended to the Project proponent, Lennar Partners (“Lennar”), that certain structural and non-structural BMPs be incorporated into the Project in order to achieve water quality standards to the maximum extent practicable. The BMPs recommended to Lennar by FoLAR are set forth below.

Indeed, FoLAR and its technical consultants met several times with Lennar and its consultants to attempt to reach a mutually agreeable resolution regarding implementation of the BMPs recommended by FoLAR. However, FoLAR and Lennar were unable to reach agreement on the suggested BMPs.

In general, Lennar gave FoLAR two reasons for not implementing the BMPs recommended by FoLAR. Lennar first expressed concern that infiltration in certain areas of the site could impact groundwater by mobilizing existing VOC contamination in subsurface soil. The second reason given by Lennar was that infiltration could “water-in” the soil vapor extraction wells operated by Union Pacific Railroad Company on the adjacent property. As set forth in the June 20, 2000 letter from Dick Jenkins to Melanie Winter of FoLAR, Lennar’s concerns should not prevent the achievement of the BMPs suggested by FoLAR below. Specifically, the concerns should not prevent the level of 184
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infiltration of the Project site suggested by FoLAR. Rather than repeat his conclusions here, FoLAR refers you to Dick Jenkin’s June 20, 2000 letter attached hereto as Exhibit

1. FoLAR therefore continues to recommend that the following BMPs be adopted as mitigation measures for the Project:

1. The Project shall retain within Parcel D all low-flow surface water runoff and all stormwater produced by a “first flush” event. A “first flush” event shall be defined as the runoff produced by 3/4" of rainfall over a 24 hour period. Design of the retention system shall assume a dry period of 48 hours following a first flush event. It shall also consider the character of the soils, the possible pollutants being infiltrated, and its impact on the ground water resources. The Project shall also detain within Parcel D all on-site stormwater runoff above a “first flush” event such that stormwater runoff impacts due to development are mitigated. Any detained stormwater runoff shall be treated prior to leaving Parcel D, as set forth in Condition No. 2 below.

2. The Los Angeles River is listed as impaired by the U.S. Environmental Protection Agency and the Los Angeles Regional Water Quality Control Board (“Regional Board”). In order to ensure that surface water or stormwater runoff from Parcel D does not cause or contribute to exceedances of water quality standards for the Los Angeles River, all surface water or stormwater runoff shall be treated prior to leaving Parcel D. Specifically, “Priority Pollutants,” as defined below, in surface water and stormwater runoff leaving Parcel D shall be limited to the standards set forth in the National Toxics Rule (40 C.F.R. § 131.36), the Water Quality Control Plan for Ocean Waters of California (“Ocean Plan”) (State Board Resolution No. 97-026), and the California Toxics Rule, 65 Fed. Reg. 31682, 31683 (U.S. EPA, May 18, 2000) (“Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic Pollutants for the States of California”). The National Toxics Rule and the Ocean Plan are standards used by the Regional Board. See Regional Board Order No. 99- 060, p. 34. “Priority Pollutants” shall be defined as: 1) those pollutants set forth in 40 Code of Federal Regulations, part 423, appendix A; 2) any pollutants previously identified on the site; and 3) any pollutants likely to be discharged from the site based upon tenant usage.

3. The Developer shall use Best Management Practices (“BMPs”) to achieve the standards set forth in Condition Nos. 1 and 2. In order to comply with Condition Nos. 1 and 2, the Developer shall design, maintain and operate the Project pursuant to the following:
a. Dry sweeping of parking and driveway areas at least once a week. b. Storing of all “Priority Pollutants,” as defined in Condition No. 2 above, and waste products under cover and on a concrete surface, with secondary 185
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containment in the form of a berm or curb or as otherwise required by law.

The site shall also provide spill containment for trapping pollutants in the unlikely event of an accidental spill. These facilities shall be located to intercept a pollutant spilled anywhere on the site. The facility shall be lined such that pollutants may not infiltrate into the groundwater. An operations and maintenance manual shall be provided by the designer of the facility to the owner and tenants which sets forth practices necessary to meet these measures. The property owner and/or tenants shall demonstrate to FoLAR practices which are consistent with the requirements of this manual. The property owner and/or tenants shall also demonstrate to FoLAR that it meets the requirements of the Stormwater Pollution Prevention Plans (“SWPPPs”), required by the State Water Resources Control Board for controlling surface water and stormwater runoff from construction and industrial activities, as well as the requirements of the Standard Urban Storm Water Mitigation Plan (“SUSMP”), required by the Los Angeles Regional Water Quality Control Board to control surface water and stormwater pollution issues in development planning for the Project.
c. The Developer agrees to implement structural devices and design measures within Parcel D to prevent uncontrolled and untreated surface water and stormwater from leaving Parcel D, including, but not limited to, during the construction process. These structural devices and system designs shall be designed, implemented, and maintained in a manner so as to achieve the standards set forth in Condition Nos. 1 and 2. These structural devices and non-structural designs may include retention and detention measures such as properly designed grass swales, wet/dry ponds, or extended dry detention facilities, and filtration devices such as oil/grease and debris traps or separators and sand gravel filters. An operations and maintenance (O&M) manual for the water quality facility shall be included in the design. The Developer shall demonstrate that the facility is operated in a manner consistent with this document.
d. The Developer shall design parking areas, landscape areas and roof-top drainage to promote retention and detention of surface water and stormwater run-off in order to achieve the standards set forth in Condition Nos. 1 and 2.

Surface water run-off shall be directed to on-site landscape areas to maximize groundwater infiltration and on-site retention on Parcel D. Permeable paving shall be employed to the maximum extent feasible. At a minimum, permeable paving shall be installed on all parking stalls (aisle surfaces may be impervious as required to accommodate anticipated truck traffic loads) and pedestrian surfaces. Modular pavers (not mortared) over a coarse gravel base (underlain with geotextile fabric to reduce soil compaction needs and prevent migration of soil into gravel base) are recommended for at least the ground 186
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June 21, 2000

level parking stalls, whereas other permeable concrete alternatives may be used for pedestrian surfaces. All permeable paving shall be vacuum swept quarterly to prevent clogging and maintain porosity.
e. The Developer agrees to design, implement, and maintain best management practices to prevent uncontrolled and untreated surface water and stormwater from leaving Parcel D during the construction process. Design standards for erosion and sediment control during construction shall be based on the San Francisco Regional Water Quality Control Board’s “Erosion and Sediment Field Guide,” and on the "Manual of Standards for Erosion and Sediment Control Measures," Second Edition, May 1995 (or as currently amended) by the Association of Bay Area Governments (“ABAG Manual”). Techniques proposed for use shall be 'preferred control measures' based on "Table 19 Summary of Structural and Mechanical Control Measure Applications" found in Chapter 7 of the ABAG Manual. Such techniques will include, but are not limited to, Measure I (Temporary Runoff Control) and Measure O (Temporary Sediment Basin). Design of all temporary erosion control facilities shall include operations and maintenance requirements to ensure proper functioning of the facility. Construction documents shall contain specifications for construction sequencing covering initial installation and final removal of these structures.
f. The Developer agrees to monitor the quality of surface water and stormwater runoff leaving the site by: 1) sampling surface water runoff on a monthly basis (by grab sample), and 2) sampling the first flush of each storm event producing at least 0.1" of rain. 'First flush' sampling shall be flow-paced composite samples taken using automated equipment. Results of all water quality testing shall be forwarded to FoLAR and the Regional Board and presented in a manner that indicates trends over time. This sampling may be suspended for the current season after testing indicates consistent results showing that the Priority Pollutants meet the standards set forth in Condition No. 2. The Developer and the Regional Board shall coordinate the final testing protocols and parameters for all water quality testing prior to occupancy of this project. If sampling demonstrates the quality of surface water or stormwater discharge does not comply with Condition No. 2 above, then the Developer shall undertake remedial actions. Where remedial actions are required, the Developer's consultants shall perform remedial actions as required by the Regional Board (and others as required by law). The Developer shall review proposed remedial actions with the Regional Board (and others as required by law) for approval prior to implementation. If the results of the tests are inconclusive, then the Developer shall retest and/or undertake such actions as may be required to achieve the standards set forth in Condition No. 2 above. The Developer shall provide ongoing maintenance and, as necessary, upgrades to Items 3a-3f above to promote the long-term 187
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effectiveness of these methodologies and solutions.
g. The Project shall incorporate landscaping to screen the buildings from the west in the form of a minimum 20-foot landscape buffer. This minimum 20- foot landscape buffer shall: 1) extend along the westerly property line of Parcel D; 2) be vegetated exclusively with appropriate native plant associations, and specifications, to be provided, with the potential exception of exotic vines used to screen the parking structure; 3) incorporate techniques and landscape/building materials to effectively screen the buildings; and 4) be designed as a runoff filtration swale. Additionally, a 30-foot landscape strip along the northern property boundary shall also be designed as a runoff filtration swale. Native soil within these two filtration swales, as well as the detention basin, shall not be subjected to intentional compaction and shall be protected from incidental compaction caused by movement of vehicles and other heavy equipment during the construction process. Such protection may be afforded by exclusionary fencing and placing one of the following over any portion of these areas which may receive traffic: 1) 6 inches deep of wood chips; or 2) 4 inches deep of 3/4 inch crushed gravel. Geotextile fabric placed under the wood chips or gravel will facilitate cleanup after the construction traffic ceases. The Developer agrees to provide ongoing landscape maintenance that: 1) helps maintain a healthy soil ecosystem, and specifications, to be provided; and 2) utilizes ecologically compatible pesticides and herbicides. The Developer further agrees to exclude the use of the product Diazonon. For more detail on how landscaping should be incorporated into the Project site design to achieve water quality standards, please refer to Verna Jigour’s written recommendations, attached hereto as Exhibit No. 2.
h. The Project’s buildings shall utilize an earth tone color palette on river-facing surfaces to blend in with the natural elements along the Los Angeles River.

B. CONCLUSION
We urge the City to fully consider the impacts of the Lennar Project proposal on the water quality and quantity of the Los Angeles River by preparing a full EIR for the Project. By preparing an EIR, the City may properly evaluate appropriate measures to mitigate the water quality and quantity impacts associated with the Project to the maximum extent practicable.

Please do not hesitate to contact me should you have any questions or comments regarding the above. Thank you for your consideration.
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Sincerely,
Kimberly Lewand
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE BILL LOCKYER, Attorney General
of the State of California
RICHARD M. FRANK
Chief Assistant Attorney General

THEODORA BERGER,
Senior Assistant Attorney General,
BRIAN HEMBACHER, State Bar No. 90428
Deputy Attorney General
300 South Spring Street, Suite 500
Los Angeles, California 90013
Telephone: (213) 897-2638
Attorneys for Amicus Curiae,
People of the State of California

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES
FRIENDS OF LOS ANGELES RIVER, a not
for profit association, ANAHAUK SOCCER
CLUB, an unincorporated association,
COALITION FOR CLEAN AIR, a non-profit
corporation; and NATURAL RESOURCE

DEFENSE COUNCIL,
Petitioners,
v.

CITY OF LOS ANGELES, a municipal
corporation,
Respondents.
_____________________________________
LENNAR PARTNERS, a Florida corporation,
and UNION PACIFIC CORPORATION, a
Utah corporation; and DOES I-X,
Real Parties in Interest.
_____________________________________
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Case No. BS 067338

MEMORANDUM OF POINTS AND AUTHOR

CURIAE, PEOPLE OF THE STATE OF CALI

ATTORNEY GENERAL BILL LOCKYER, IN

FOR WRIT OF MANDATE
Date: July 20, 2001
Time: 9:30 a.m.

Department 86
Honorable David P. Yaffe

PRELIMINARY STATEMENT
The Attorney General, on behalf of amicus curiae People of the State of California, 192
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE submits this memorandum of points and authorities in support of Petitioners in their request that this court issue a peremptory writ of mandate ordering the City of Los Angeles (“City”) to vacate its approval of the Mitigated Negative Declaration (“MND”) for a 40 acre industrial and commercial project in Taylor Yards to be developed by Lennar Partners (“Lennar project”). The proposed project will include large industrial warehouses on a site near the Los Angeles River in the northeast area of Los Angeles.

The City has failed to comply with the California Environmental Quality Act (“CEQA”) (Pub. Resources Code, § 21000, et seq.) in approving the MND for the Lennar project. Because there is substantial evidence in the record that the proposed project may have significant adverse environmental impacts, the City should have prepared an Environmental Impact Report (“EIR”) before approving the project. (Pub. Resources Code, § 21151.) These potential impacts include:
(1) air pollution generated by hundreds of trucks emitting diesel exhaust each day (2) water quality impacts created by the impermeable surfaces of the project that will increase storm water runoff. Further, the conditions and mitigation set out in the MND do not reduce the environmental impacts from the project to a level of insignificance. Accordingly, the use of an MND as the basis for an approval of the project is not in compliance with CEQA. (Pub.

Resources Code, § 21064.5.)
In light of the significant potential impacts to the environment from the project, the failure to prepare an EIR violates CEQA and justifies the granting of Petitioner’s request for a Peremptory Writ of Mandate setting aside the City’s approval of the MND.

STATEMENT OF FACTS
The Lennar project calls for the development of a parcel in an area known as Taylor Yards. The project will be built in two phases. (AR 1:11.) The first phase involves the construction on 27 acres of 650,000 square feet of industrial space in buildings for use in manufacturing and warehousing. (AR 1:4, 6-7.) This part of the development will have 1317 parking spaces. (AR 1:11.) The second phase of the project will contain a retail/entertainment complex with 119,133 square feet of commercial space, including a 3900 seat theater and 1200 193
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE parking spaces. (AR 1:4, 35.) About 38% of the site will be “hardscaped”, 48% will have buildings on it and only 14% will be landscaped. (AR 1: 186.) The property in question is close to the Los Angeles River and immediately next to a parcel which has already been designated for the creation of a state park within the Los Angeles River Parkway.11/ (AR 1:36.) State officials
have indicated a strong interest in purchasing the Lennar property for the creation of a park. (AR 5:971.)
The industrial park portion of the project will result in over 4,000 new vehicle trips per day, the retail portion of the project will add more than 8,000 trips per day. (AR 1:164.) Hundreds of these trips will be by trucks using diesel as fuel. (AR 1:164, 200.) Diesel fuel has been shown to produce toxic and carcinogenic emissions. (AR 11-2168.) There are elementary schools and a middle school within one mile of the project that may be affected by the diesel emissions. (AR 5:959.) In addition, the plans for the project would create large impermeable surfaces for parking lots and warehouses that will increase the possibility of storm water runoff into the Los Angeles River. There are concerns about the impact from runoff to the adjacent area designated for a state park, in particular the sensitive wetlands that are planned for that park. (AR 11:2219-2220.)

ARGUMENT

THE FAILURE TO PREPARE AN ENVIRONMENTAL IMPACT REPORT BEFORE APPROVING THE PROJECT VIOLATES CEQA.

A. STANDARD OF REVIEW UNDER CEQA.

1. The Legislature has set aside $45 million to purchase land to create a state park at Taylor Yards as part of the proposed Los Angeles River Parkway. (AR 11:2222.) In enacting CEQA, the Legislature declared that the long-term protection of the environment should be the guiding principle in public decisions. (Pub. Resources Code, § 21001(d).) Compliance with CEQA requires that an opportunity for public participation be available in the decision-making process. (County of Inyo v. City of Los Angeles (1977) 71 194
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE Cal.App.3d 185, 192.) Accordingly, if it can be “fairly argued” that the project may have a significant impact, an EIR is required. (Friends of “B” Street v. City of Hayward (1980) 106 Cal.App.3d 988, 1001.) A MND is only appropriate where there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment. (Pub. Resources Code, § 21064.5.) The CEQA guidelines define "substantial evidence" as "enough relevant evidence and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached," Cal. Code Regs., tit. 14 § 15384(a); Laurel Heights Improvement Association v. Regents of the University of California (1988) 47 Cal.3d 376, 393.

CEQA Guidelines define a “significant effect on the environment” as “a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance.” (Cal. Code Regs., tit. 14 § 15382.) There is compelling evidence in the record of the likely severe impacts to air quality from diesel emissions from trucks using the planned industrial park and substantial, adverse changes to physical conditions such as water quality from runoff at the site. Since these impacts have not been adequately mitigated, a mandatory finding that the project may have a significant effect on the environment is required, thereby mandating the preparation of an EIR.

The requirement that an EIR be prepared instead of an MND is more than just bureaucratic paper-shuffling. The difference in the analysis between the two types of environmental review are essential to a full understanding of environmental impacts of a project.

The purpose of the EIR, inter alia, is to provide public agencies and the public in general with detailed information about the effect of the proposed project on the environment. (Pub.

Resources Code, § 21061.) In Laurel Heights Improvement Association v. Regents of the University of California, the California Supreme Court set forth the importance of accurately and fully divulging all available and relevant information in an EIR, stressing the necessity of full 195
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE disclosure in the CEQA process:
"The EIR is therefore the heart of CEQA. An EIR is an environmental `alarm bell' whose purpose is to alert the public and its responsible officials to environmental changes before they have reached ecological points of no return.

The EIR is also intended to demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action. Because the EIR must be certified or rejected by public officials, it is a document of accountability. If CEQA is scrupulously followed, the public will know the basis on which its responsible officials either approve or reject environmentally significant action, and the public, being duly informed, can respond accordingly to action with which it disagrees. The EIR process protects not only the environment but also informed self government." (Laurel Heights at 392.)
Here, the preparation of an MND in lieu of an EIR deprived the decisionmakers of the essential analysis that would have fully informed the policymakers of the significant environmental impacts of this project.

B. THERE WILL BE SIGNIFICANT IMPACTS TO AIR QUALITY FROM THE

PROJECT THAT MANDATE THE PREPARATION OF AN EIR THAT HAVE NOT BEEN ANALYZED NOR MITIGATED.
1) The Air Impacts From the Project Have Not Been Properly Analyzed.

If a industrial park’s size is greater than 276,000 square feet, as the Lennar project is, it is per se considered to have potentially significant air quality impacts. (CEQA Air Quality Handbook of the South Coast Air Quality Management District, cited at AR 1:192.) The industrial park portion of proposed project alone is expected to result in at least 4,072 new vehicular trips per day. Even using the MND projection (which has been hotly disputed by the 196
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE petitioners as being far too low, see AR 5:92012/), 6% of this daily total will be diesel burning trucks. (AR 3:627, 5:920.) This means that a total of at least 240 trucks will be using the project site on a daily basis. Despite these hundreds of vehicular trips that will involve vehicles using diesel fuel, there is no analysis of the local toxic effects of these emissions, it is not even described as an impact of the operation of the facility.

Diesel particulate exhaust is a listed toxic air contaminant in California. (Cal. Code Regs., tit.17, § 93000.) Diesel engine exhaust is also on the list of chemicals know to the State of California to cause cancer. (Cal. Code Regs., tit. 22, § 12000.) Yet the MND’s analysis ignores this exposure to emissions that will impact the local area. In so doing, the MND completely fails to meet CEQA’s public disclosure purpose when it omits the impacts from exposure to this toxic air contaminant. The failure to adequately analyze the impacts from diesel emissions is particularly troubling in light of the fact that there are elementary and secondary schools close by the project site. (AR 5:959.) Because of the substantial evidence in the record of significant impact to public health in the local area from the diesel emissions that will necessarily result from the operations planned for the site, an EIR is mandated. (Cal. Code Regs., tit. 14, § 15065(d).)
The MND is also inadequate in its analysis on the impacts on air quality in that, its assessment of the impacts of emissions from operation of the project on the local area solely looks at one type of emission, carbon monoxide (“CO”), and only at one point, the intersection of San Fernando Road and Division Street (AR 1:201-202.) Using modeling for CO at that point the Initial Study states that there would be no significant local impact to air quality, without considering any other type of emission or considering any other location near the project for its

2. The MND concludes that even though there will be 650,000 square feet of industrial park space created by the project, only 5% of the vehicles visiting the site will be heavy duty trucks and 1% light heavy duty trucks. (AR 1:200.) It defies common sense that hundreds of thousands of square feet of industrial space will be built and yet only 6% of the traffic bringing in component materials and taking away finished products will be trucks. . 197
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE study of localized impacts. This is not an adequate, quantitative analysis of all of the localized air impacts. (See, report by Air Quality Dynamics, AR 11:2181-2188.) This conclusory, superficial analysis of possible localized air quality impacts caused by the operation of the site does not meet the requirements of CEQA.

One matter that the Air Quality Analysis (Appendix A to the Initial Study, AR 1:185-208) does get right is that the mitigation measures applied at the project will not insure sufficient reduction of project emissions from operation. (AR 1:207.) However, the remedy it proposes to address this problem, the purchase of emission reduction credits, is unavailable and inappropriate, as will be discussed below.
2) The Mitigation for Air Quality Impacts Set Out in the MND Are Infeasible and Inadequate.

Other than stating the car pooling of future tenants of the project will be strongly encourage, the MND completely relies on the purchase of emission reduction credits to offset the significant adverse impacts caused by the operation of the project (AR 1:207.) The MND indicates that the project will purchase Regional Clean Air Incentives Market (“RECLAIM”) credits or emission reduction credits (“ERC”) to mitigate for impacts from all pollutants above threshold levels. (AR (AR 3:484.) Yet the South Coast Air Quality Management District (“SCAQMD”), which has jurisdiction in this area, has stated that RECLAIM credits are not available to offset mobile source emissions. (AR 11:2159.) Further, the SCAQMD informed the City that the ERC credits are very in demand and therefore it is uncertain if they will be available in the future when needed. (AR 5:1009.) There are currently not enough pollution credits to go around and this has caused a pollution credit shortage, as many more firms need to purchase credits than there are credits for sale. (Polakovic, Innovative Smog Plan Makes Little Progress, The Los Angeles Times, (April 17, 2001) p. 1, Metro Section.) In addition, the credits have become extremely expensive even if they are available. (Id.) Further, the MND does not discuss how the requirement to purchase credits in the future will be enforced once the applicant is no 198
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE longer involved with the project.

In addition, it is the opinion of the SCAQMD the use of the credits is inappropriate because they do nothing to benefit the local population which is suffering from these impacts. (AR 5:1009.) They may benefit the Los Angeles basin generally, but the use of these credits does nothing to help the people living around the project site. Courts have ruled that agencies cannot rely on mitigation measures of unknown efficacy to conclude that impacts have been reduced to a level of insignificance. (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 727-728.) The uncertainty of the ability to use the ERC credits as mitigation, along with the inappropriate use of the RECLAIM credits that benefit the basin to mitigate local impacts, does not meet the rigorous requirements of CEQA for mitigation of significant adverse impacts to air quality.

C. WATER QUALITY IMPACTS FROM THE PROJECT REQUIRE THE
PREPARATION OF AN EIR.

The Initial Study for the Project admits that control of runoff from the site is important because the site drains to the adjacent Los Angeles River and ultimately, to the Pacific Ocean.

Hundreds of trucks will use the facility on a daily basis and will generate oil drippings that could result in contaminated runoff. The retail and industrial aspects of the project may generate material that may be carried through storm drains to the Los Angeles River, adding to the already degraded nature of that watercourse. While the mitigation provided as a condition of the approval of the project provides for some filtering of deleterious materials through the use of swales, detention basins and sand filters, there has been no showing that these measures will in fact reduce to a level of insignificance the environmental impacts of harmful materials that may be carried into the Los Angeles River from the drainage system at the site. (AR 1:23.) There have been unanswered concerns raised that the above-described system as it is not designed to address runoff from a storm event that exceeds 3/4 of an inch. (AR 3:510, 7:1204, 11:2219.) Although requested, there is no requirement for monitoring of runoff so as to determine if there 199
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE have been contaminated releases of storm water from the project site. (AR 3:515.) As mitigation for the impacts of contaminated runoff, the MND requires the project applicant to develop a state Stormwater Water Pollution Prevention Plan and to comply with a National Pollutant Discharge Elimination System permit. (AR 1:141.) However, because this compliance is in the future, the decisionmakers are not able to evaluate whether or not the measures taken to comply with those permitting processes will reduce the impacts to a level of insignificance. CEQA requires more than reliance on another agency’s regulatory scheme as mitigation. (Sundstrom v. County of Mendocino (1988) 202 Cal. App.3d 296, 309, held county improperly relied on future approval by another agency as mitigation of significant impacts, thus deferring environmental assessment and evading its duty to engage in a comprehensive environmental review.) CEQA does not allow an agency to defer analysis of impacts and mitigation measures to another agency which may subsequently approve an aspect of the project. (Cal. Code Regs., tit.14, § 15126.4(a)(1)(B); Sundstrom v. County of Mendocino, supra, 202 Cal.

App.3d at 309.) The reason for not allowing the deferral of mitigation measures is obvious. By allowing the project to begin without an identification of the necessary mitigation, the ability to implement those items of mitigation is lessened and some forms of mitigation might be foreclosed. If the mitigation is not described in the necessary detail at the time the lead agency acts on the approval of the MND, there is no mechanism by which it can judge if the impacts of the project have been reduced to a level of insignificance.

Here, the MND may not rely on the later approval process of the Regional Water Board or other agencies with jurisdiction over water quality issues; it must spell out the mitigation for the foreseeable significant impacts of the project. There should be specific measures that will be implemented, rather than suggested regulation that may or may not be imposed in the future by another entity. Further, because the mitigation measures for impacts to air quality are not described, there is no substantial evidence that the adverse impacts of diesel exhaust emissions will be mitigated in any manner, let alone to a level of insignificance. It is CEQA’s mandate to 200
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MEMORANDUM OF P & A’S OF AMICUS CURIAE IN SUPPORT OF PETITION FOR WRIT OF MANDATE discuss all foreseeable impacts, and to propose mitigation to address those impacts. (Stanislaus Natural Heritage Project v. County of Stanislaus (1996) 48 Cal.App.4th 182, 205-206.) There can be no substantial evidence in the record to support the City’s findings that impacts have been mitigated to a level of insignificance when the mitigation is unknown and left for the future. The City should be required to fully and adequately analyze the impacts of storm water runoff from this site both during construction and during occupancy.

CONCLUSION
Because there is substantial evidence that the project may cause significant environmental impacts which have not been mitigated to a level of insignificance, an EIR must be prepared for the project. Accordingly, amicus curiae respectfully requests that the Court grant Petitioner’s Peremptory Writ of Mandate and that the approval of the MND and the project by the City be set aside .

Dated:

Respectfully submitted,
BILL LOCKYER, Attorney General
of the State of California
RICHARD M. FRANK
Chief Assistant Attorney General

THEODORA BERGER
Senior Assistant Attorney General

BRIAN HEMBACHER
Deputy Attorney General
By: ____________________________________

BRIAN HEMBACHER
Deputy Attorney General
Attorneys for Amicus Curiae,
People of the State of California,
Ex rel. Attorney General Bill Lockyer
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EXHIBIT L
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element
City of Long Beach General Plan
creating vibrant and exciting places

LAND USE
DECEMBER 2019
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Intentionally Blank
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136 Land Use Element | City of Long Beach
Implementation
5 No. Implementation Strategies
Time Frames
ShorttermMidtermLongterm Ongoing
LU- M-83
Consult with the US Navy NWS Seal Beach Community Planning Liaison Officer (CPLO) to help identify any critical issues to be considered or addressed in the planning process, define the “military influence area” (MIA), and ensure that the MIA addresses the health and welfare of the public, as well as the military mission. Ensure compliance with SB 1468, to ensure consideration of military readiness in the planning process, compliance with CA 1462 to ensure proper notification to the military..

Responsible Department: Development Services
Supporting Departments: Public Works, Government Affairs Related Policies: LU Policy 8-3
•
Increased and Diversified Open Space
LU- M-84
Increase parks and open space areas to meet the City standard of eight acres of park land for every 1,000 Long Beach residents, particularly in neighborhoods where there is a deficiency in park space.

Responsible Department: Development Services
Supporting Department: Parks, Recreation and Marine
Related Policies: LU Policy 19-1, 19-2, 20-1, 20-6, 20-7 •
LU- M-85
Continue to implement and update the Department of Parks, Recreation and Marine Strategic Plan and the Open Space and Recreation Element.

Responsible Departments: Development Services and Parks, Recreation and Marine Related Policies: LU Policy 19-1, 19-3, 20-2
•
LU- M-86
Update and implement the Long Beach Riverlink Plan to create a continuous greenway of pedestrian and bike paths and linkages along the east bank of the Los Angeles River, as well as to connect to existing and future parks, open space and beaches along western portions of the City.

Responsible Department: Parks, Recreation and Marine
Supporting Departments: Public Works, Development Services Related Policies: LU Policy 19-1, 19-2, 19-3, 20-1, 20-2, 20-3, 20-4, 21-1 •
LU- M-87
Pilot streetlet demonstration projects along Long Beach Boulevard to test the effectiveness and design for permanent streetlet projects. Pilots will range from one day to a yearlong demonstration.

Responsible Department: Development Services
Supporting Department: Public Works
Related Policies: LU Policy 18-7, 18-9, 19-1, 19-2, 19-3 •
LU- M-88
Increase the diversity of urban recreational spaces to include pocket parks, infill parks, community gardens, small green spaces, rooftop gardens, urban agriculture and gardening spaces, paseos, linear parks, small play fields and courts, playgrounds, urban trails and similar urban open spaces.

Responsible Department: Development Services
Supporting Department: Parks, Recreation and Marine
Related Policies: LU Policy 19-2
•
LU- M-89
Focus on locating new parks and open spaces in residual and innovative areas such as remnant freeway rights-of-way, abandoned railway lines, utility corridors, riverfronts and waterfronts, vacant lots, underutilized or irregular parcels and rooftops.

Responsible Department: Development Services
Supporting Department: Parks, Recreation and Marine
Related Policies: LU Policy 18-9, 19-1, 19-2, 20-1
•
LU- M-90
Create joint-use park facilities and work with Long Beach Unified School District to enhance school sites for public use.

Responsible Department: Parks, Recreation and Marine
Related Policies: LU Policy 18-6, 19-1, 19-2
•
December 2019
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EXHIBIT M
207
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director South Coast Region
3883 Ruffin Road
San Diego, CA 92123
(858) 467-4201
www.wildlife.ca.gov
November 17, 2020
Amy L. Harbin
City of Long Beach
411 W. Ocean Beach Blvd. 3rd Floor
Long Beach, CA 90802
[email protected]
Subject: Pacific Place Project, Mitigated Negative Declaration (MND), Los Angeles County, SCH #2020100290
Dear Ms. Harbin:

The California Department of Fish and Wildlife (CDFW) has reviewed the Pacific Place Project (Project) and the MND’s supporting documentation, including a Biological Resources Assessment for the Industrial-Self Storage/RV Parking at 3701 Pacific Place, Long Beach, California (BRA) dated April 8, 2020; Results of a Biological Constraints Analysis for 3701 Pacific Place Project in the City of Long Beach, Los Angeles County, California (BCA) dated April 23, 2020; Focused Special-Status Plant Species Surveys for the Industrial - Self Storage/RV Parking at 3701 Pacific Place, Long Beach, California (PSS) dated August 21, 2020; and Crotch Bumble Bee Visual Survey for the Industrial -Self Storage/RV Parking at 3701 Pacific Place, Long Beach, California (CBB) dated September 11, 2020. Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife. Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW’s Role
CDFW is California’s Trustee Agency for fish and wildlife resources, and holds those resources in trust by statute for all the people of the State [Fish & G. Code, §§ 711.7, subdivision (a) & 1802; Public Resources Code, § 21070; California Environmental Quality Act (CEQA) Guidelines, § 15386, subdivision (a)]. CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (Id., § 1802). Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect state fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA (Public Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code, including lake and streambed alteration regulatory authority (Fish & G. Code, § 1600 et seq.). Likewise, to the extent implementation of the Project as proposed may result in “take”, as defined by state law, of any DocuSign Envelope ID: 4DFBE940-8371-46D8-A695-AA924B7F3178 208
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City of Long Beach

November 17, 2020
species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), or state-listed rare plant pursuant to the Native Plant Protection Act (NPPA; Fish & G. Code, §1900 et seq.) authorization as provided by the applicable Fish and Game Code will be required.

Project Description and Summary
Objective: The proposed Project is comprised of a three-story 152,745-square foot (sf) selfstorage building with 1,132 self-storage units, a 2,153 sf car wash, a recreational vehicle (RV) parking facility with 578 parking spaces, and a 5,000 sf office space on four parcels totaling approximately 14-acres. Anticipated industrial uses on site include a single-story building with up to 77,000 square-feet of building area consisting of 73,500 square-feet warehouse space and 3,500 square-feet of office space. In addition, a proposed vacated roadway easement is located adjacent to the self-storage, car wash, and RV parking facility on four parcels totaling approximately 5.5. acres in the City of Long Beach, Los Angeles County, California. The Project area totals approximately 19.41 acres.

Approximately 1,500 square feet (sq ft) of vegetation, including potential southern tarplant habitat, was removed from the Project site prior to completing appropriate biological surveys.

Location: The Project site is located north of Interstate 405, east of Interstate 710 and the Los Angeles River, and west of the Los Angeles Metropolitan Transportation Authority A Line light rail tracks and Los Cerritos Park.

Comments and Recommendations
CDFW offers the comments and recommendations below to assist the City of Long Beach (City) in adequately identifying, avoiding, and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources. CDFW recommends the measures or revisions below be included in a science-based monitoring program that contains adaptive management strategies as part of the Project’s CEQA mitigation, monitoring and reporting program (Public Resources Code, § 21081.6 and CEQA Guidelines, § 15097).

Comment #1: Vegetation Removal Activities
Issue: The PSS states, “On August 12, 2020, it was observed that an on-site area having vegetation that had not been surveyed on August 7 had been cleared.” Specific impacts: Approximately 1,500 sq ft of potential special status vegetation habitat was removed, as shown in Figure 2 in the PSS.

Why impact would occur: Because vegetation removal activities took place before adequate surveys were conducted, there is no longer an opportunity to determine if there were special status species were located in that area.

Evidence impact would be significant: CDFW is unable to analyze or comment on any special status species vegetation that may have been located in the area that was removed. In addition, the presence of southern tarplant on site, a species often found in areas with vernal DocuSign Envelope ID: 4DFBE940-8371-46D8-A695-AA924B7F3178 209
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City of Long Beach

November 17, 2020
pools (B.G. Baldwin, 2012), is an indicator that there may be other species that thrive in these habitats, such as the prostrate vernal pool navarretia and Coulter’s goldfields. Therefore, there is potential that these and other species may be on site.

Recommended Potentially Feasible Mitigation Measure(s):

Mitigation Measure: CDFW recommends mitigating at a ratio of no less than 5:1 for the loss of 1,500 sq ft of habitat that may have supported special status plant species. These species include Coulter’s saltbush, Parish’s brittlescale, lucky morning-glory, decumbent goldenbush, Coulter’s goldfields, prostrate vernal pool navarretia, and San Bernardino aster. The ratio should be for the total acreage of removed vegetation. All revegetation/restoration areas that will serve as mitigation should include preparation of a restoration plan, to be approved by USFWS and CDFW prior to any ground disturbance. The restoration plan should include restoration and monitoring methods; annual success criteria; contingency actions should success criteria not be met; long-term management and maintenance goals; and, a funding mechanism to assure for in perpetuity management and reporting. Areas proposed as mitigation should have a recorded conservation easement and be dedicated to an entity which has been approved to hold/manage lands (AB 1094; Government Code, §§ 65965-65968).

Recommendation: The vegetated area that was removed before adequate surveys were conducted should be identified as a significant impact.

Comment #2: Impacts to Candidate Endangered Species – Crotch’s Bumble Bee Issue: The CBB states, “The survey consisted of two visits, 5 days apart, on August 12 and 17, 2020”. CDFW is concerned that surveys were conducted at the very end of the Crotch’s bumble bee active period. This may reduce the ability of detection.

Specific Impact: Project ground disturbing activities such as grading and grubbing may result in crushing or filling of active bee colonies, causing the death or injury of adults, eggs, and larvae. The Project may remove bee habitat by eliminating vegetation that may support essential foraging habitat. The timing of the survey conducted also may decrease detection of bee colonies that may be on site.

Why Impact would occur: Impacts to Crotch’s bumble bee could result from ground disturbing activities. Project disturbance activities could result in mortality or injury to hibernating bees, as well as temporary or long-term loss of suitable foraging habitats. Construction during the breeding season of bees could result in the incidental loss of breeding success or otherwise lead to nest abandonment. In addition, survey efforts that take place outside of flying season when bees are most likely to be detected may lead to false negative results. This may also lead to insufficient mitigation measures to protect bees or colonies that may be found on site.

Evidence Impact would be significant: On June 12, 2019, the California Fish and Game Commission accepted a petition to list the crotch bumble bee as endangered under the California Endangered Species Act (“CESA”), determining the listing “may be warranted” and advancing the species to the candidacy stage of the CESA listing process. The Project's potential to substantially reduce and adversely modify habitat for Crotch’s bumble bee, reduce and potentially seriously impair the viability of populations of Crotch’s bumble bee, and reduce the number and range of the species while taking into account the likelihood that special status DocuSign Envelope ID: 4DFBE940-8371-46D8-A695-AA924B7F3178 210
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City of Long Beach

November 17, 2020
species on adjacent and nearby natural lands rely upon the habitat that occurs on the proposed Project site.

Recommended Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: Due to potentially suitable habitat within the Project site, within one year prior to vegetation removal and/or grading, a qualified entomologist familiar with the species behavior and life history should conduct surveys to determine the presence/absence of Crotch’s bumble bee and their colony. Surveys should be conducted during flying season when the species is most likely to be detected above ground, between March 1 to September 1 (Thorp et al. 1983). Survey results including negative findings should be submitted to CDFW one week prior to initiation of Project activities. If “take” or adverse impacts to Crotch’s bumble bee cannot be avoided either during Project activities or over the life of the Project, the City must consult CDFW to determine if a CESA incidental take permit is required (pursuant to Fish & Game Code, § 2080 et seq.).

Mitigation Measure #2: Because an individual bee has been observed, there is potential for more to be on site. If an individual is observed during Project activities, work should not occur until the animal has left the work area of its own volition. If a nest is observed, no Project activities should occur until a plan to protect Crotch bumblebee, including over-wintering queens, has been approved in writing by CDFW. The City should develop appropriate avoidance, minimization, and mitigation measures to decrease Project impacts to less than significant. If avoidance is not feasible, compensatory mitigation may be necessary to offset impacts to habitat and colony size.

Comment #3: Impacts to Bat Species, including California Species of Special Concern Issue: The Project includes activities that will result in the removal of trees and vegetation that may provide foraging and roosting habitat for bats. In addition, the BRA identifies the Yuma myotis (Myotis yumanensis), Mexican free-tailed bat (Tadarida brasiliensis), and western yellow bat (Lasiurus xanthinus) a designated California Species of Special Concern, as potentially present on site. CDFW is concerned that there is no mitigation for potential loss of occupied foraging and/or roosting habitat on site.

Specific impacts: Project activities include the removal of trees, vegetation, and/or structures that may provide foraging habitat and therefore has the potential for the direct loss of bats.

Why impacts would occur: The removal of vegetation and trees will potentially result in the loss of foraging and roosting habitat for bats. Construction activities will temporarily increase the disturbance levels as well as human activity in the Project area. Disturbances related to bat habitat may have impacts to not only their roosts but their source of food. For example, “Encroachment of urban development and agriculture into areas of native vegetation likely alters the composition and abundance of insect prey in an area and may affect the ability of Townsend’s big-eared bat to find adequate prey.” (Gruver, J.C., 2006). Development activities may impact any bat species that could be within the Projet boundary or its vicinity.

Evidence impacts would be significant: Bats are considered non-game mammals and are afforded protection by state law from take and/or harassment, (Fish & G. Code, § 4150; Cal.

Code of Regs, § 251.1). There are many bat species that can be found year-round in urban DocuSign Envelope ID: 4DFBE940-8371-46D8-A695-AA924B7F3178 211
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City of Long Beach

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areas throughout the south coast region of California (Miner & Stokes, 2005). Several bat species are considered California Species of Special Concern and meet the CEQA definition of rare, threatened or endangered species (CEQA Guidelines, § 15065). Take of California Species of Special Concern could require a mandatory finding of significance by the City (CEQA Guidelines, § 15065).

Recommended Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: Prior to construction activities, CDFW recommends bat surveys be conducted by a qualified bat specialist to determine baseline conditions within the Project area and within a 500-foot buffer. This will aid in determining not only impacts of species on site but also any species that may be in the surrounding Project vicinity. CDFW recommends the use of acoustic recognition technology to maximize detection of bat species to minimize impacts to sensitive bat species. The City should document the presence of any bats and include species specific mitigation measures, such as avoiding roosting season for that species, to reduce impacts to below a level of significance.

Mitigation Measure #2: To the extent feasible, tree removal or relocation should be scheduled between October 1 and February 28, outside of the maternity roosting season. Maternity season lasts from March 1 to September 30. Trees and/or structures determined to be maternity roosts should be left in place until the end of the maternity season.

Mitigation Measure #3: If trees and/or structures must be removed during the maternity season (March 1 to September 30), a qualified bat specialist should conduct a pre-construction survey to identify those trees and/or structures proposed for disturbance that could provide hibernacula or nursery colony roosting habitat for bats. Each tree and/or structure identified as potentially supporting an active maternity roost should be closely inspected by the bat specialist no greater than 7 days prior to tree disturbance to more precisely determine the presence or absence of roosting bats.

Mitigation Measure #4: If bats are not detected, but the bat specialist determines that roosting bats may be present at any time of year, it is preferable to push any tree down using heavy machinery rather than felling it with a chainsaw. In order to ensure the optimum warning for any roosting bats that may still be present, the tree should be pushed lightly two to three times, with a pause of approximately 30 seconds between each nudge to allow bats to become active. The tree should then be pushed to the ground slowly and should remain in place until it is inspected by a bat specialist. Trees that are known to be bat roosts should not be sawn up or mulched immediately. A period of at least 24 hours, and preferably 48 hours, should elapse prior to such operations to allow bats to escape. Bats should be allowed to escape prior to demolition of buildings. This may be accomplished by placing one-way exclusionary devices into areas where bats are entering a building that allow bats to exit but not enter the building.

The bat specialist should document all demolition monitoring activities and prepare a summary report to the City upon completion of tree disturbance and/or building demolition activities.

It should be noted that the temporary halt of Project activities to allow bats to escape during nesting season does not constitute effective mitigation for the purposes of offsetting Project impacts associated with habitat loss. Additional mitigation would be necessary to compensate for the removal of roosting habitat within the Project site based on acreage of impact and DocuSign Envelope ID: 4DFBE940-8371-46D8-A695-AA924B7F3178 212
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City of Long Beach

November 17, 2020
vegetation composition. CDFW should be consulted to determine proper mitigation for impacts to occupied habitat depending on the status of the bat species. Mitigation ratios would increase with the occurrence of a California Species of Special Concern.

Comment #4: Impacts to Burrowing Owl (Athene cunicularia) Issue #1: The BRA indicates that burrowing owl (Athene cunicularia), a Species of Special Concern, has the potential to be found on the Project site. In addition, Table C-2 in the BRA indicates that the California ground squirrel (Citellus beecheyi) was detected on site. These observations may indicate that these species have the potential to burrow on the Project site and, therefore, provide nesting habitat for burrowing owls.

Issue #2: The BRA indicates that one general field survey was conducted on December 6, 2019. CDFW is concerned over the lack of multiple and focused surveys for burrowing owl.

Specific impact: Identification of potential for burrowing owls during non-winter months, including the nesting season, may be missed, especially with only one site visit. Therefore, the Project may result in direct and indirect burrowing owl mortality or injury; the disruption of natural burrowing owl breeding behavior; and loss of breeding, wintering and foraging habitat for the species. Project impacts would contribute to statewide population declines for burrowing owl.

Why impact would occur: Burrowing owls have been known to use highly degraded and marginal habitat where existing burrows or stem pipes are available. Nest and roost burrows of the burrowing owl are most commonly dug by ground squirrels as “starts” (Gervais, J.A., Rosenberg, D.K., & Comrack, L.A., 2008). Ground squirrel presence on site may indicate potential for burrowing owl habitat. Impacts to burrowing owl could result from vegetation clearing and other ground disturbing activities. Project disturbance activities may result in crushing or filling of active owl burrows, causing the death or injury of adults, eggs, and young.

The Project will remove burrowing owl foraging habitat by eliminating native vegetation that supports essential rodent, insect, and reptile that are prey for burrowing owl. Rodent control activities could result in direct and secondary poisoning of burrowing owl ingesting treated rodents.

Evidence impact would be significant: Take of individual burrowing owls and their nests is defined by Fish and Game Code section 86 and prohibited by sections 3503, 3503.5, and 3513.

Take is defined in Fish and Game Code section 86 as “hunt, pursue, catch, capture or kill, or attempt to hunt, pursue, catch, capture or kill.” Without appropriate take avoidance surveys prior to Project operations including, but not limited to, ground and vegetation disturbing activities and rodent control activities, adverse impacts to burrowing owl may occur. In addition, burrowing owl qualifies for enhanced consideration afforded to species under CEQA, which can be shown to meet the criteria for listing as endangered, rare or threatened (CEQA Guidelines, § 15380(d)).

Insufficient survey efforts for burrowing owl may conclude false negative results, which would not require avoidance and mitigation measure implementation. Inadequate avoidance and mitigation measures will result in the Project continuing to have a substantial adverse direct and cumulative effect, either directly or through habitat modifications, on any species identified as a DocuSign Envelope ID: 4DFBE940-8371-46D8-A695-AA924B7F3178 213
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City of Long Beach

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candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or United States Fish and Wildlife Service (USFWS).

Recommended Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: To reduce impacts to burrowing owl to less than significant, CDFW recommends that the Project adhere to CDFW’s March 7, 2012, Staff Report on Burrowing Owl Mitigation (CDFW 2012). All survey efforts should be conducted prior to any Project activities that could result in habitat disturbance to soil, vegetation or other sheltering habitat for burrowing owl. In California, the burrowing owl breeding season extends from February 1 to August 31 with some variances by geographic location and climatic conditions. Survey protocol for breeding season owl surveys states to conduct 4 survey visits: 1) at least one site visit between February 15 and April 15, and 2) a minimum of three survey visits, at least three weeks apart, between April 15 and July 15, with at least one visit after June 15.

Mitigation Measure #2: Permanent impacts to occupied owl burrows and adjacent foraging habitat should be offset by setting aside replacement habitat to be protected in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity, which should include an appropriate non-wasting endowment to provide for the long-term management of mitigation lands. CDFW recommends that the City require a burrowing owl mitigation plan be submitted to CDFW for review and comment prior to Project implementation.

Mitigation Measure #3: For proposed preservation and/or restoration, the final environmental document should include measures to protect the targeted habitat values in perpetuity from direct and indirect negative impacts. The objective should be to offset the Project-induced qualitative and quantitative losses of wildlife habitat values. Issues that should be addressed include, but are not limited to, restrictions on access, proposed land dedications, monitoring and management programs, control of illegal dumping, water pollution, and increased human intrusion. An appropriate non-wasting endowment should be provided for the long-term monitoring and management of mitigation lands. CDFW recommends that mitigation occur at a state-approved bank or via an entity that has been approved to hold and manage mitigation lands pursuant to Assembly Bill 1094 (2012), which amended Government Code sections 65965-65968. Under Government Code section 65967(c), the lead agency must exercise due diligence in reviewing the qualifications of a governmental entity, special district, or nonprofit organization to effectively manage and steward land, water, or natural resources on mitigation lands it approves.

Mitigation Measure #4: Project use of rodenticides that could result in direct or secondary poisoning to burrowing owl should be avoided.

Comment #5: Mitigation for southern tarplant (Centromadia parryi ssp. australis) Issue: BIO-1 of the MND may not provide sufficient mitigation to offset impacts to southern tarplant below a significant level.

Specific impacts: Project grading and fuel modification associated with the construction development would impact approximately 830 southern tarplants. BIO-1 of the MND states an option for tarplant mitigation “will translocate those southern tarplant individuals to be impacted to a suitable location, which will be determined by the Developer in collaboration with the Project DocuSign Envelope ID: 4DFBE940-8371-46D8-A695-AA924B7F3178 214
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Biologist.” Translocation is not adequate to mitigate for impacts to southern tarplant. Therefore, the Project may result in population declines or local extirpation of the species.

Why impacts would occur: Creation or restoration using the transplanting of plant species should be considered experimental in nature. It should not be viewed as a primary mitigation strategy to mitigate below a significant level under CEQA. CDFW, in general, does not recommend transplantation of rare plants as a mitigation/minimization measure because successful implementation of translocation is rare with minimal documented success.

In addition, the MND states, “Section 21.42. Southern tarplants (Centromadia parryi ssp. australis) proposed for removal from the development area would be relocated to the proposed landscaped area in the north end of the Artesia parcels.” Southern tarplants require sandy, disturbed soils, and will not have a high success rate of survival in a landscaped area.

Evidence impacts would be significant: Transplantation projects have a poor success rate and often demonstrate a downward trend of survival over time (GodeFroid, S., et al., 2010).

CDFW defines success as long-term, self-sustaining population with a positive overall population trend, demonstrated fertile seed set, and demonstrated recruitment. Even if transplantation is initially successful, they typically fail to persist over time. Studies show success of transplantation projects within the 10 to 15 percent range, with an optimistic outcome of 50 percent survival maintained over 5 years (or thereafter, 50% survival maintained for 1 year).

These impacts would continue to be significant because BIO-1 will not result in adequate avoidance, minimization, or mitigation for the unavoidable direct, indirect, and temporal loss of a special status species. This is including the uncertainties and often failures of creation or restoration practices for special status plants using transplanting of species. Absent adequate mitigation, the ecosystem function and contribution to genetic biological diversity of southern tarplant and other special status plants in conjunction with their contribution to breeding, feeding and cover habitat for wildlife will be compromised.

Recommended Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: CDFW recommends, the preservation of areas where southern tarplant is located on site. If on-site mitigation is not feasible or would not be biologically viable, off-site mitigation through occupied habitat acquisition and preservation in perpetuity may be appropriate. Due to the suitable habitat found on site, the estimated 830 individuals found, and the estimated 1,500 sq ft of suitable habitat already removed, CDFW recommends mitigating at a ratio no less than 10:1 for this rare 1B.1 ranked. This ratio should be used for the habitat acreage as well as the individual plants that are found on site.

Mitigation Measure #2: CDFW recommends that all open space preservation/mitigation land be protected in perpetuity with minimal human intrusion by recording and executing a perpetual conservation easement in favor of an approved agent dedicated to conserving biological resources. CDFW recommends all open space or habitat lands considered for mitigation of environmental impact under CEQA be owned and managed by an entity with experience in managing habitat and be placed under a conservation easement. A management and monitoring plan, including a funding commitment, should be developed for any conserved land, and implemented in perpetuity to protect existing biological functions and values. Permeable DocuSign Envelope ID: 4DFBE940-8371-46D8-A695-AA924B7F3178 215
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wildlife fencing should be erected around any conserved land to restrict incompatible land uses and signage posted and maintained at conspicuous locations communicating these restrictions to the public.

Comment #6: Special Status Plant Survey
Issue: BIO-2 of the MND states, “a survey for special status plant species shall be conducted during their peak blooming period and prior to construction activities to determine whether the following species occur in the survey area: southern tarplant, Coulter’s saltbush, Parish’s brittlescale, lucky morning-glory, decumbent goldenbush, Coulter’s goldfields, prostrate vernal pool navarretia, and San Bernardino aster. If any of these species are observed, the population shall be avoided, if possible. If the population would be impacted, mitigation may be required depending on the number of individuals that would be impacted as compared to the number known in the project region.” However, the PSS states that special status plant surveys were conducted on December 6, 2019 and August 7 and 17, 2020. CDFW is concerned that these surveys were conducted when some of the plant species listed in BIO-2 are not blooming, namely Coulter’s goldfields and prostrate vernal pool navarretia.

Specific impacts: The December survey is outside of the blooming period for all plant species listed in BIO-2. The August survey is outside of the blooming period for Coulter’s goldfields and prostrate vernal pool navarretia. Special status plants may be missed if surveys are not conducted during appropriate times for detection. Project implementation, therefore, may result in impacts to special status plant species that may be located on site. The impacts from construction activity may result in direct mortality, reduced reproductive capacity, or population declines in rare or CDFW special status species.

Why impact would occur: In order to analyze if a project may have a significant effect on the environment, Project related impacts, including survey results for species that occur in the Project footprint, need to be disclosed during the public comment period. This information is necessary to allow CDFW and the public to comment on alternatives to avoid impacts, as well as to assess the significance of the specific impact relative to the species (e.g., current range, distribution, population trends, and connectivity). In addition, special status plants may not be detected if surveys are not conducted during appropriate times, which may lead to loss of special status species.

Evidence impact would be significant: CEQA Guidelines sections 15070 and 15071 require the Negative Declaration to analyze if the Project may have a significant effect on the environment as well as review if the Project will avoid the effect or mitigate to a point where clearly no significant effects would occur. Absent sufficient survey data, CDFW is unable to provide meaningful avoidance, minimization, or mitigation measures related to biological resources.

Recommended Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: CDFW recommends conducting focused surveys for all species listed in BIO-2 in the MND on-site and disclosing the results in the CEQA document. Based on the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW, 2018), a qualified biologist should “conduct botanical surveys in the field at the times of year when plants will be both evident and identifiable. Usually DocuSign Envelope ID: 4DFBE940-8371-46D8-A695-AA924B7F3178 216
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this is during flowering or fruiting.” The final CEQA documentation should provide a thorough discussion on the presence/absence of sensitive plants on-site and identify measures to protect sensitive plant communities from Project-related direct and indirect impacts.

Mitigation Measure #2: CDFW recommends avoiding any special status plant species found on the Project site. If avoidance is not feasible, due to the suitable habitat found on, CDFW recommends mitigating at a ratio no less than 5:1 for impacts to special status plant species.

This ratio should be used for the acreage as well as the individual plants that comprise each unique community. All revegetation/restoration areas that will serve as mitigation should include preparation of a restoration plan, to be approved by USFWS and CDFW prior to any ground disturbance. The restoration plan should include restoration and monitoring methods; annual success criteria; contingency actions should success criteria not be met; long-term management and maintenance goals; and, a funding mechanism to assure for in perpetuity management and reporting. Areas proposed as mitigation should have a recorded conservation easement and be dedicated to an entity which has been approved to hold/manage lands (AB 1094; Government Code, §§ 65965-65968).

Comment #7: Impacts to Nesting Birds
Issue: Mitigation measure BIO-4 of the MND states, “In order to avoid impacts on nesting birds, construction shall be scheduled to begin outside the peak nesting season (i.e., between September 1 and January 31), if feasible.” While CDFW agrees that construction should take place outside of peak nesting season, there is concern over the lack of mitigation for the removal of potentially inhabited vegetation.

Specific impacts: Construction during the breeding season of nesting birds could result in the incidental loss of fertile eggs or nestlings or otherwise lead to nest abandonment in trees directly adjacent to the Project boundary. The Project could also lead to the loss of foraging habitat for potentially sensitive bird species.

Why impact would occur: Impacts to nesting birds could result from ground disturbing and construction activities. Project disturbance activities could result in mortality or injury to nestlings, as well temporary or long-term loss of suitable foraging habitats. Construction during the breeding season of nesting birds could result in the incidental loss of breeding success or otherwise lead to nest abandonment on site and around the Project vicinity.

Evidence impact would be significant: The loss of occupied habitat or reductions in the number of rare bird species, either directly or indirectly through nest abandonment or reproductive suppression, would constitute a significant impact absent appropriate mitigation.

Furthermore, nests of all native bird species are protected under state laws and regulations, including Fish and Game Code sections 3503 and 3503.5.

Recommended Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: To protect nesting birds that may occur on site or adjacent to the Project boundary, CDFW recommends that no construction should occur from February 15 (January 1 for raptors) through August 31.

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City of Long Beach

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Mitigation Measure #2: If avoidance is not feasible, a qualified biologist should complete a survey for nesting bird activity within a 500-foot radius of the construction site. The nesting bird surveys should be conducted at appropriate nesting times and concentrate on potential roosting or perch sites. Surveys should be conducted no more than 7 days prior to the beginning of any Project-related activity likely to impact raptors and migratory songbirds, for the entire Project site. If Project activities are delayed or suspended for more than 7 days during the breeding season, repeat the surveys. If nesting raptors and migratory songbirds are identified, CDFW recommends the following minimum no-disturbance buffers be implemented: 300 feet around active passerine (perching birds and songbirds) nests, 500 feet around active non-listed raptor nests and 0.5 mile around active listed bird nests.

These buffers should be maintained until the breeding season has ended or until a qualified biologist has determined that the birds have fledged and are no longer reliant upon the nest or parental care for survival. These buffers should be increased if necessary, to protect the nesting birds.

It should be noted that the temporary halt of Project activities within nesting buffers during nesting season does not constitute effective mitigation for the purposes of offsetting Project impacts associated with habitat loss. Additional mitigation would be necessary to compensate for the removal of nesting habitat within the Project site based on acreage of impact and vegetation composition. CDFW should be consulted to determine proper mitigation for impacts to occupied habitat depending on the status of the bird species. Mitigation ratios would increase with the occurrence of a California Species of Special Concern and would further increase with the occurrence of a CESA-listed species.

Comment #8: Tree Removal
Issue: The MND indicates tree removal during ground and vegetation disturbing activities.

CDFW is concerned that the trees to be removed have not been identified, nor have the number of trees been indicated. In addition, an investigation has not taken place to identify the potential for tree pests.

Specific Impact: Project activities that involve removal of trees have the potential to result in the spread of tree insect pests and disease into areas not currently exposed to these stressors.

This could result in expediting the loss of trees in California which may support a high biological diversity including special status species.

Why impact would occur: Trees will be removed and presumably hauled to off-site locations for disposal, thereby exposing off-site tree species to potential infestation and disease.

Evidence Impact would be significant: The Project may result in an adverse effect, either directly or through habitat modifications, by exposing other habitats to insect and/or disease pathogens. Exposure to insect and/or disease pathogens may have a substantial adverse effect on any sensitive natural identified in local or regional plans, policies, and regulations or by the CDFW or U.S. Fish and Wildlife Service.

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City of Long Beach

November 17, 2020
Recommended Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: An infectious tree disease management plan should be developed and implemented prior to initiating Project activities. All trees scheduled for removal should be identified and counted to provide total numbers and species type. In addition, trees scheduled for removal resulting from the Project should be inspected for contagious tree diseases including but not limited to: thousand canker fungus (Geosmithia morbida), Polyphagous Shot Hole Borer (Euwallacea spp.), and goldspotted oak borer (Agrilus auroguttatus) (TCD 2020; UCANR 2020; UCIPM 2013). To avoid the spread of infectious tree diseases, diseased trees should not be transported from the Project site without first being treated using best available management practices relevant for each tree disease observed.

Mitigation Measure #2: CDFW recommends replacing native trees at least a 3:1 ratio with a combination of native trees and/or appropriate understory and lower canopy plantings. CDFW recommends that any loss of oaks should be replanted at a minimum 10:1 ratio. Replacement oaks should come from nursery stock grown from locally sourced acorns, or from acorns gathered locally, preferably from the same watershed in which they were planted. CDFW recommends replacing nonnative trees with at least a 1:1 ratio with native trees.

Comment #9: Impacts to Aquatic Resources
Issue: Southern tarplant is a species often found in areas with vernal pools (B.G. Baldwin, 2012). Therefore, some areas on the Project site may be submerged on a seasonal basis.

Specific Impact: Site photography presented in the BRA and the MND show depressions that may exist on the landscape that contain ponding water. CDFW is concerned there is potential for aquatic resources to be present on site that will be impacted by Project activities.

Why impact would occur: Lack of sufficient special status vegetation surveys (which would indicate vernal pool presence) may result in undisclosed impacts to aquatic resources.

Evidence Impact would be significant: CDFW, as described in Fish and Game Code section 703(a), is guided by the Fish and Game Commission’s policies. The Wetlands Resources policy (CFGC 2005) of the Fish and Game Commission “…seek[s] to provide for the protection, preservation, restoration, enhancement and expansion of wetland habitat in California. Further, it is the policy of the Fish and Game Commission to strongly discourage development in or conversion of wetlands. It opposes, consistent with its legal authority, any development or conversion that would result in a reduction of wetland acreage or wetland habitat values. To that end, the Commission opposes wetland development proposals unless, at a minimum, Project mitigation assures there will be ‘no net loss’ of either wetland habitat values or acreage. The Commission strongly prefers mitigation which would achieve expansion of wetland acreage and enhancement of wetland habitat values.”
CEQA Guidelines §15125(c) require the City to include information on the regional setting that is critical to an assessment of environmental impacts, with special emphasis placed on analyzing resources that are or unique to the region. There are very few vernal pools left in Los Angeles County; therefore, the loss of any vernal pool potentially on the Project site is significant to CDFW.

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City of Long Beach

November 17, 2020
Recommended Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: CDFW recommends an assessment of vernal pools, salt marshes, and saline alkaline pools to be conducted on the Project site during the wet season of the year by an individual familiar with wetland delineation. If any of these habitats are detected on site, CDFW recommends avoidance measures, such as avoiding any construction and development activities and preserving these areas, be put in place to prevent impacts to sensitive habitats.

Mitigation Measure #2: CDFW recommends conducting a USFWS wet and dry season protocol level survey for Branchiopods (USFWS 2015) on the Project site within suitable habitat.

The MND should include the results of all surveys.

Filing Fees
The Project, as proposed, could have an impact on fish and/or wildlife, and assessment of filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the fee is required in order for the underlying Project approval to be operative, vested, and final (Cal.

Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089).

Conclusion
We appreciate the opportunity to comment on the Project to assist the City in adequately analyzing and minimizing/mitigating impacts to biological resources. CDFW requests an opportunity to review and comment on any response that the City has to our comments and to receive notification of any forthcoming hearing date(s) for the Project. Questions regarding this letter and further coordination on these issues should be directed to Felicia Silva, Environmental Scientist, at [email protected] or (562) 430-0098.

Sincerely,
Erinn Wilson-Olgin
Environmental Program Manager I
Ec: CDFW
Victoria Tang, Los Alamitos – [email protected] Felicia Silva, Los Alamitos – [email protected] Andrew Valand, Los Alamitos – [email protected] Ruby Kwan-Davis, Los Alamitos – [email protected] Susan Howell, San Diego – [email protected]
CEQA Program Coordinator, Sacramento – [email protected] State Clearinghouse – [email protected]
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References
[CDFW] California Department of Fish and Wildlife. 2012. Staff Report on Burrowing Owl Mitigation. Accessed at: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843 [CDFW] California Department of Fish and Wildlife, 2018. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities. Accessed at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline. [CFGC] California Fish and Game Commission. 2005. Miscellaneous Policies. Wetlands Resources. Accessed at: https://fgc.ca.gov/About/Policies/Miscellaneous Bruce G. Baldwin 2012, Centromadia parryi subsp. australis, in Jepson Flora Project (eds.) Jepson eFlora, https://ucjeps.berkeley.edu/eflora/eflora_display.php?tid=79524, accessed on November 10, 2020.

Gervais, J.A., Rosenberg, D.K., and Comrack, L.A. Burrowing Owl (Athene cunicularia).

Shuford, W.D., and Gardali, T., editors. 2008. California Bird Species of Special Concern:

A ranked assessment of species, subspecies, and distint populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California, and California Department of Fish and Game, Sacramento.

Gruver, J.C. and D.A. Keinath (2006, October 25). Townsend’s Big-eared Bat (Corynorhinus townsendii): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available: http://
www.fs.fed.us/r2/projects/scp/assessments/townsendsbigearedbat.pdf [Accessed May 11, 2020].

Miner, Karen L. & Stokes, Drew C. 2005. Bats in the South Coast Ecoregion: Status, Conservation Issues, and Research Needs. USDA Forest Service General Technical Report PSW-GTR-195.
https://www.fs.fed.us/psw/publications/documents/psw_gtr195/psw_gtr195_2_13_Miner.pdf Thorp, Robbin W., Horning Jr, Donald S., and Dunning, Lorry L. 1983. Bumble Bees and Cuckoo Bumble Bees of California. Bulletin of the California Insect Survey 23.

Sawyer, J.O., Keeler Wolf, T., and Evens J.M. 2008. A manual of California Vegetation, 2nd ed.

ISBN 978 0 943460 49 9.
[TCD] Thousand Cankers Disease. 2020. What is Thousand Cankers? Accessed at:
http://thousandcankers.com/.
[UCANR] University of California Agriculture and Natural Resources Division. 2020. Invasive Shot Hole Borers. Accessed at: https://ucanr.edu/sites/eskalenlab/?file=/avocado.html. [UCIPM] University of California Statewide Integrated Pest Management Program. 2013. How to Manage Pests. Pests in Gardens and landscapes. Goldspottted Oak Borer. Accessed at:
http://ipm.ucanr.edu/PMG/PESTNOTES/pn74163.html.
[USFWS] United States Fish and Wildlife Service. 2015. Survey Guidelines for the Listed Large Brachiopods. Accessed at:
https://www.fws.gov/sacramento/es/SurveyProtocolsGuidelines/Documents/VernalPoolBr anchiopodSurveyGuidelines_20150531.pdf
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State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director South Coast Region
3883 Ruffin Road
San Diego, CA 92123
(858) 467-4201
www.wildlife.ca.gov
CDFW recommends the following language to be incorporated into a future environmental document for the Project.

Biological Resources
Mitigation Measure Timing Responsible
Party
MM-BIO-1-Vegetation
Removal Activity
Mitigation will take place at a ratio of no less than 5:1 for the loss of 1,500 sq ft of habitat that may have
supported special status plant species. These species
include Coulter’s saltbush, Parish’s brittlescale, lucky morning-glory, decumbent goldenbush, Coulter’s
goldfields, prostrate vernal pool navarretia, and San
Bernardino aster. The ratio shall be for the total
acreage of removed vegetation. All
revegetation/restoration areas that will serve as
mitigation shall include preparation of a restoration
plan, to be approved by USFWS and CDFW prior to
any ground disturbance. The restoration plan shall
include restoration and monitoring methods; annual
success criteria; contingency actions should success
criteria not be met; long-term management and
maintenance goals; and, a funding mechanism to
assure for in perpetuity management and reporting.

Areas proposed as mitigation shall have a recorded
conservation easement and be dedicated to an entity
which has been approved to hold/manage lands (AB
1094; Government Code, §§ 65965-65968).

Prior to
Construction
City of Long Beach
MM-BIO-2-Crotch’s
bumble bee
Due to potentially suitable habitat within the Project
site, within one year prior to vegetation removal and/or grading, a qualified entomologist familiar with the
species behavior and life history shall conduct surveys to determine the presence/absence of Crotch’s bumble
bee and their colony. Surveys shall be conducted
Prior to
Construction
City of Long Beach
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during flying season when the species is most likely to be detected above ground, between March 1 to
September 1 (Thorp et al. 1983). Survey results
including negative findings shall be submitted to CDFW
one week prior to initiation of Project activities. If “take” or adverse impacts to Crotch’s bumble bee cannot be
avoided either during Project activities or over the life of the Project, the City must consult CDFW to determine if a CESA incidental take permit is required (pursuant to
Fish & Game Code, § 2080 et seq.).

MM-BIO-3-Crotch’s
bumble bee
If an individual is observed during Project activities, work shall not occur until the animal has left the work area of its own volition. If a nest is observed, no Project activities shall occur until a plan to protect Crotch
bumblebee, including over-wintering queens, has been
approved in writing by CDFW. The City shall develop
appropriate avoidance, minimization, and mitigation
measures to decrease Project impacts to less than
significant. If avoidance is not feasible, compensatory mitigation may be necessary to offset impacts to habitat and colony size.

Prior to
Construction
City of Long Beach
MM-BIO-4-Bat Species Prior to construction activities, bat surveys will be conducted by a qualified bat specialist to determine
baseline conditions within the Project area and within a 500-foot buffer, if feasible. This will aid in determining not only impacts of species on site but also any species that may be in the surrounding Project vicinity. Acoustic recognition technology will be used to maximize
detection of bat species to minimize impacts to
sensitive bat species. The City shall document the
presence of any bats and include species specific
mitigation measures, such as avoiding roosting season
for that species, to reduce impacts to below a level of significance.

Prior to
Construction
City of Long Beach
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MM-BIO-5-Bat Species To the extent feasible, tree removal or relocation shall be scheduled between October 1 and February 28,
outside of the maternity roosting season. Maternity
season lasts from March 1 to September 30. Trees
and/or structures determined to be maternity roosts
shall be left in place until the end of the maternity
season.

Prior to
Construction
City of Long Beach
MM-BIO-6-Bat Species If trees and/or structures must be removed during the maternity season (March 1 to September 30), a
qualified bat specialist shall conduct a pre-construction survey to identify those trees and/or structures
proposed for disturbance that could provide
hibernacula or nursery colony roosting habitat for bats.

Each tree and/or structure identified as potentially
supporting an active maternity roost shall be closely
inspected by the bat specialist no greater than 7 days
prior to tree disturbance to more precisely determine
the presence or absence of roosting bats.

Prior to
Construction
City of Long Beach
MM-BIO-7-Bat Species If bats are not detected, but the bat specialist determines that roosting bats may be present at any
time of year, it is preferable to push any tree down
using heavy machinery rather than felling it with a
chainsaw. In order to ensure the optimum warning for
any roosting bats that may still be present, the tree
shall be pushed lightly two to three times, with a pause of approximately 30 seconds between each nudge to
allow bats to become active. The tree shall then be
pushed to the ground slowly and shall remain in place
until it is inspected by a bat specialist. Trees that are known to be bat roosts shall not be sawn up or
mulched immediately. A period of at least 24 hours,
and preferably 48 hours, shall elapse prior to such
operations to allow bats to escape. Bats shall be
allowed to escape prior to demolition of buildings. This Prior to
Construction
City of Long Beach
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November 17, 2020
may be accomplished by placing one-way exclusionary
devices into areas where bats are entering a building
that allow bats to exit but not enter the building.

The bat specialist shall document all demolition
monitoring activities and prepare a summary report to
the City upon completion of tree disturbance and/or
building demolition activities.

Temporary halt of Project activities to allow bats to
escape during nesting season does not constitute
effective mitigation for the purposes of offsetting Project impacts associated with habitat loss. Additional
mitigation will be necessary to compensate for the
removal of roosting habitat within the Project site based on acreage of impact and vegetation composition.

CDFW shall be consulted to determine proper
mitigation for impacts to occupied habitat depending on the status of the bat species. Mitigation ratios would
increase with the occurrence of a California Species of Special Concern.

MM-BIO-8-Burrowing
Owl
To reduce impacts to burrowing owl to less than
significant, the Project will adhere to CDFW’s March 7, 2012, Staff Report on Burrowing Owl Mitigation (CDFW
2012). All survey efforts shall be conducted prior to any Project activities that could result in habitat disturbance to soil, vegetation or other sheltering habitat for
burrowing owl. In California, the burrowing owl breeding season extends from February 1 to August 31 with
some variances by geographic location and climatic
conditions. Survey protocol for breeding season owl
surveys states to conduct 4 survey visits: 1) at least
one site visit between February 15 and April 15, and 2) a minimum of three survey visits, at least three weeks
apart, between April 15 and July 15, with at least one
Prior to
Construction
City of Long Beach
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visit after June 15.

MM-BIO-9-Burrowing
Owl
Permanent impacts to occupied owl burrows and
adjacent foraging habitat shall be offset by setting aside replacement habitat to be protected in perpetuity under a conservation easement dedicated to a local land
conservancy or other appropriate entity, which shall
include an appropriate non-wasting endowment to
provide for the long-term management of mitigation
lands. The City shall require a burrowing owl mitigation plan be submitted to CDFW for review and comment
prior to Project implementation.

Prior to
Construction
City of Long Beach
MM-BIO-10-Burrowing
Owl
For proposed preservation and/or restoration, the final environmental document shall include measures to
protect the targeted habitat values in perpetuity from
direct and indirect negative impacts. The objective shall be to offset the Project-induced qualitative and
quantitative losses of wildlife habitat values. Issues that shall be addressed include, but are not limited to,
restrictions on access, proposed land dedications,
monitoring and management programs, control of
illegal dumping, water pollution, and increased human
intrusion. An appropriate non-wasting endowment shall
be provided for the long-term monitoring and
management of mitigation lands. Mitigation will occur at a state-approved bank or via an entity that has been
approved to hold and manage mitigation lands
pursuant to Assembly Bill 1094 (2012), which amended
Government Code sections 65965-65968. Under
Government Code section 65967(c), the lead agency
must exercise due diligence in reviewing the
qualifications of a governmental entity, special district, or nonprofit organization to effectively manage and
steward land, water, or natural resources on mitigation lands it approves.

Prior to
Construction
City of Long Beach
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MM-BIO-11-Burrowing
Owl
Project use of rodenticides that could result in direct or secondary poisoning to burrowing owl shall be avoided.

MM-BIO-12-Southern
Tarplant
Areas where southern tarplant is located on site shall
attempted to be preserved. If on-site mitigation is not feasible or would not be biologically viable, off-site
mitigation through occupied habitat acquisition and
preservation in perpetuity may be appropriate. Due to
the suitable habitat found on site, the estimated 830
individuals found, and the estimated 1,500 sq ft of
suitable habitat already removed, mitigation will be at a ratio no less than 10:1 for this rare 1B.1 ranked
species. This ratio is for the acreage and the individual plants that are found on site.

Prior to
Construction
City of Long Beach
MM-BIO-13-Southern
Tarplant
All open space preservation/mitigation land be
protected in perpetuity with minimal human intrusion by recording and executing a perpetual conservation
easement in favor of an approved agent dedicated to
conserving biological resources. All open space or
habitat lands considered for mitigation of environmental impact under CEQA be owned and managed by an
entity with experience in managing habitat and be
placed under a conservation easement. Ownership of
any open space or habitat land considered as
avoidance under CEQA shall be placed with a
conservancy or other land management company to
allow for legal remedies shall trespass and
clearing/damage occur. A management and monitoring
plan, including a funding commitment, shall be
developed for any conserved land, and implemented in
perpetuity to protect existing biological functions and values. Permeable wildlife fencing shall be erected
around any conserved land to restrict incompatible land uses and signage posted and maintained at
Prior to
Construction
City of Long Beach
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conspicuous locations communicating these restrictions
to the public.

MM-BIO-14-Special
Status Plant Survey
A focused survey for southern tarplant shall be
conducted on-site and the results disclosed in the
CEQA document. Based on the Protocols for Surveying
and Evaluating Impacts to Special Status Native Plant
Populations and Sensitive Natural Communities
(CDFW, 2018), a qualified biologist shall “conduct
botanical surveys in the field at the times of year when plants will be both evident and identifiable. Usually this is during flowering or fruiting.” The final CEQA
documentation shall provide a thorough discussion on
the presence/absence of sensitive plants on-site and
identify measures to protect sensitive plant
communities from Project-related direct and indirect
impacts.

Prior to
Construction
City of Long Beach
MM-BIO-15-Special
Status Plant Survey
Any special status plant species found on the Project
site shall be avoided. If avoidance is not feasible, due to the suitable habitat found on site and the estimated 1,500 sq ft of suitable habitat already removed, CDFW
recommends mitigating at a ratio no less than 5:1 for
impacts to special status plant species. This ratio would be for the acreage and the individual plants that
comprise each unique community. All
revegetation/restoration areas that will serve as
mitigation shall include preparation of a restoration
plan, to be approved by USFWS and CDFW prior to
any ground disturbance. The restoration plan shall
include restoration and monitoring methods; annual
success criteria; contingency actions shall success
criteria not be met; long-term management and
maintenance goals; and, a funding mechanism to
assure for in perpetuity management and reporting.

Areas proposed as mitigation shall have a recorded
Prior to
Construction
City of Long Beach
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conservation easement and be dedicated to an entity
which has been approved to hold/manage lands (AB
1094; Government Code, §§ 65965-65968).

MM-BIO-16-Nesting
Birds
To protect nesting birds that may occur on site or
adjacent to the Project boundary, no construction shall occur from February 15 (January 1 for raptors) through
August 31.

Prior to
Construction
City of Long Beach
MM-BIO-17-Nesting
Birds
If avoidance is not feasible, a qualified biologist shall complete a survey for nesting bird activity within a 500- foot radius of the construction site. The nesting bird
surveys shall be conducted at appropriate nesting
times and concentrate on potential roosting or perch
sites. Surveys shall be conducted no more than 7 days
prior to the beginning of any Project-related activity
likely to impact raptors and migratory songbirds, for the entire Project site. If Project activities are delayed or suspended for more than 7 days during the breeding
season, repeat the surveys. If nesting raptors and
migratory songbirds are identified, the following
minimum no-disturbance buffers be implemented: 300
feet around active passerine (perching birds and
songbirds) nests, 500 feet around active non-listed
raptor nests and 0.5 mile around active listed bird
nests.

These buffers shall be maintained until the breeding
season has ended or until a qualified biologist has
determined that the birds have fledged and are no
longer reliant upon the nest or parental care for
survival. These buffers shall be increased if needed to protect the nesting birds.

The temporary halt of Project activities within nesting buffers during nesting season does not constitute
effective mitigation for the purposes of offsetting Project Prior to
Construction
City of Long Beach
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impacts associated with habitat loss. Additional
mitigation will be necessary to compensate for the
removal of nesting habitat within the Project site based on acreage of impact and vegetation composition.

CDFW shall be consulted to determine proper
mitigation for impacts to occupied habitat depending on the status of the bird species. Mitigation ratios will
increase with the occurrence of a California Species of Special Concern and will further increase with the
occurrence of a CESA-listed species.

MM-BIO-18-Tree
Removal
An infectious tree disease management plan shall be
developed and implemented prior to initiating Project
activities. All trees scheduled for removal shall be
identified and counted to provide total numbers and
species type. In addition, trees scheduled for removal
resulting from the Project shall be inspected for
contagious tree diseases including but not limited to:
thousand canker fungus (Geosmithia morbida),
Polyphagous Shot Hole Borer (Euwallacea spp.), and
goldspotted oak borer (Agrilus auroguttatus) (TCD
2020; UCANR 2020; UCIPM 2013). To avoid the
spread of infectious tree diseases, diseased trees shall not be transported from the Project site without first
being treated using best available management
practices relevant for each tree disease observed.

Prior to
Construction
City of Long Beach
MM-BIO-19-Tree
Removal
All trees removed as a result of the proposed work
activities shall be replaced with at least a 1:1 ratio with native trees. All native trees shall be replaced with at least a 3:1 ratio with a combination of native trees
and/or appropriate understory and lower canopy
plantings. Any loss of oaks shall be replanted at a
minimum 10:1 ratio. Replacement oaks shall come
from nursery stock grown from locally sourced acorns,
Prior to
Construction
City of Long Beach
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or from acorns gathered locally, preferably from the
same watershed in which they were planted.

MM-BIO-20- Aquatic
Resources
An assessment of vernal pools, salt marshes, and
saline alkaline pools to be conducted on the Project site during the wet season of the year by an individual
familiar with wetland delineation. If any of these
habitats are detected on site, avoidance measures,
such as avoiding any construction and development
activities and preserving these areas, will be put in
place to prevent impacts to sensitive habitats.

Prior to
Construction
City of Long Beach
MM-BIO-21- Aquatic
Resources
A USFW wet and dry season protocol level survey for
Branchiopods (USFWS 2015) shall be conducted on
the Project site within suitable habitat. The MND shall include the results of all surveys.

Prior to
Construction
City of Long Beach
Recommendations
Recommendation-1 The vegetated area that was removed before adequate surveys were conducted should be identified as a
significant impact.

Prior to finalizing
CEQA document
City of Long Beach
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EXHIBIT N
232
4/10/2021 Editorial: Make green space not development the priority on the LA Riverfront - Long Beach Post Voices https://lbpost.com/voices/editorial-make-green-space-not-development-the-priority-on-the-la-riverfront 1/3 Fire pit Book early - ADVERTISEMENT -
EDITORIAL APR 9 12:54 PM
Editorial: Make green space not
development the priority on the LA
Riverfront
The Community Editorial Board   310
The following represents the views of the undersigned members of the Community Editorial Board.
- ADVERTISEMENT -
If you have driven through Bixby Knolls or Wrigley recently, you might have seen this sign: Build The River Park. The Riverpark Coalition has been advocating to stop development of a storage facility and RV parking lot off Pacific Place, the abandoned golf driving range off the 405 and 710 interchange by the LA River. Instead, Riverpark Coalition, along with many members of the local community, are championing a plan to transform the precious land into an open green space for all.

A common misperception about the LA River is that it is not actually a river but is merely a concrete water channel or a storm drain. But if you ask any local environmental advocate or native Angeleno about the river they will happily tell you about the unique bird watching, kayaking, biking, or even fishing. (Though none of us would dare eat the fish.) Many years before the Army Corps of Engineers paved the river in the 1930s, it provided food and water to the indigenous Tongva people.

Within the past 20 years, there have been more and more efforts to revitalize the river, opening up the space for more recreation, restoring wildlife habitat, and increasing public access. Most recently, Atwater Village opened two new pedestrian bridges that interact with the LA River bike path. The architect Frank Gehry has recently unveiled his ambitious 233
4/10/2021 Editorial: Make green space not development the priority on the LA Riverfront - Long Beach Post Voices https://lbpost.com/voices/editorial-make-green-space-not-development-the-priority-on-the-la-riverfront 2/3 and controversial plan that includes a massive cultural center and park on the LA River bike path where the river is joined by the Rio Hondo. But where does that leave Long Beach?
Currently, we have parks sprinkled throughout our city, some of which see more love than others. Most of Long Beach’s shoreline is publicly accessible as well, excluding the port. We also have expansive parks that traverse several blocks and provide welcoming green spaces–in particular Heartwell, El Dorado and Recreation. All three of these parks are east of Lakewood Boulevard. The other five districts west of Lakewood Boulevard are left wanting more.

A map of Long Beach’s parks will show you that West Long Beach is greatly in need of more open green space, even if we count the LA County-owned Dominguez Gap Wetlands, which is a small hidden gem within Long Beach, and the ongoing Wrigley Greenbelt project—both of which are less than 50 acres combined. El Dorado East alone is nearly 400 acres. City parks are essential to the quality of life, health, resilience, and overall well-being of our communities. Increased access to wellmaintained parks has been shown to reduce crime, decrease pollution, and strengthen local neighborhoods.

The City Council’s hearing for appeal of the Planning Commission’s decision related to development of Pacific Place will be held on April 13.

The city has been given an incredible opportunity to build something vitally important for our local community.

A belated Park Acquisition Feasibility Report released by the City of Long Beach on April 5 attempts to justify the use and zoning of the space for industrial development. As noted in the recent press release by the Riverpark Coalition and included in the City’s 2007 Green Vision Map, however, the land should remain as an opportunity for use as a green space. The city has been negligent in its commitment to serve the needs of our community by instead supporting commercial development of the land.

We must make our voices heard by demanding our councilmembers stop plans for development in order to conduct a full Environmental Impact Report and to continue to advocate for the River Park.

West Long Beach has been left for far too long without accessible green spaces. A beautiful, expansive park could become a landmark along the LA River bike path and an icon for Long Beach. Our communities in West Long Beach also deserve access to parks and green spaces within our neighborhoods. With the proposed River Park, West Long Beach may finally have green spaces that can join the ranks of the other beloved parks of Long Beach. This would be so much more meaningful than a three story industrial building and parking lot.

Signed,
Murriel McCabe
Amber Hopper
Ebony Utley
Jeff Rabin
Jose Osuna
Mariela Salgado
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4/10/2021 Editorial: Make green space not development the priority on the LA Riverfront - Long Beach Post Voices https://lbpost.com/voices/editorial-make-green-space-not-development-the-priority-on-the-la-riverfront 3/3 The Community Editorial Board
The Community Editorial Board is made up of seven members of the Long Beach community and are drawn from different life journeys, different parts of the city and different socioeconomic experiences. The board writes on issues and subjects in which it has a personal interest, experience or expertise. The board operates wholly separate from the newsroom and members serve a one-year term. The Community Editorial Board ca be reached at [email protected].
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Strategic Plan – Executive Summary
Department of Parks, Recreation, and Marine
In the fall of 1999, the Long Beach Department of Parks, Recreation, and Marine began to develop a strategic plan to identify current issues and potential future challenges to the Department and to develop strategies for meeting them. The resulting plan incorporates many elements of the City of Long Beach’s 2010 Strategic Plan (see Appendix) and will be used to direct the Department’s recreational programming, park and facility development and improvement, and administrative decisions for the next ten years. The mission of the Long Beach Department of Parks, Recreation, and Marine, “We create community and enhance the quality of life in Long Beach through people, places, programs, and partnerships,” guides the focus and vision of the Strategic Plan.

Long Beach is a city of almost 500,000 with a diverse and growing population. The Department analyzed its assets— the parks, beaches, recreation centers, marinas, programming, and the Department itself to determine strengths, weaknesses, and projected needs. How demographic changes might affect the programming, infrastructure, maintenance, growth, staffing, and funding were all assessed in the context of the City of Long Beach’s Strategic Plan 2010.

Long Beach’s Department of Parks, Recreation, and Marine (PRM) operates 94 parks with 25 community centers, two major tennis centers, one of the busiest municipal golf systems in the country with five courses, the largest municipally operated marina system in the nation with 3,800 boat slips and 11 miles of beaches. Approximately 3,100 acres within the City’s 50 square miles are devoted to recreation.

Gathering Information Through Surveys, Research, and Interviews As PRM began to develop its strategic plan, important community input was gathered through surveys, forums, interviews, meetings with city commissions and advisory groups, the Mayor and City Council, focus groups, and demographic, facility, and program analysis. PRM also reviewed fee structures, potential partnerships, and benchmark information collected from other communities and parks and recreation departments throughout the country. This information was used to identify the Department’s strengths, constraints or weaknesses, future threats, and future opportunities.

The vast majority of Long Beach’s residents affirm that parks, open space, and the City’s appearance are important. Nearly all residents surveyed agree that developing and maintaining parks, beaches, and waterways is an important role for the Department. Nearly as many residents felt the Department’s roles in preserving the environment and providing open space are important. While a majority of the City’s residents are satisfied with the amount of parks and open spaces in Long Beach, a large number are not. Almost 60 percent of residents surveyed thought the City had enough parks and open spaces, but slightly over 40 percent disagreed.

The level of the dissatisfaction with the amount of parks and open spaces is reflected in the degree to which the residents would be willing to support a tax and additional spending to Introduction
240

Strategic Plan – Executive Summary
Department of Parks, Recreation, and Marine

DEPARTMENT OF PARKS, RECREATION, AND MARINE CORE VALUES ?? Strengthen the community image and sense of place by creating a positive identity for the City and its neighborhoods through parks and natural places.
?? Serve the needs of the community and its citizens, providing the best service and facilities possible, in a professional, customer friendly, efficient, and positive manner.
?? Protect environmental resources.
?? Provide recreational experiences; promote play and celebration. ?? Promote healthy lifestyles, and foster personal development, professional growth, and lifelong learning.
?? Strengthen safety and security by providing constructive outlets and forums for community interaction. Facilitate community problem solving by providing facilities and programs for positive interaction. ?? Increase cultural unity by celebrating heritage and diversity. Ensure that people of diverse ages, ethnic origins, abilities, gender, and income levels feel welcome in Long Beach parks, beaches, facilities, and recreation programs.
?? Ensure that parks, programs, facilities, and services are equitably distributed and easily accessible throughout the community strengthening Long Beach’s neighborhoods, and benefiting all residents. ?? Support economic development by providing parks, beaches, waterways, and programs that enhance quality of life and support continuing economic success.
expand or improve the City’s parks and recreation system. Only 9 percent of residents surveyed said they would vote against a bond measure to improve or expand the City’s parks and recreation system. Forty percent would vote in favor, 33 percent might vote in favor, and 18 percent were unsure. Given current anti-tax sentiment among citizens in general, this shows a substantial level of support.

Developing a Strategy
During PRM’s strategy development phase, the mission and values of the Department were refined. Strategic issues were identified, discussed, and prioritized, based on their impact on the Department’s future vision. Numerous alternative strategies for addressing each issue were developed. Those strategies with the greatest likelihood of contributing to the Department’s mission were selected and an implementation timetable was developed. Although planning has been developed in the context of the vast amount of research and information gathered, the Department’s mission and
supporting core values
provide the foundation for
the goals and strategies
that have been developed
to implement the strategic
plan.

From the informationgathering phase and the
refining of the
Department’s mission and
values, six goals were
defined that will guide the
future growth and development of Long Beach PRM.

For each of these goals,
the project team assessed
the current conditions,
surveyed employees and
users, and reviewed
benchmark information
from other parks and
recreation facilities. From
this research, PRM
examined where improvements could be made and
developed strategies to
make those improvements to fulfill its mission.

A series of strategies have been developed to accomplish each of the goals. Each of these strategies requires some change in priority or approach. Some require additional investment in 241

Strategic Plan – Executive Summary
Department of Parks, Recreation, and Marine
park land and in improving or building new facilities. Other strategies require changes in how things are accomplished, including changes in processes. Some strategies will require changes in the organizational structure of the Department, including changes in roles and responsibilities or units and individuals. Changing management policies and practices will be required to implement some strategies, which may include changing such things as reward systems, or the relationship between management and labor. The most difficult strategies to implement will be those that require people to change. These changes will include upgrading Department employees’ skills and abilities. It will also include changing the attitudes, values, beliefs, and culture of the organization.

As strategies are implemented, several indicators of success have been adopted to measure progress. The information for these indicators will be collected and reviewed periodically, and, if necessary, strategies will be enhanced, revised, or completely changed to ensure adequate progress is achieved. The Executive Summary provides overall strategies designed to achieve each of the goals listed below. Refer to the complete Strategic Plan of the Long Beach Department of Parks, Recreation, and Marine for specific, targeted strategies.

DEPARTMENT OF PARKS, RECREATION & MARINE

STRATEGIC GOALS
Goal 1: Ensure Open Space Parks and Recreational Facilities Meet Community Needs.

Goal 2: Ensure City Parks and Recreational Facilities Provide a Positive Experience and Image.

Goal 3: Ensure Recreational Programming, Leisure Opportunities, and Community Services Meet the Diverse Needs and
Interests of Residents and Visitors.

Goal 4: Ensure Beaches, Waterways, and Marine Amenities Are Accessible and Provide a Positive Experience and Image.

Goal 5: Ensure Marinas Are Fiscally Sound and Meet Boat Owner and Community Needs.

Goal 6: Facilitate and Encourage Productive Service to the Community through the Department’s Management
Philosophy, Structure, Culture, and Employees.
242

Strategic Plan – Executive Summary
Department of Parks, Recreation, and Marine
The City of Long Beach has a substantial parks and recreational system that includes 94 parks encompassing 1,672 acres. Parks include mini, neighborhood, and community parks; regional parks, including 6 linear miles of beach; and greenway parks. In addition to parks, the City has a number of specialty facilities that provide recreational and leisure opportunities. These include a riverfront campground, two historic ranchos, the Long Beach Museum of Art, two marine biological preserves, two special events parks, the park at Colorado Lagoon, Shoreline, Santa Cruz and Victory parks, and the El Dorado Nature Center Park and trail. The City also manages water recreation areas, including five public boat launches, the Alamitos Bay, and Marine Stadium, and five public golf courses.

LONG BEACH DEPARTMENT OF PARKS, RECREATION, AND MARINE
North
West
South
C East ity of
Signal Hill
Sou # th Street Parkway (G)
#
Jackson (M)
S # leepy Hollow Greenbelt (G)
#
Daisy Greenbelt (G)
Fourteenth Street (M) #
Drake (N) #
#
Santa Cruz (M)
#
Alamitos (M)
#
Costa Del Sol (G)
#
Naples Plaza (M)
#
Will Rogers (M)
#
Marina Vista (N)
#
Mossy Kent (M)
#
Channel View (G)
#
College Estates (N)
#
Los Altos Plaza (M)
#
Bouton Creek (M)
#
Whaley (N)
#
Los Altos (N)
#
Pan American (N)
#
Ramona (N)
#
Houghton (C)
#
Coolidge (N)
DeForest (N) #
A #tlantic Plaza (N)
#
Scherer (C)
#
Bixby Knolls (N)
#
Cherry (C) #
Somerset (N)
# Los Cerritos (N)
S # ilverado (C)
Ve #terans (C)
#
Martin Luther King, Jr. (C)
Hudson (N) #
A # dmiral Kidd (N)
#
California Recreation Center (N)
#
MacArthur (N)
C #esar E. Chavez (C)
#
Bixby (C)
#
Recreation (C)
#
Heartwell (C)
#
El Dorado - Regional
#
El Dorado - West (C)
#
Stearns Champions (C)
#
Wrigley Greenbelt (G)
#
Orizaba (N)
#
Bluff (G)
#
Rose (M)
#
Livingston Drive (M)
#
Bayshore (M)
#
Pacific Electric Greenbelt (G)
#
Douglas (M)
#
Wardlow (N)
#
Birdcage (M)
#
Treasure Island (M)
#
Lilly (M)
#
Plaza Zaferia (M)
#
Victory (G)
#
Miracle on 4th Street (M)
City Parks & Beaches
Source: Long Beach Department of Parks, Recreation, and Marine 2001 Maps of Parks, Facilities, and Service Areas (C) = Community Park, (N) = Neighborhood Park, (M) = Mini Park, (G) = Greenway Goal 1: Ensure Open Space Parks and Recreational Facilities Meet Community Needs. 243

Strategic Plan – Executive Summary
Department of Parks, Recreation, and Marine
Long Beach Needs Additional Park Space
Although its residents may not think of Long Beach as a densely populated urban city, the City has a population density of over 9,000 persons per square mile, which is more dense than the cities of Baltimore, Detroit, and Los Angeles. There are currently approximately 5.8 acres of park land for every 1,000 residents, which is substantially below the average of 13 acres per 1,000 residents for all the cities compared, and somewhat below the average of 7 acres per 1,000 for other high-density cities. It is important to note that many of these other cities have national, state, or county parks within their boundaries that serve the needs of their residents.

Long Beach does not have any of these types of parks.

The high population density also makes it more difficult to develop and maintain park space, given the high demand for land area. Needs for housing, commercial space, and even public services compete for the limited space available. Long Beach also falls well below the average in park area compared to total city area - 7.9 percent of Long Beach is park land compared to the average of 10.9 percent for all the cities benchmarked.

Access to City Parks and Number of Residents Served Is Uneven While the number of acres of park land is an important indicator of overall park resources, it does not indicate how accessible park resources are to residents. Much of the park land in Long Beach is concentrated on the eastern edge of the City, while the majority of the City’s residents are in the central and northern areas. Ideally, residents living in high-density areas would have a neighborhood park within one-quarter mile. Those living in low-density areas would have a neighborhood park within one-half mile. Neighborhood park needs are not met in a substantial part of the City. Park land is not distributed throughout the City in the same proportion as the population. The number of acres per 1,000 population varies widely, ranging from only 1 acre per 1,000 in the North and West Park Districts, to over 16 acres per 1,000 in the East Park District. Given this disparity, the number of persons served per park acre in different areas of the City varies widely, with some parks serving nearly 8,000 residents per acre, while others serve a few hundred residents per acre.

Park Acres and Population Density

16.7 2.7

1.0 1.0
0 3,000
6,000
9,000
12,000
15,000
East South North West
Population
0 2
4 6
8 10
12 14
16 18
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Park Acres Per
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Strategic Plan – Executive Summary
Department of Parks, Recreation, and Marine
Strategy 1.1: Increase the Amount of Park Space in Long Beach.

PRM has established a target of 8 acres of park land for every 1,000 Long Beach residents.

While this level of park land is well below the average of 13 for all cities compared, it is above the average of 7 acres per 1,000 residents for high-density cities comparable to Long Beach.

Approximately 1,080 acres of park land would be needed to meet this target for the current population, with an additional 231 acres of park land needed by 2010 to keep pace with projected population growth.

Strategy 1.2: Improve Access to City Parks in Long Beach.

Residents of Long Beach strongly support the Department’s role in providing sports and recreation facilities and amenities. PRM uses two measures to determine how well facilities are meeting the needs of the community— the number of residents served per facility and the area served by each facility— and has developed target service levels for each of the types of recreation facilities it provides. The Department currently provides access to playgrounds,

LONG BEACH DEPARTMENT OF PARKS, RECREATION, AND MARINE
Source: Long Beach Department of Parks, Recreation, and Marine 2001 Maps of Parks, Facilities, and Service Areas 245

Strategic Plan – Executive Summary
Department of Parks, Recreation, and Marine
swimming pools, tennis courts, outdoor basketball courts, football/soccer fields, baseball/softball fields, and community recreation centers.

The Department also provides nontraditional active recreational facilities. These include skate and bicycle parks and plazas, handball courts, roller hockey courts, volleyball courts, spray pools, group picnic facilities, amphitheaters and band shells, a fly-casting pond, an archery range, model plane and boat facilities, sailing, canoeing and kayaking facilities, and an off-leash dog area. While these facilities are important, they were not included in this analysis. These facilities are often developed to meet specific needs in specific locations, and are somewhat unique in nature. Given this, there are no national standards or community targeted service levels for these nontraditional facilities. The Long Beach Unified School District also operates and maintains recreation facilities to support the recreational needs of the students. Some of these facilities are open and accessible to the public during non-school hours. School facilities that are accessible to the public have been included in the analysis of service levels and needs.

PRM target service levels range from substantially below the established levels in the case of swimming pools and sports fields to somewhat below established levels for tennis courts and basketball courts. The facility additions required to bring the Department up to their established target service levels can be found in the full Strategic Plan, which provides numbers for current needs and projected needs in 2010.

Strategy 1.3: Increase public access to School District recreational facilities.

Public access to school recreation facilities is limited due to the need to secure the facilities from vandalism and the need for personnel to supervise the sites. Facilities are open where the School District or the Department has been able to acquire funding to provide supervised programs or where youth sports organizations have developed agreements with the District to provide for site supervision and security.

The District’s current policy allows each school principal to determine if the public can access recreation facilities at each school site. Many of the District’s sports fields identified as not accessible are used by youth sports leagues and other members of the public if they provide for site security and supervision. To use these facilities requires applying for and receiving a permit from the District, and payment of a fee to cover the cost of school personnel on-site during the use. This use meets some of the community’s recreational needs. In addition to the access discussed above, there is community demand for more open school facilities for casual and/or passive recreational access, and for more use of classrooms and auditoriums to substitute for recreation center facilities in areas without recreation centers.

Strategy 1.4: Develop additional City recreational facilities.

While the School District’s recreational facilities can help meet the community’s recreational needs, they cannot completely fill the gap between needs and existing facilities. The City will need to develop additional recreational facilities. Specific strategies include developing new master plans for El Dorado Regional Park and for each community park in the City; plans to address citywide aquatics and pools; and developing Chittick Field and a new sports park on the City property at Spring and Orange.
246

Strategic Plan – Executive Summary
Department of Parks, Recreation, and Marine
Strategy 1.5: Develop full service community recreation centers throughout the City.

The Department is pursuing the development of four to five large multi-generational community recreation centers. These centers would be 40,000 to 60,000 square feet in size, and would be located throughout the City based on the population to be served. Each facility would have a variety of facilities, including pools, gymnasiums, exercise areas, sports courts, classrooms, and community rooms. Larger recreation centers are more cost effective to operate and can generate a substantial amount of revenue to offset operational costs. These centers can serve more age groups in one setting, and at a cost per person that is significantly less than current levels.

Strategy 1.6: Develop a recreation service transportation program.

The Community Recreation Services Bureau will work jointly with Long Beach Transit and other agencies to develop recreation routes for youth and seniors to access programs and facilities. 247
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Final Remedial Investigation Report
Former Oil Operators North Site
3701 Pacific Place
Long Beach, California
May 27, 2009
002-10231-063
Prepared For
CRG Properties, Ltd.
4010 W. Chandler Avenue
Santa Ana, California 92704
Prepared By
LFR Inc.
3150 Bristol Street, Suite 250
Costa Mesa, California 92626
270
May 27, 2009 002-10231-06
Mr. Greg Holmes, Unit Chief
California Department of Toxic Substances Control
Southern California Cleanup Operations
5796 Corporate Avenue
Cypress, California 90630-4732
Subject: Final Remedial Investigation Report, Former Oil Operators North Site, 3701 Pacific Place, Long Beach, California
Dear Mr. Holmes:

LFR Inc. (LFR) has prepared the attached Final Remedial Investigation Report to document and present the results of investigation activities at the former Oil Operators, Inc. North facility located at 3701 Pacific Place, Long Beach, California (“the Site”). LFR previously completed and submitted a Revised Data Characterization Report for the Site, which included our responses to the California Department of Toxic Substances Control’s (DTSC) comments dated March 12, 2007.

Data gaps identified by that report have been addressed by this remedial investigation, and we believe the project is now ready for a Feasibility Study.

If you have any questions regarding the material presented in this report, please contact the undersigned at 714-444-0111.

Sincerely,
Melissa C. Schuetz
Senior Associate Geologist
Attachments
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LFR Inc. Final Remedial Investigation Report
The results of these two studies indicated that the majority of sump materials were too compressible to directly support shallow foundations. If foundations were to be placed on these materials, differential foundation settlement would likely be excessive.

Three cross-section maps (Subsurface Profiles No. 1, 2, and 3) were prepared using the information obtained from the CPT tests. These cross-sections are presented as Figures 4, 5, and 6, respectively, with profile locations shown on Figure 3. Four zones are identified in the cross-sections. According to the 1984 Supplemental Investigation, Zones 1 through 3 were considered to be stiff to very soft sump materials with the following characteristics:
• Zone 1 – Stiff clay and sandy clay soil with occasional sand near the ground surface; relatively high to moderate oil content; “appears to have been treated and recompacted.”
• Zone 2 – Firm to soft clay and silt; moderate to low oil content; may have been lightly treated and replaced; very compressible.
• Zone 3 – Very soft clay; untreated and uncompacted; water saturated; highly compressible.

Zone 3 materials reached as deep as 30 feet below ground surface (bgs) in some locations at the Site. The deepest area appears to be in the central portion of the property, mimicking somewhat the triangular shape of the Site itself. Zone 4, beneath the other zones, was believed to be possibly natural soil with some moderately compacted sump material near the top.

2.1.2 Geotechnical Investigation
GEOFON, Inc. (GEOFON) performed a geotechnical investigation to provide an evaluation of subsurface conditions at the Site in relation to the design and construction of a proposed business park development. This undated report appears to be the same document referred to in a 1986 Site Characterization Study (see Section 2.1.3). The investigation included drilling 12 borings (identified as B-1 through B-12 in the report and as GB-1 through GB-12 on Figure 3) to obtain soil samples for laboratory testing, visually classify soil types, ascertain the level of soil contamination, and confirm the depth of sump materials. Data from the previous geotechnical studies (see Section 2.1.1) were also incorporated in the preparation of the report.

Based on the results of the investigation, the greatest amount of sump materials (approximately 75,000 cubic yards [yd3
]) was found to be distributed in a zone
approximately 450 feet long, 300 feet wide, and 15 feet thick in the south-central portion of the Site. Another large triangular-shaped body of unprocessed sump material (approximately 7,000 yd3
and 7 to 10 feet thick) occurs in the northernmost corner of the Site. The very soft, unprocessed sump materials were found to be at the base of the sump (below 24 to 34 feet above mean sea level [msl], approximately 20 to 30 feet bgs). Together with other smaller pockets of unprocessed sump material, the total volume of unprocessed sump material at the Site was estimated to be 80,000 to

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Final Remedial Investigation Report LFR Inc.
100,000 yd3. Combined with lightly and moderately processed sump materials, the total volume of all sump fills was estimated at between 390,000 and 490,000 yd3 .

Sump materials were found to consist primarily of mud similar to clayey soils, mixed with highly variable amounts of salty water (brine) and oily wastes. Shallow groundwater was encountered at 8 feet bgs in one boring (GB-4). This was believed to be a localized perched condition because native sands at greater depths were not saturated and no other borings encountered perched groundwater.

GEOFON concluded that surface conditions at the time were not suitable for supporting structures on shallow foundations. The sump materials have highly variable engineering properties and are too compressible for supporting structures or fills. They would be suitable, however, once moisture-conditioned and compacted.

An isopach map of the sump material is presented as Figure 7.

2.1.3 Site Characterization Study
Jaykim Engineers, Inc. (Jaykim) and GEOFON conducted a Site Characterization Study for Statewide Investors, Incorporated, in October 1986. Twelve borings were drilled, and soil samples were collected from the borings for geophysical properties and chemical analysis. The borings were subsequently converted to gas monitoring probes, and gas pressures and lower explosive limit (LEL) levels were monitored. These boring locations are labeled as GB-1 through GB-12 on Figure 3, and are the same borings referred to in the GEOFON report (see Section 2.1.2).

Soil Results
The soil at the Site was characterized into six types, based on physical characteristics:
• Type 1 – low to medium oil content in a dark silty or sandy clay • Type 2 – medium to high oil content, with some samples showing liquid oil, in a black, silty to sandy clay
• Type 3 – extremely high oil content in a toothpaste-like consistency • Type 4 – very low oil content in a dry blue clay
• Type 5 – very low oil content in a dry gray sand
• Type 6 – none to very low oil content in a brown silty sand Analytical results included concentrations of TPH ranging from no detection (Type 6) to 75,800 milligrams per kilogram (mg/kg; Type 3) and lead up to 444 mg/kg (Type 3). Benzene and xylenes were detected at concentrations up to 3.0 mg/kg (Type 3) and 28 mg/kg (Type 2), respectively. Tables and figures are not available for this report; therefore, the location and distribution of contaminants is not known.

May2709 CRG Former Oil Operators North Site Final RI Rpt.doc:CTS Page 5 274
Intentionally Blank
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EXHIBIT 3
276

Tilly Hinton, PhD
Independent Scholar and Curator
229 S Westlake Ave Apt 206
Los Angeles CA 90057
[email protected]
Amy Harbin
Planner, Development Services Department
City of Long Beach
LBDS‐EIR‐[email protected]
12 April 2021
Dear Ms Harbin,
712 Baker Street Initial Study for CEQA Process
I am writing to comment on the Initial study for CEQA on the 712 Baker Street parcel, also known as the Long Beach RiverPark Residential Project.

I am an independent scholar and the founder/curator of Los Angeles River X.1 I have over a decade of
international research and community engagement expertise in river landscapes and their complex interrelationships with surrounding communities, particularly the Los Angeles River. On that basis, I make the following comments on the Initial Study. I look forward to seeing them addressed in the forthcoming Draft EIR.

Adverse effect on habitat
Considering the substantially altered state of the Los Angeles River and the commitments made at city, regional, county, and national levels regarding its revitalization, it is clear that the EIR will have to robustly consider how the proposed development will ‘have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species’ (p. 23) and also the dire impact of eliminating any possibility that the 20 acre site could immediately or in the future become public open space. There are at least 124 sensitive species on the site and in the immediate area, 23 of those threatened or endangered (p. 26). Safe habitat is essential for these threatened, endangered and otherwise at‐risk species. To say that ‘the Project Site consists of disturbed vacant land surrounded by existing residential development and urban infrastructure’ (p. 27) hides the ecologically significant impact on the entire watershed of protecting this site from development. The Letter from the Department of Fish and Wildlife has particular points which I look forward to seeing addressed in the EIR, including a recommendation that replanting be at a 3:1 ratio for removed native trees. It would be a mistake to conceptualize empty lots as devoid of ecological values or habitat, as evidenced by the finding of Burrowing Owls (Athene cuniculara) – a California Species of Special Concern – in empty lots a mile north and immediately adjacent to the Project site. The removal of ‘some old foundations, roads, and pipes [that] are still present on the site’ could well destroy habitat for owls.2
I note an error on p. 75 in relation to habitat and impacts on plant and animal communities. It is marked as both ‘Less Than Significant Impact with Mitigation Incorporated’ and ‘Potentially Significant Impact’. I trust the EIR will treat this as the latter.
1 https://www.instagram.com/lariverx   2 https://files.ceqanet.opr.ca.gov/267919‐1/attachment/HuhVoMY0sv‐ 44efzmLNS4ZIdpnZaKIZTWvNmPIsKS9FIfnvgsgWhh89isXpnQT4Y4uBoPeSsdvZhAUbS0 277

Air quality
As well as considering the air quality impacts of the proposed development (p. 20), the EIR process must adequately consider the ethical and public health implications of knowingly moving several hundred new residents into an area known to have catastrophically poor air quality already. Locating a large and dense residential development in an area known as the Diesel Death Zone, with residents at high risk of adverse health outcomes including cancer, asthma, and diabetes, needs rigorous environmental and ethical appraisal.

Cumulative Impacts
When the EIR considers ‘impacts that are individually limited, but cumulatively considerable’ (p. 75) please ensure that the following themes are fully elucidated: equestrian culture, public open space, environmental injustice, housing affordability, air quality, and traffic.

Density
The Initial Study cites the proposed density of 14.6 dwelling units/acre (p. 9) but does not compare this to the existing density in the immediate neighborhood, or of West Long Beach. For the Draft EIR to adequately scope the impact, these comparisons will need to be included.

Flooding
The Initial Study indicates that the project site is not within a risk zone for a 100‐year or a 500‐year flood (p. 50). I understand that FEMA have been remapping stretches of the LA River to upwardly revise the flood risks. The EIR will need to investigate whether there have been or are likely to be forthcoming changes to the thirteen‐year‐old mapping that is currently published by FEMA for the area.

The channelization of the Los Angeles River was made necessary by developers building carelessly in the flood plain, and it seems unfortunate to repeat this behavior some 90 years on, as this development seeks to do. Surely we have learned something since 1938? As a historian, I can’t help but think of how history has an ominous way of repeating itself, and I trust that the City of Long Beach won’t put people in harm’s way, as in the first decades of the twentieth century when the flood ravaged river destroyed residential, commercial, and industrial sites that had been the wrong developments in the wrong places.

Further, I understand there has been litigation in recent years relating to flooding in the area, and this should be investigated and referenced in the EIR.

Groundwater recharge
The assertion that there will be a Less Than Significant Impact in terms of ‘groundwater supplies or interfere[nce] with groundwater recharge’ (p. 48) is questionable and needs attention in the draft EIR.

Likewise the document asserts that the creation or contribution of runoff water would be ‘less than significant’ (p. 52).

Is it true that in such a densely built development that the site is ‘38 percent pervious’ (p. 48), even though it is entirely dominated by streets and buildings? The movement of water, and its biofiltration, appears not to be for aquifer recharge but rather expulsion from the site via the stormwater system into the LA River and out to the ocean. This wastage of water is not sensible nor justifiable in our drought‐prone climate. 278

Designing homes and the clubhouse area to have rainwater capture and/or greywater reuse was not mentioned anywhere in the Initial Study. It must be considered in the EIR and in the City’s deliberations.

In light of water scarcity in the region, which is only increasing with climate change, urban and architectural design can and must do their part to lessen our water footprint.

I am glad to see sufficiency of ‘water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years’ categorized as a potentially significant impact (p. 71) and I trust that groundwater recharge, rainwater capture and/or greywater reuse will be adequately incorporated into the project design.

Historic significance
The Initial Study comments that ‘according to the Long Beach General Plan Historic Preservation Element, the Project Site does not contain historic resources and is not in a historic district’ (p. 16, also p. 29) and yet it has a rich and materially documented equestrian history that spans back to the Spanish and the Rancho periods in our history, and remains as living history every day in Long Beach. Also, as noted, Native American historical significance must be robustly investigated and protected, through the EIR process.

Horse Overlay District
The proposed removal of the Horse Overlay District (p. 13) – a distinctive and essential element of Long Beach’s urban fabric – needs extensive attention in the draft EIR. My strong opinion is that the Horse Overlay must not be removed. My request is that the draft EIR fully address the following:
 the history of Horse Overlays in Long Beach, including the EIR that was part of the overlay establishment in the 1970s, and also any relevant legal proceedings  how many of the original six overlays/equestrian communities remain intact and what the cumulative impacts would be to removing this one, in terms of the land use character of Long Beach, and the protection of Long Beach’s living equestrian history  the density allowed under a Horse Overlay compared to the density of the proposed project (I understand it is approximately 4 homes per acre, but I have not seen documentation of this)  effects of the removal of the Overlay, and the construction of the housing development on both the immediate equestrian community with open space and the trail, as well as linear connectivity for horses and their riders between Long Beach equestrian districts, and indeed into the San Gabriel River, the Rio Hondo, and north to Atwater and Burbank equestrian neighborhoods
Land Use
It's not just the Horse Overlay District under threat. As recently as late 2019 in the City’s 2040 General Plan, the land use designation for this area was affirmed by the City as Founding and Contemporary Neighborhood (FCN) and Open Space (OS)  (p. 4). The current zoning from Commercial Storage (CS) and Single‐Family Residential Standard Lot (R‐1‐N) would be changed to residential Planned Unit Development (RP) and Council would waive height restrictions. Other approvals forecast in the Initial Study include Vesting Tentative Tract Map and a Street Vacation ‐ meaning the complete or partial abandonment or termination of the public right to use a street, highway, or public service easement ‐ to enable the development to proceed
Given all of this, I challenge the appropriateness of the Less Than Significant Impact rating given regarding any ‘conflict with any land use plan’ (p. 55). I would also ask that the consultants ensure plain 279

English language explanations of technical terms such as Vesting Tentative Tract Map and Street Vacation so that lay readers like me can be fully aware of the meaning and implications.

The City made a promise in an undated recent document that FCN constitutes 'more than 34 percent of the City’s land area and will not be changed' [emphasis added].3 The Initial Study suggests the City would
be breaking this promise by approving the proposed development.

Park Space
Detailed analysis about access to parkland open space will be important in the EIR, and I ask the preparers to ensure that analysis is more nuanced than at a whole‐of‐City level. West Long Beach is substantially underserved in terms of open space, and overserved in terms of environmental injustices.

For this reason, please ensure that the EIR analysis addresses West Long Beach in particular as well as referencing city wide statistics. Can the EIR please calculate the impact of 624 new residents on West Long Beach’s current park ratio, which I believe is 1 acre per thousand residents? Given the open space deficits that exist in West Long Beach, the addition of 624 residents and the provision of 5‐acres of recreational open space (p. 66) is insufficient.

The EIR needs to systematically document past promises made in planning documents and elsewhere about this land parcel and others in terms of creating public open nature space .

Plant palette
The planting list for the condominium area does not indicate any intention of the developer to use a native plant palette. Instead it specifies Tipu Tree, Purple Orchid Tree, Magnolia, Marina Arbutus, Australian Wouldow, Brisbane Box, New Zealand Christmas Tree, Chanticleer Pear, Crape Myrtle, and Majestic Beauty (p. 13). The developer needs to design with a commitment to native plants, at a minimum adhering to the standards in the Draft Los Angeles River Master Plan of at least 85% being native to the LA River watershed and no more than 15% being non‐native, non‐invasive plants.

Population growth
This project would by definition ‘induce substantial unplanned population growth in an area, directly (for example, by proposing new homes and businesses)’ and yet this is ascribed a ‘Less Than Significant Impact’ rating (p. 60). It will not meet the City’s own Founding and Contemporary Neighborhood (FCN) General Plan Land Use designation per the City’s recent 2040 General Plan.

It is too blunt, some may even say disingenuous, to use a city‐wide thirty‐year growth projection to make the magnitude of this development look smaller than it really is.

Ascribing this point a ‘Less Than Significant Impact’ appears to be in error and needs to be corrected.

Public Engagement
I ask the City and the consultants to all they can to facilitate engagement of the general public with the EIR process, accommodating linguistic diversity, socioeconomic status, education, as well as cultural and social capital. Environmental injustices disproportionally impact disadvantaged, minority, and 3 http://www.longbeach.gov/globalassets/city‐news/media‐library/documents/lb‐general‐plan‐misconceptions 280

marginalized communities and the City has a responsibility to address this in the current CEQA process, and in general. Outreach initiatives should be documented in the EIR.

Scenic vista
I disagree with the assertion that the development will have a less than significant impact on a scenic vista (p. 15). The River is designated as ‘a scenic route as it provides a viewshed that is worthy of protection and enhancement’ (p. 16) and no convincing argument is made that the addition of 227 buildings in a jumble of high‐density Spanish Colonial, Italianate, and Santa Barbara architectural styles ‘would not substantially alter the existing views along the Los Angeles River’ (p. 16). The Los Angeles River is internationally and locally iconic, and the viewshed needs not only to be protected but also enhanced.

Traffic
I note that the Department of Transportation has stated several strong concerns about the development in terms of adverse traffic outcomes.4
I share these concerns and look forward to seeing them addressed in the EIR. The addition of at least 511 vehicles (p. 9) to the neighborhood needs to be addressed and mitigated.

Urban Heat Island
The density and character of the development looks as if it will contribute substantially to urban warming, an increasing problem in the face of climate change. This needs to be addressed in the EIR and mitigated in the site design.

In conclusion, the highly developed/degraded nature of a site is often used by EIR preparers to craft an illusion of the development being unproblematic because it is proposed on land already substantially altered, a brownfield not worthy of environmental protections. This is a paradigm that is philosophically and practically unviable, particularly in hyper urban landscapes such as those along the Los Angeles River. The character, scale, and function of the proposed development is vastly unsuitable for the site, particularly in light of the draft Los Angeles River Master Plan, the Lower LA River Revitalization Plan, and RiverLink.

When the EIR proposes alternatives, as per CEQA Guidelines, I hope that an environmentally superior alternative to the project or its location will include the possibility of the land parcel being protected as public green space, and that the developer may be encouraged to build in a more suitable manner on a more suitable site. The protection of this land parcel as open green space would be game‐changing for Long Beach, and the entire river. I trust the City and the CEQA process to protect the river, the 712 Baker Street parcel, and the adjacent community.

Best regards,
Tilly Hinton, PhD
Cc.   Mayor of Long Beach
Long Beach Councilmembers
4 https://files.ceqanet.opr.ca.gov/267919‐
1/attachment/4QOQSHrPrjnVcJJSROwxKc6L0pQjyOfxD6wbw9oGvt8kXNPQ6fqezcNHe6vT1my_BU7HMbiSKRgcnzjO0 281
EXHIBIT 4
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OPEN SPACE AND RECREATION ELEMENT

OF THE GENERAL PLAN
OCTOBER 2002

PREPARED BY DEPARTMENT OF PLANNING AND BUILDING

AND DEPARTMENT OF PARKS, RECREATION AND MARINE

CITY OF LONG BEACH
Reprinted 2005
283
284

OPEN SPACE AND RECREATION ELEMENT
City of Long Beach General Plan
Mayor and City Council
Beverly O’Neill, Mayor
Frank Colonna, Vice Mayor, 3rd District
Bonnie Lowenthal, 1st District
Dan Baker, 2nd District
Dennis Carroll, 4th District
Laura Richardson-Batts, 6th District
Tonia Reyes Uranga, 7th District
Robert Webb, 8th District
Val Lerch, 9th District
Planning Commission
Charles Winn, Chair
Nick Sramek, Vice Chair
Thomas Fields
Charles Greenberg
Edward Ludloff
Lynn Moyer
Greg Whelan
City Staff
Gerald R. Miller, Acting City Manager
Eugene J. Zeller, Director of Planning and Building
Phil T. Hester, Director of Parks Recreation and Marine Dennis Eschen, Superintendent of Park Planning and Development Angela Reynolds, Advance Planning Officer
Patricia A. Garrow, Senior Planner, Project Manager
Larry Rich, Planner
Carolynn Montgomery, Secretary
Citizens of Long Beach
A special Thank You is extended to the many conscientious members of the public who participated in the creation of this document.

Adopted by the City Council on October 15, 2002
285
Pages Intentionally Omitted
286

OPEN SPACE AND RECREATION ELEMENT
TABLE OSR – 7

4. Open Space for Outdoor Recreation
Implementation Programs
Program Responsibility Funding
Source
Time Frame

4.1 Inventory and analyze City-owned
oil drillin
can be
parks a

4.1, 4.11 & 4.14)
City of Long Beach
erties and
Technology Services
City of Long
Fund
Within one year
lands, blighted properties, and former
g sites to identify parcels that
converted to open space or
nd recreation uses. (Policies:

Departments of Planning
& Building, Community
Development, Oil
Prop
Beach Water
Department
and General
of the adoption
of this chapter

4.2 Adopt a citywide ratio of eight
f parkland for each 1,000
ts. (Policy: 4.1)
Long Beach City Council Not applicable Approve ratio
with adoption of
this chapter
view and revise as necessary City of Long Beach City Federal a acres o
residen

4.3 Re
the Park Impact Fee Ordinance in order
and rec
Council, City Attorney,
&
Building Departments
nd
State grants,
Beach Park
Impact Fee
Within two years
of the adoption
to achieve the community’s open space
reation goals. (Policy: 4.1)
Parks, Recreation &
Marine, and Planning
City of Long of this chapter

4.4 Formally dedicate all City owned
nd designate them to be
ed in perpetuity. (Policies: 4.2,
Long Beach City Council,
City Attorney, Parks,
Recreation & Marine, and
City of Long
Beach Genera
Fund
Within six
parks a
preserv
l months of the
adoption of this

4.4, 4.5, & 4.8) Planning & Building
Departments
chapter

4.5 Require that any conversion of
d be replaced amenity-for-
and acre-for-acre at a 2:1 ratio.
re of replacement land shall be
Long Beach City Council,
City Attorney, Parks,
Recreation and Marine,
and Planning
City of Long
Beach General
Fund
Upon adoption
parklan of this chapte
amenity
One ac
located in the park service area where
e land was converted and an
dditional acre of replacement land
hall be located in a park service area
eeding parkland – as determined by
e Recreation Commission.
and
Building Departments
r
th
a
s
n
th

4.6 Integrate the provisions of the
epartment’s Strategic Plan for the
ocially, economically and
nvironmentally sustainable
evelopment of the City's park and
creation system, with short and longrm Capital Improvement Plans. olicies; 4.6, 4.7, 4.8 & 4.14, 4.15)
City of Long Beach
Parks, Recreation &
Marine, Public Works,
and Financial Mgmt.

Departments in
conjunction with the City
Manager’s Office
Federal, State
and regional
grants, City of
Long Beach
General Fund
Within two years
of the adoption
of this chapter
D
s
e
d
re
te
(P

4.7 Develop a long-term funding
echanism for park and open space
cquisition and development.
(Policies: 4.1, 4.5, & 4.14)
City of Long Beach
Parks, Recreation &
Marine, Public Works,
Financial Mgmt.

Departments in
conjunction with City
Manager’s Office
To be
determined
Within two years
of the adoption
of this chapter
m
a
City of Long Beach 27 General Plan
287
EXHIBIT 5
288
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augusT 2015 ctivities
Decreased Lead Poisoning
Decreased Health Disabilities
Improve Public Health
Health Services
Increased Open Space (with Roadway Reconguration)
Major Roadway Improvements
Lighting
Reduced VMT
Safety for Pedestrians / Transit Riders
Transit Improvements
Lighting
Pervious Surface
Open Space Acreage Added
Park Improvem
The WesT Long Beach LIVaBILITy ImpLemenTaTIon pLan ents and Expansions Access to Open Spac
The WesT Long Beach LIVaBILITy ImpLemenTaTIon pLan e / Schools / Parks Reduced VMT
Increased S
The WesT Long Beach LIVaBILITy ImpLemenTaTIon pLan afety Pedestrian
+
Bike
Improvements
Access
The WesT Long Beach LIVaBILITy ImpLemenTaTIon pLan to
Open
Space
/
Schools
/
Parks
Reduc
The WesT Long Beach LIVaBILITy ImpLemenTaTIon pLan ed
VMT
/ Increase in
Walking
Safet
The WesT Long Beach LIVaBILITy ImpLemenTaTIon pLan y for Pedestria ns
/
Tra
nsit Riders
Lig
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The WesT Long Beach LIVaBILITy ImpLemenTaTIon pLan in
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The WesT Long Beach LIVaBILITy ImpLemenTaTIon pLan ni g P
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The WesT Long Beach LIVaBILITy ImpLemenTaTIon pLan ased Tree
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august 2015
city of Long Beach Team » Amy Bodek, AICP, Director, Long Beach Development Services » Angela Reynolds, AICP, Deputy Director, Long Beach Development Services » Brant Birkeland, AICP, Planner, Long Beach Development Services » Ira Brown, Planner, Long Beach Development Services
» Christopher Koontz, AICP, Advanced Planning Offi cer, Long Beach Development Services » Derek Wieske, Assistant City Engineer, Long Beach Department of Public Works » Nathan Baird, Mobility & Healthy Living Programs Offi cer, Long Beach Department of Public Works » Meredith Elguira, Capital Projects Coordinator, Long Beach Department of Public Works » Heather Tomley, Director of Environmental Planning, Port of Long Beach » Renee Moilanen, Manager of Air Quality Practices, Port of Long Beach » Kirsten Berg, Environmental Specialist, Port of Long Beach » Jennifer Haith Farinas, AICP, Transportation Planner, Port of Long Beach » Lara Turnbull, Project Director, Long Beach Department of Health and Human Services » Cheryl Barrit, Policy, Planning and Prevention Bureau Manager, City of Long Beach » Offi ces of CD-7, Councilmember Robert Uranga
» Offi ces of CD-1, Councilmember Lena Gonzalez
consultant Team » Melani Smith, AICP, Meléndrez
» Amber Hawkes, AICP, Meléndrez
» Shannon Davis, Meléndrez
» David Koo, Meléndrez
» Abraham Sheppard, Meléndrez
» Tony Mendoza, Parsons Brinckerhoff
» Mark Briggs, Parsons Brinckerhoff
» Kekoa Anderson, Koa Consulting, Inc.
» Traci Gleason, Koa Consulting, Inc.
» Sumire Gant, Westbound Communications
» Erika Brooks, Westbound Communications
» Sean Daly, Iteris
credits
This Plan was funded through the generosity of the Long Beach Board of Harbor Commissioners. 291
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292
1 L VABLE L

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L VABLE L

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Livable West Long Beach (also referred to as
the West Long Beach Livability Implementation
Plan) presents a comprehensive approach for
achieving the community’s vision for healthy,
vibrant, attractive and safe neighborhoods.

Livable West Long Beach identifies, prioritizes, and strategizes the implementation of projects and initiatives that will provide a variety of neighborhood benefits including enhancements to the community’s physical environment, improved accessibility and connectivity, a cleaner environment, a vibrant economy, and improved community health. Over the last several years, various City planning efforts have proposed numerous physical, environmental, and health-related projects and initiatives – some of which have been executed, but many of which have not. Aided by valuable feedback from community members and stakeholders, Livable West Long Beach coordinates these already-proposed projects and initiatives into a comprehensive implementation program composed of three strategies for “Livable Neighborhood Connections”, or LiNCs. The LiNCs will be supported by health services, education, and other livability programs that have been previously funded by the Port. The Plan also identifies funding mechanisms for implementing these projects and strategies.

What is Livability?
A community can be perceived as livable based on many factors including environmental quality, community health, safety, the quality of its built environment, and economic vitality. A livable community encourages walking, bicycling, using public transit, and exercising outdoors, and provides economic and social opportunities for all community members. See the pages that follow for more information regarding the various elements of livability that are assumed in this Plan.
chapter 1: Introduction
Livable west long beach Engaging the community
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Long Beach mobility element update (city of Long Beach, 2013) » Establishes the vision, goals, policies, and implementation measures to enhance the City’s local and regional transportation networks
» Goals include:
» Balance the needs of all roadway users, providing accessible and comfortable streets for transit riders, pedestrians, bicyclists, and motorists » Develop context-sensitive street classifi cations
» Ensure multi-modal connectivity and accessibility
» Encourage active transportation (bicycling and walking) Long Beach capital Improvement program (city of Long Beach, 2014-2015) » Outlines the city’s short range strategic capital investment program for fi scal year 2014-2015
» The programs are organized by the type of capital investment: Marinas, Beaches & Waterways, Parks and Recreation, Marine, Public Facilities, Storm Drains, Street Rehabilitation, Transportation Enhancements, Airport, Gas and Oil, Harbor, Successor Agency (SA), and Water.

Long Beach open space & recreation element (city of Long Beach, 2002) » Establishes the vision, goals, policies, and implementation measures to address the need for more high-quality and accessible open space within the City, and to encourage enhanced opportunities for both outdoor and indoor recreational activities.
» Goals include:
» Open Space for the Preservation of Natural Resources
» Open Space for the Managed Production of Resources
» Open Space for Health and Public Safety
» Open Space for Outdoor Recreation and Recreation Facilities Long Beach housing element (city of Long Beach, 2013)
» Establishes the vision, goals, policies, and implementation measures to guide development and programs in order to ensure healthy, stable and attractive neighborhoods, housing affordability, and increased housing availability. » Goals include:
» Ensure a strong network of healthy, safe neighborhoods in Long Beach. » Encourage strong community leadership, collaboration, stewardship and public participation
» Provide healthy neighborhoods where diversity is celebrated, arts and cultural programs fl ourish, services are accessible, and all community members have tools to improve the quality of their lives » Support neighborhood efforts to create beauty and pride by removing blight and providing high-quality public infrastructure, parks, and public facilities » Improve availability of housing by addressing declining homeownership, neighborhood stability and overcrowding
The yards
» Community proposal for the second largest park in Long Beach while relocating some of the most impactful infrastructure away from the community. Included in this proposal is a concept for converting the segment of the Terminal Island Freeway between Pacifi c Coast Highway and Willow Street, controlled by the City of Long Beach, from a freeway to a local road and open space buffer goals of relevant plans and policies consulted
intRoDUction LivabLe west Long beach
295
5 L VABLE L

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san pedro Bay ports clean air action plan (caap) (port of Long Beach and port of La, 2006, updated 2010)
» Seeks to reduce health risks associated with air pollution from port-related ships, trains, trucks, terminal equipment and other harbor craft » Includes long-term goals for emissions and health-risk reductions for both the San Pedro and Long Beach ports
port of Long Beach green port policy (port of Long Beach, 2005) » Provides a guide to decision making and establishes a framework for environmentally-sensitive port operations
» A comprehensive set of guidelines for improving air, water and soil quality, protecting wildlife habitat, encouraging community engagement, and ensuring sustainable practices
Long Beach river Link (city of Long Beach parks, recreation & marine, 2007) » Identifi es areas for the acquisition of additional open space. The primary goal is to provide eight (8.0) acres of recreational open space for each 1,000 residents of the city. To achieve this, approximately 1,100 acres needs to be added to the current inventory of 2,855 acres
» Identifi es ways to connect city residents to the Los Angeles River. This is oriented towards improving physical access to the bicycle and pedestrian trails on the levees and open spaces along the River
» Identifi es locations along the Los Angeles River where the native habitats could be restored
» Provides guidance to Improve the aesthetics of the Los Angeles River and the City community Livability plan - I-710 corridor neighborhoods (city of Long Beach public Works, 2008)
» Addresses impacts that area neighborhoods are experiencing from the operations of the I-710 freeway
» Identifi es community assets along the I-710 Freeway corridor » Includes 58 projects and 15 Livability Plan design concepts to illustrate livability improvements in specifi c locations along the corridor
healthy communities policy (city of Long Beach, 2014) / health department programs » Includes policies for the built environment, health and wellness, and health equity and safety
» Includes a description of existing City policy documents and programs that affect community health
additional policy consulted
» Port of Long Beach Community Mitigation Grant Programs LivabLe west Long beach intRoDUction
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Identify Existing Plans and Policies
Review of existing plan and policy documentation
and identification of the goals of each. The following
plans and policies were consulted:
» Long Beach Mobility Element Update
» Long Beach Capital Improvement Plan
» Long Beach Open Space & Recreation
Element
» Long Beach Housing Element
» The Yards Plan
» San Pedro Bay Ports Clean Air Action Plan
(CAAP)
» Port of Long Beach Green Port Policy
» Long Beach RiverLink
» 710 Community Livability Plan
» Long Beach Healthy Communities Policy
Identify Livability Criteria
Of the goals that were pulled from the plans and
policies listed above, special consideration was
given to the elements of livability that each goal
addressed. Groupings of criteria were created,
and three overarching categories of livability rose
to the top: Environment/Health, Economy, and
Community/Safety/Access.

Identify Existing Projects and Programs
Following the plans reviewed to establish criteria,
only City adopted plans were reviewed to identify
projects and programs to be included in the Livable
West Long Beach Plan. Of the adopted plans listed
above, projects were lifted from the following:
» Long Beach Mobility Element Update
» Long Beach Capital Improvement Plan (2014-
2015)
» Long Beach Open Space and Recreation
Element
» Long Beach Housing Element
» Long Beach RiverLink
» I-710 Community Livability Plan
» Long Beach Healthy Communities Policy
Step 1 of the evaluation process involved identifying a set of previously adopted plans and policies in West Long Beach. As discussed in Chapter 1, the ten plans and policies that were relevant to this effort were distilled into a set of goals. Using these goals, specific projects and programs that reflected the elements of livability (as shown in the Livability Wheel - Figure 1.1) were lifted from these plans, livability criteria were extracted, and a master list of projects and programs was created. Based on community input, the programs that have been included in the past by the Port of Long Beach Community Mitigation Grant program were also added to the list.

Step 1: Identify Related Plans & Projects/Programs
Livable west long beach Livable neighborhood connections - LiNCS 298
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TRANSIT IMPROVEMENTS

PROJECT NAME ORIGIN
Primary Transit Corridor - Pacific Coast
Highway (Santa Fe Ave to Daisy Ave) Mobility Element
Primary Transit Corridor - Pacific Coast
Highway (Daisy Ave to Long Beach Blvd) Mobility Element Primary Transit Corridor - Willow Street Mobility Element Primary Transit Corridor - Long Beach Blvd
(north of Willow Street) Mobility Element
Primary Transit Corridor - Long Beach Blvd
(south of Willow Street) Mobility Element
Primary Transit Corridor - Broadway /
Pacific Avenue Mobility Element

PARK IMPROVEMENTS & EXPANSIONS

PROJECT NAME ORIGIN
Drake Park Greenbelt and Improvements
CIP 2015,
Livability Plan,
and Riverlink
Tanaka Park Greenbelt and Park Expansion Livability Plan Silverado Park Improvements CIP 2015 & Livability Plan Del Mar Park Livability Plan &
Riverlink
Wrigley Heights Park Expansion and River
Connector
Livability Plan &
Riverlink
14th St Park Improvements and Expansion Livability Plan

MAJORROADPROJECTS

PROJECT NAME ORIGIN
I-710 Freeway Terminus Realignment Mobility Element
Long Beach Blvd / Wardlow Rd and I-405
Ramps Mobility Element
Long Beach Blvd. Class III Bikeway Mobility Element
15th Street - Bike Boulevard Mobility Element
Alamitos / Shoreline Dr. (Improved Access) Mobility Element Veteran’s Park / Blue Line Bikeway Livability Plan
Wardlow Blue Line Station Park and Ride Mobility Element Willow Blue Line Station Park and Ride Mobility Element Blue Line Transit Signal Priority & Upgrades CIP 2015
Safety/Security » Community Watch
» Safe Routes to School
(SRTS)
Focus on Community » Community Garden
Program
» Neighborhood Clean-Up
Assistance Program
» Urban Forestry Program
Health Services » Child Health Disability
Prevention (CHDP)
» Childhood Lead
Poisoning Prevention
Program (CLPPP)
» Community Health
Improvement Plan
» Lead Hazard Control
Program
Health and Education Activities » Asthma Life Skills
Academy for Adults
(ASLA)
» Community Asthma &
Air Quality Resource
Education (CAARE)
» Health Promotion and
Wellness Program
» Healthy Active Long
Beach
Programs
Greenhouse Gas Emissions Reduction » Native and Drought Tolerant Planting
» Urban Forest
» Energy-efficient
Outdoor Lighting
» Solar Thermal
Installation
» Solar Electricity
Generation
» HVAC Upgrades and
Boiler Replacement
Schools and Related Sites » Air Filtration System
Upgrades and Filter
Replacement
» Landscaping
» Windows and Doors
Replacement
Health Care and Senior Facilities » Air Filtration System Upgrades and Filter
Replacement
» Mobile Health Clinics
» Health Education and
Outreach
» Asthma Health
Services
» Health Worker Training

PROJECT NAME ORIGIN PROJECT NAME ORIGIN
Livable west long beach Livable neighborhood connections - LiNCS 300
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Linc strategy 2: north Zone
Figure 4.8
Within each project type (e.g. Streetscapes, Bicycle and Pedestrian Improvements), projects are listed in ranked order. The higher the number, the more impact the project will have on livability in West Long Beach.

Note: The project types are not listed in order of priority.

LivabLe neighboRhooD connections - Lincs LivabLe west Long beach

RANK PROJECT PROJECT DESCRIPTION ORIGIN BUDGET IN CIP

STREETSCAPES
1 Pacifi c Avenue Streetscape
Pedestrian and streetscape enhancements on Pacifi c Ave from Country Club Dr south to Wardlow Rd, including underpass improvements, lighting, trees, and signal at Pacifi c, to enhance Metro Station pedestrian access Livability Plan $20,000,000

BICYCLE AND PEDESTRIAN IMPROVEMENTS
2 Pacifi c Avenue Class II Bikeway
(segment north of Willow Street)
Class II bikeway along Pacifi c St (between Willow Ave and San Antonio Dr)
Mobility
Element
3 Daisy Avenue Bike Blvd
(segment north of Willow Street) Bike Blvd. proposed from Spring to Willow Mobility Element
4 Wardlow Streetscape
Improvements / 710 Overpass
Pedestrian and streetscape enhancements to Wardlow St. from Long Beach Blvd to Santa Fe (lighting, trees, etc.) Livability Plan 5 Spring Street Bikeway Mobility Element Proposed Bikeway Mobility
Element &
Livability Plan
6 Wardlow Streetscape
Improvements / 405 Overpass
Improvements to increase pedestrian safety along Wardlow, including the 405 underpass Livability Plan
7 Pacifi c Place Class I Bikeway Mobility Element Proposed Bikeway Mobility Element
8 Del Mar Greenbelt Ped/Bike Path
Design and construct greenway along Blue Line public right-of-way between Metro Willow and Wardlow Stations including walking and biking paths.

Mobility
Element $3,500,000
9 San Antonio Drive Class II
Bikeway
Construction of class II bikeway along San Antonio from Pacifi c to Atlantic Livability Plan
10 Del Mar Walking Trail - Los
Cerritos / River Connector
Improvements to existing path and green space that extends from Los Cerritos Park north to the Dominguez Gap wetlands to allow ADA access, and to provide long-term additional maintenance of and access to the connector.

Livability Plan
& Riverlink
11 Del Mar Bikeway Access
Design, construct, implement projects and programs to enhance the safety and viability of bicycle and pedestrian routes. Del Mar Bikeway access from L.A. River to 4600 Del Mar Avenue between L.A. River Trail.

CIP 2015 $10,462,799
12 Dominguez Gap and Ped/Bike
Bridge
New ped/bike bridge over the Los Angeles River to connect the LA River Bike Path to the Compton Creek Bike Path to minimize the use of Del Amo Boulevard as the only route over the Creek
Mobility
Element $7,000,000.00
13 Los Cerritos / Del Mar Pedestrian
Bridge
Improvements to existing pedestrian bridge near Los Cerritos Elementary
Livability Plan
& Riverlink

TRANSIT IMPROVEMENTS
14 Primary Transit Corridor - Long
Beach Blvd (north of Willow St)
Amenities to existing stops along PTC’s that could include solar-powered bus stop shelters and freestanding benches, security lighting, trash receptacles and crosswalk enhancements. BRT or high-capacity transit service is anticipated.

Mobility
Element
$5,000,000
for all PTC
Improvements
15 Wardlow Blue Line Station Park
and Ride
Develop increased vehicle capacity at Metro Blue Line stations park and ride facility to encourage ridesharing, transit use and multi-modal connectivity.

Mobility
Element
$10,000,000 (both
Willow/Wardlow)
16 Willow Blue Line Station Park
and Ride
Develop increased vehicle capacity at Metro Blue Line stations park and ride facility to encourage ridesharing, transit use and multi-modal connectivity.

Mobility
Element
$10,000,000 (both
Willow/Wardlow)

PARK IMPROVEMENTS AND EXPANSIONS
17 Del Mar Park Development of new park per River Link plan Livability Plan & Riverlink
18 Wrigley Heights Park Expansion
and River Connector
Expansion of Wrigley Heights park south of 405 as part of River Link; Potential City agreement with LA County to acquire land along the LA River
Livability Plan &
Riverlink

MAJOR ROAD PROJECTS
19 Long Beach Blvd / Wardlow Rd
and I-405 Ramps
This project includes ramp reconfi guration to improve connections to Long Beach Boulevard and reduce congestion at Pacifi c and Wardlow.

Mobility
Element $5,000,000
302
Linc strategy 2 description
LiNC Strategy 2, (also referred to as
the North Zone) is bound generally by
the City of Long Beach boundary to
the west, Del Amo Boulevard to the
north, Long Beach Boulevard to the
east, and Willow Street to the south.

This neighborhood is separated by the
I-405 freeway into distinct communities:

Upper Westside, Wrigley Heights, Los
Cerritos, and Bixby Knolls.

Improving crossings and access around
the I-405 freeway will encourage active
transportation and provide connections
for bicyclists, pedestrians, and transit
users alike.

New parks and expansions are also a
part of this plan, incorporating open
space and access along the LA River as
it crosses the I-405.
projects/programs
Additional projects and programs that
should be funded concurrent with the
projects in LiNC Strategy 2 can be
found on pages 46-48.

Streetscapes
Bike/Ped Improvements
Parks Improvements/Expansions
Transit Improvements
Major Road Improvements
Legend
LiNC 2 & 3 projects are shown in
muted colors for reference
Figure 4.9
LivabLe west Long beach LivabLe neighboRhooD connections - Lincs Santa Fe Ave Santa Fe Ave
Gale Ave
Delta Ave
28th St
Wardlow St
Wardlow St
23rd St
21st St
19th St
16th St
Cowles St
8th St
5th St
Hill St Hill St
Willow St
25th St
Anaheim St
Broadway
1st St
9th St
Long Beach Blvd Long Beach Blvd
Magnolia Ave
Pacic Ave Pacic Ave
Del Mar Ave
San Antonio Dr
Daisy Ave
Golden Ave
Daisy Ave
Atlantic A ve
Pacic Pl
Spring St
32nd St
34th St
Pacic Coast Hwy
I-405
I-710
LA River LA River
I-710
y
Pacic Ave
14 y
rd
Pacic Coast Hwy
17 18
3 4
5 6
19 8
9 10
11 13
12 15 1
2 14
7 16
Terminal Island Freeway
8 Ave
3 v
303
EXHIBIT 6
304
I-710 Corridor Neighborhoods

LONG BEACH CALIFORNIA
LivabilityPlan

COMMUNITY
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305
306
I-710 Corridor Neighborhoods

LONG BEACH CALIFORNIA
LivabilityPlan

COMMUNITY
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ACKNOWLEDGEMENTSLONG BEACH CITY COUNCIL MEMBERSBonnie Lowenthal, District OneTonia Reyes Uranga, District SevenRae Gabelich, District EightVal Lerch, District NineCOMMUNITY LIVABILITY PLAN WORKING GROUPSumire Gant, Department of Public WorksCITY COUNCIL OFFICESClaudia Escobedo, District OneBianca Román, District OneNiki Tennant, District OneRay Pok, District SevenCraig Carter, District EightLinda Ivers, District EightJonathan Kraus, District EightJerry Caligiuri, District NineJonda Matrone, District NineCITY STAFF MEMBERSDennis Th ys, Community DevelopmentRyan Grognano, Harbor DepartmentCarl Kemp, Harbor DepartmentHeather Morris, Harbor DepartmentJohn Pope, Harbor DepartmentArt Wong, Harbor DepartmentJeff Benedict, Health and Human ServicesMarlene Arrona, Long Beach Police DepartmentBilly Quatch, Long Beach Police DepartmentScott Robertson, Long Beach Police DepartmentDennis Eschen, Parks, Recreation and MarineAnna Mendiola, Parks, Recreation and MarinePat Garrow, Development ServicesSteve Gerhardt, Development ServicesScott Mangum, Development ServicesLee Mayfi eld, Development ServicesStephanie Reich, Development ServicesAldo Schindler, Development ServicesDavid White, Development ServicesPUBLIC AGENCIESKaren Heit, Gateway Cities Council of GovernmentsShirley Hsiao, Long Beach TransitDan Rosenfeld, Long Beach TransitSusan Ahn, Long Beach Unifi ed School DistrictCarri Matsumoto, Long Beach Unifi ed School DistrictRoy Choi, Los Angeles County Metropolitan Transportation Authority CONSULTANT TEAMMeléndrezMelani SmithSteve PattonRebecca FinnValerie WatsonDiverse Strategies for OrganizingTony Torres Irene PayanIteris / Meyer, Mohaddes and AssociatesLee WardCommunity Livability Plan Team Members 307
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COMMUNITY LIVABILITY PLAN for the I-710 CORRIDOR NEIGHBORHOODS > LONG BEACH CALIFORNIA i Table of ContentsGUIDE TO THE DOCUMENT………………………………………………………………………iiiPROJECT & PROCESS…………………………………………………………………………………1EXISTING CONDITIONS………………………………………………………………………………9CULTURAL NEEDS ASSESSMENT……………………………………………………………23THE COMMUNITY LIVABILITY PLAN………………………………………………………31APPENDIX 309
ii COMMUNITY LIVABILITY PLAN for the I-710 CORRIDOR NEIGHBORHOODS > LONG BEACH CALIFORNIA List of Figures & TablesFIGURE 1-1: PLAN AREA .................................................................................. 1FIGURE 1-2: VICINITY ......................................................................................2FIGURE 1-3: COMMUNITY LIVABILITY ISSUES AT MULTIPLE SCALES .............3FIGURE 1-4: PROJECT PROCESS ......................................................................4FIGURE 1-5: COMMUNITY STAKEHOLDER PRESENTATIONS MAP ...................5FIGURE 1-6: COUNCIL DISTRICTS WITHIN THE PLAN AREA .............................6FIGURE 1-7: ROUTE OF SITE TOUR ..................................................................7FIGURE 2-1: GENERAL PLAN LAND USE MAP ................................................ 10FIGURE 2-2: EXISTING LAND USE MAP ......................................................... 10FIGURE 2-3: EXISTING & PROPOSED MOBILITY OPTIONS .............................11FIGURE 2-4: TRANSIT RIDERSHIP ................................................................. 12FIGURE 2-5: AVERAGE DAILY TRAFFIC FLOW ................................................ 12FIGURE 2-6: MAJOR CORRIDOR STUDY HYBRID DESIGN CONCEPT .............. 13FIGURE 2-7: REDEVELOPMENT PROJECT AREAS ........................................... 19FIGURE 2-8: PROJECT IMPACT LOCATION MAP .............................................20FIGURE 3-1: CORRIDOR SUBAREAS ..............................................................23FIGURE 3-2: RESIDENTIAL LOCATIONS OF WORKSHOP PARTICIPANTS .......24TABLE 3-1: DEMOGRAPHIC CHARACTERISTICS - NORTH ..............................25TABLE 3-2: DEMOGRAPHIC CHARACTERISTICS - CENTRAL ...........................25TABLE 3-3: DEMOGRAPHIC CHARACTERISTICS - SOUTH ..............................26TABLE 3-4: DEMOGRAPHIC CHARACTERISTICS - WEST ................................26TABLE 3-5: RESIDENT COMMENT CATEGORIES ............................................27TABLE 3-6: CORRIDOR-WIDE WORKSHOP RESPONSES - CONCERNS ..........28TABLE 3-7: CORRIDOR-WIDE WORKSHOP RESPONSES - STRENGTHS .........28TABLE 3-8: CORRIDOR-WIDE WORKSHOP RESPONSES - CHANGES .............28TABLE 3-9: NORTH CORRIDOR CHANGES .....................................................29TABLE 3-10: CENTRAL CORRIDOR CHANGES ................................................29TABLE 3-11: SOUTH CORRIDOR CHANGES ....................................................30TABLE 3-12: WEST CORRIDOR CHANGES .....................................................30 FIGURE 4-1: COMMUNITY ASSETS ................................................................32FIGURE 4-2: CORRIDOR IMPROVEMENTS ....................................................36TABLE 4-1: CORRIDOR RECOMMENDATIONS ...............................................37FIGURE 4-3: NEIGHBORHOOD IMPROVEMENTS ...........................................40TABLE 4-2: NORTH CORRIDOR RECOMMENDATIONS ..................................45TABLE 4-3: CENTRAL CORRIDOR RECOMMENDATIONS ...............................47TABLE 4-4: SOUTH CORRIDOR RECOMMENDATIONS ..................................49TABLE 4-5: WEST CORRIDOR RECOMMENDATIONS ..................................... 51FIGURE 4-4: NEIGHBORHOOD CONCEPTUAL PLANS KEY MAP .....................52FIGURE 4-5: ARTESIA BOULEVARD SAFE ROUTE TO SCHOOL .......................53FIGURE 4-6: NORTH LONG BEACH TREE BUFFER ..........................................54FIGURE 4-7: SOUTH STREET PARKWAY ........................................................55FIGURE 4-8: WRIGLEY HEIGHTS RIVERLINK CONNECTOR, BUFFER AND PEDESTRIAN BRIDGE .......................................................................................56FIGURE 4-9: TANAKA GREENBELT AND TANAKA PARK EXPANSION .............57FIGURE 4-10: VETERAN’S PARK / BLUE LINE BIKE PATH ..............................58FIGURE 4-11: HILL STREET OPEN SPACE CONNECTOR ..................................59FIGURE 4-12: 14TH STREET PARK EXPANSION AND ANAHEIM STREET RIVER CONNECTION ...............................................................................................60FIGURE 4-13: OCEAN BOULEVARD GREENING .............................................. 61FIGURE 4-14: LIVABLE SCHOOLS CONCEPT ..................................................62FIGURE 4-15: ALLEY GREENING CONCEPTS ..................................................63 310
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COMMUNITY LIVABILITY PLAN for the I-710 CORRIDOR NEIGHBORHOODS > LONG BEACH CALIFORNIA iii Guide to the DocumentThe Plan that follows is organized into the following chapters:Chapter 1: Project & ProcessChapter One provides an introduction to the project, a description of the Plan area, a discussion of community livability as a concept and its specific application in the I-710 corridor in Long Beach, and a summary of the project process and components.Chapter 2: Existing ConditionsChapter Two summarizes the existing conditions within the Plan area, including land use, mobility options, transit and traffic. This chapter also includes summaries of the key existing state, regional, subregional and City planning efforts related to the corridor with the potential to impact community livability.Chapter 3: Cultural Needs AssessmentChapter Three summarizes the Corridor Plan area demographics. In addition to describing “who” the corridor is, it also describes “what” the needs and priorities are of corridor residents, with regard to livability issues, by category of issue, as expressed to the project team in the outreach conducted as part of this planning process.Chapter 4: The Community Livability PlanThe Plan chapter includes a compilation of community assets identified in the corridor area, as well as a set of recommendations relating to livability improvements that should be made corridor wide, and those that apply specifically to corridor neighborhoods. The regional context for livability issues is also touched on in this chapter. Finally, the Plan includes 15 Livability Plan design concepts developed to illustrate livability improvements that may be made in specific locations in neighborhoods throughout the corridor.AppendixThe Appendix, in a separate volume, incorporates the project schedule, Working Group meeting notes, comments from the Councilmember interviews, comments from the first round of community outreach presentations, a general list of comments as well as a categorized list residents made at the four Neighborhood Design Workshops, and a list of comments made at the three Design Review Meetings. 311
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COMMUNITY LIVABILITY PLAN for the I-710 CORRIDOR NEIGHBORHOODS > LONG BEACH CALIFORNIA v
Committing to develop and implement a Community Livability Plan for the I-710 corridor neighborhoods in the City of Long Beach is a natural outgrowth of a single crucial realization: neighborhoods within the I-710 corridor bear a disproportionate share of the negative impacts resulting from the operation of the I-710 Freeway and the Ports. Further, they receive few of the benefi ts derived from the $3 billion in goods that arrive through the two Ports and are transported through their neighborhoods. This Plan seeks to bring a better balance between residents’ exposure to environmental and health hazards, and the benefi ts and investments they want and need in order to maintain a healthy environment in which to live, learn, work and play. The I-710 corridor is part of a network of pathways for goods arriving from international markets and distributed to the rest of the United States. This corridor includes some of the most heavily used freeways, roadways and railways that are a part of the nation’s goods movement system. Yet we cannot lose sight of the fact that in this more than 16 square mile area of our City, all roads lead home. This corridor is home to over 190,000 of our City’s residents – nearly 40% of our total population. Nineteen of our parks and recreation areas are here. Twenty four of our City’s schools are in this corridor. The Los Angeles River corridor is a prominent feature here as well, with its linkages to the rest of the Los Angeles basin upstream for water, wildlife, and recreation. It will be critical to maximize the quality of life benefi ts to corridor neighborhoods from the developing network of RiverLink parks and greenbelts. We must be mindful that this corridor is a place for people – a place where people want a high quality of life and a healthy, prosperous and livable future. This is a future that the residents who call this corridor home deserve. 313
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1 LivabilityPlan

COMMUNITY
I-710 Corridor Neighborhoods
LONG BEACH CALIFORNIA Chapter One
INTRODUCTIONIn 2006 the City of Long Beach received a Caltrans Environmental Justice Planning Grant to develop a Community Livability Plan, an initiative to address quality of life issues for City neighborhoods that are aff ected by the I-710 freeway. A variety of public agencies, including the Gateway Cities Council of Governments, the South Coast Air Quality Management District and the Long Beach Department of Health and Human Services, have documented the impacts the I-710 has had on individuals who live adjacent to this active goods movement corridor. Th ese impacts—including traffi c, noise, emissions, air quality, as well as associated public health implications—are of considerable concern to the community and its leadership. Th e City therefore conceived of this project to identify and prioritize the community’s collective vision for livability improvements that can and should be made in I-710 corridor neighborhoods.With a focus on community involvement as a foundation for this eff ort, the City developed two primary goals for the Community Livability Plan:
• To work with the I-710 corridor neighborhoods to identify and develop plans to address the impacts they are experiencing from the operation of the I-710 freeway, and • To develop a series of action strategies and design solutions to improve the physical environment for residents in those neighborhoods PLAN AREATh e planning area for the Community Livability Plan is a 16.88 square mile zone that incorporates all public and private parcels and public rights of way located roughly within one mile of the I-710. Th e boundaries of the planning area are roughly Atlantic Avenue to the east, the Pacifi c Ocean to the south, and the City boundary line to the west and to the north. All or portions of twenty-nine different City neighborhoods fall within the Community Livability Plan planning area, as shown in Figure 1-1. Notable landmarks include the Los Angeles River, the Metro Blue Line, the western end of downtown Long Beach, the Port of Long Beach, and the 405, 91 and I-710 freeways. Figure 1-2 shows the City of Long Beach vicinity.

PROJECT & PROCESS EXISTING CONDITIONS CULTURAL NEEDS ASSESSMENT COMMUNITY LIVABILITY PLAN FIGURE 1-1: PLAN AREA
315
2 COMMUNITY LIVABILITY PLAN for the I-710 CORRIDOR NEIGHBORHOODS > LONG BEACH CALIFORNIA FIGURE 1-2: VICINITY

PLAN AREA
Los Angeles
Inglewood
Torrance
Lakewood
Westminster
Buena Park
Anaheim
Norwalk
Rancho Palos
Verdes
El Monte West Covina
Culver City
Long Beach
Compton
Gardena
Hawthorne
Huntington
Park
South Gate
Downey
Montebello
Whittier
Lawndale
Monterey Park
La Habra
Garden Grove
710
10 5
110
105
10 110
605
405
405
405
5 5
405
710
710
22 91
91 60
HISTORY AND BACKGROUNDTh e City of Long Beach Department of Public Works initiated the Community Livability Plan as an initial response to the outcomes of the I-710 Major Corridor Study (MCS) and the I-710 Locally Preferred Strategy (LPS). During the planning process for the MCS, extensive community outreach eff orts enabled residents to explore and voice specifi c areas of concern in their communities. In these meetings, the community overwhelmingly emphasized their two primary issues were health and air quality, as well as concerns with noise, safety, congestion and the expansion of the Port. Because of the community concerns that emerged from the outreach process for the MCS, the City decided to develop a plan that would build on the results from the community workshops, in order to address quality of life issues that can make impacted Long Beach neighborhoods more livable. Th e Department of Public Works sought and successfully obtained a Caltrans Environmental Justice Planning Grant, to develop the plan. Th e project was initiated in February of 2007, and was completed by January of 2008.It is important to note the Community Livability Plan is not a part of the I-710 MCS or the LPS for the I-710 Major Improvements Project. Current planning efforts related to the I-710 have been summarized and evaluated, and every eff ort was made to understand the overall impact that these plans and their affi liated objectives and policies could potentially have on neighborhoods within the Community Livability Plan area. However, the ultimate focus was directed to understanding the current strengths, weaknesses and priorities for change that are unique to every neighborhood that is located adjacent to the I-710, and the fi ndings within this planning eff ort will be forwarded for consideration in the development of the EIR/EIS for the I-710 Corridor.APPROACHTh e approach to this project was to identify the most important community assets that help build and maintain healthy neighborhoods, and to then use these assets as a framework for neighborhood design and planning. Th e team worked with community residents to understand their most important neighborhood issues and concerns, and correlated those issues with existing and proposed City projects and plans. Th is information was then used as a foundation for identifying possible future improvement projects and recommendations which can be implemented in the shortmedium- and long-term future. 316
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32 COMMUNITY LIVABILITY PLAN for the I-710 CORRIDOR NEIGHBORHOODS > LONG BEACH CALIFORNIA FIGURE 4-1: COMMUNITY ASSETS
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34 COMMUNITY LIVABILITY PLAN for the I-710 CORRIDOR NEIGHBORHOODS > LONG BEACH CALIFORNIA CORRIDOR-WIDE IMPROVEMENTSTh e City of Long Beach initiated this Community Livability Plan in part because of the many community concerns that emerged from the City’s outreach process for the I-710 Major Corridor Study. In order to follow through on, and continue the process of, community engagement around the I-710 corridor issues that began to emerge during the major corridor study, this planning process and its outreach component have been completed. Th e City recognizes that the community outreach around these issues to date has revealed signifi cant community concerns about the scope, form and impacts of any I-710 corridor improvements project to come. Th e set of corridor wide recommendations to follow in this section have been catalogued in order to provide input that is intended to infl uence the I-710 Major Improvements Project EIR/EIS, which was initiated early in 2008, and the mitigation measures that must be completed as part of the project. Corridor-wide recommendations are listed in Table 4-1.A number of categories of potential corridor-wide improvements have been identifi ed and mapped in Figure 4-2. Th ese categories of improvements are defi ned, described and in some cases conceptually illustrated below.Freeway Noise/Air Impact Zone Areas closest to the I-710 corridor, within a roughly 200 meter (650 ft.) distance from it, are most impacted by emissions and traffi c noise from the corridor. Mitigation measures should respond to the needs of individuals who live, work and go to school within this impact zone. Measures which may be implemented within this zone include providing indoor air fi ltration devices, a program which is already being test-piloted at Hudson Elementary School in west Long Beach. Th is program could apply in some form to public facilities such as schools and other community facilities, as well as to private residences and businesses. Providing incentive or assistance programs to install double-paned windows in schools as well as in private residences and businesses could also mitigate noise and air quality impacts in this zone. Finally, soundwalls must be implemented as part of any I-710 improvements project in order to reduce the noise impacts of the freeway on adjacent residences, schools and other public gathering places. Public art on soundwalls facing the neighborhoods should also be included, along with greening, to enhance the view of such buff ers.Hill Street Pedestrian Bridge Hill Street is home to several public schools and parks, as well as residential neighborhoods. It is bisected by the I-710 and the LA River corridor, and terminates at the Terminal Island Freeway. City plans have already identifi ed Hill Street as an open space connector from east to west through the corridor area. In order to facilitate this east-west connection, a pedestrian and bicycle only bridge should be considered for construction at this location as part of the I-710 major improvements project. While other locations within the City may be appropriate for separated pedestrian and bicycle crossings of the I-710 and LA River, this opportunity stands out, given the right of way width existing on Hill Street, the opportunity it presents as a major linkage to several public schools on the east and west sides of the corridor, and the benefi ts of providing an alternative to pedestrian and bicycle traffi c on both Pacifi c Coast Highway and Willow Street.

Goods Movement in California, introduced in 2005 and 2006. Th e goals of the Plan are to:
• Reduce emissions to 2001 levels by 2010;• Continue reducing emissions until attainment of applicable standards is achieved;
• Reduce diesel-related health risks 85% by 2020; and,• Ensure suffi cient localized risk reduction in each aff ected community. 320
All Roads Lead Home
CHAPTER FOUR > COMMUNITY LIVABILITY PLAN 35
I-710 Bridge and Overpass Improvements I-710 Bridge and Overpass Improvements Several I-710 bridges have been identifi ed as “early action items” of the I-710 Major Corridor Study. Th ese include the Shoemaker Bridge replacement, which is in design at this time. As bridge and overpass improvements and replacements are designed, and bridges are presumably widened, multiple modes of travel and transportation on them should be fairly considered, in order to facilitate residents’ travel from one side of the freeway and river to the other. Accessibility and safety for pedestrians and bicyclists must be a priority, with provision made for separated bike lanes, pedestrian lighting, wider and ADA compliant safe sidewalks and ramps, signage and possibly even public art elements.RiverLink Open Spaces Th e City of Long Beach is currently spearheading and securing funding for development of the RiverLink, a proposed system of open spaces, gateways and open space connectors that will strengthen the physical connections between the Los Angeles River and surrounding corridor neighborhoods and commercial and industrial districts. Th e RiverLink system is a vital part of the Los Angeles River corridor, and must be supported and enhanced by the I-710 Major Improvements Project. Future I-710 construction projects should be designed to avoid existing and future RiverLink plans and projects as well as avoid compromising access to and public enjoyment of the River itself at interchanges and other potential points of confl ict.LARIO Trail Th e Class I bike path, known as the LARIO trail, under the jurisdiction of Los Angeles County, runs adjacent to the Los Angeles River from the terminus of the Rio Hondo near Lynwood, through Long Beach, to the Pacifi c ocean. Although the bike path is constructed, suggestions have been made, in the RiverLink plan, and in the outreach conducted as part of this Community Livability Plan, to improve the trail by adding landscaping, seating, shade, signage and other wayfi nding measures, and by improving access to the trail from surrounding residential neighborhoods. Like the RiverLink park, greenway and connections system itself, the LARIO is a vital part of the Los Angeles River corridor in Long Beach, and access to it should be enhanced by the I-710 Major Improvements Project. However, in order to ensure that the LARIO trail is the community asset and recreation destination that it can and should be, it will also be critical to address the river corridor challenges and the homeless population that currently exists there. Residents have identifi ed this issue as a serious safety concern in the Community Livability Plan outreach process, and described it as a major impediment to their use and enjoyment of the LARIO trail. In fact, it was noted at a public workshop that without this issue being addressed, RiverLink may be instead perceived as “crimelink,” and the access and connections it provides may be unwelcome in corridor neighborhoods.I-710 Corridor Green Zone As noted above, areas closest to the I-710 corridor, within a roughly 200 meter (650 ft.) distance from it, are most impacted by it. Green zone improvements in these areas should include tree and landscape planting. Tree planting eff orts in this zone can play a role in reducing levels of ozone, PM10, nitrous oxide and sulfur dioxide, minimize the heat island eff ect, and provide visual and noise barriers between the freeway and neighborhoods. Other green mitigation measures, addressing capturing and cleaning storm water runoff , and groundwater recharge should also be considered in these areas.

I-710 Freeway Interchanges New or redesigned freeway interchanges, which will be part of the I-710 Major Improvements project, should incorporate cutting edge design approaches to address multi-modal transportation systems operating on adjacent neighborhood roadways, and to improve safety for trucks, automobiles, pedestrians and bicyclists.I-710 Streetscape and Street Improvements Th e I-710 Major Improvements Project will have an impact on the major streets that either bisect or run parallel to the freeway. Streetscape and street improvements include pedestrian and biking considerations that should be implemented as part of the I-710 freeway project. Street improvements should include, as appropriate, designated bikeways, landscaping, pedestrian lighting, ADA compliant sidewalks and ramps, signal and crosswalk improvements, public art, and comprehensive signage and wayfi nding to facilitate all modes of travel and transportation.

FOR MORE INFORMATIONI-710 Corridor Major Improvements Projecthttp://metro.net/images/I-710_newsletter.pdfLong Beach RiverLinkhttp://www.longbeach.gov/park/facilities/study.asp LARIO http://dpw.lacounty.gov/wmd/watershed/LA/History.cfm 321
EXHIBIT 7
322

LA RIVER
MASTER
PLAN
323
Pages Intentionally Omitted
324
PREPARED FOR:

LOS ANGELES COUNTY AND LOS ANGELES COUNTY PUBLIC WORKS
PREPARED BY:
325
LA RIVER MASTER PLAN 7

TABLE OF CONTENTS
SECTION I: INTRODUCTION
17 1. Executive Summary
20 Vision: The Reimagined River
22 Goal-driven Framework and
Plan Summary
24 Thriving in Place: Equity
in the LA River Master Plan
26 Questions about the LA River
and Watershed
32 Public Stewardship and
Implementation
34 How to Use This Document
35 River Mile System
36 River Ruler System
38 Familiarize Yourself with
the River
40 Familiarize Yourself
with the Appendices
43 2. Master Plan 2020
44 LA River 1996 Master
Plan Summary
48 Literature Review
50 Measureable Outcomes
52 Jurisdictions, Ownership,
and Rights
54 The Role of the County
56 Planning Context and Process
59 Planning Timeline
60 Data-Based Methodology
62 Integrating Future Data
SECTION II: CONTEXT
69 3. History of the River
70 The Natural History: Basin
Formation River Hydrology,
and Native Species
74 Indigenous Peoples of
the LA River Basin
76 Spanish Colonization, Mexican
California, and California
Statehood (1850)
78 Industrial Revolution and
Rapid Population
Expansion Until 1938
82 1938 Until the Present
85 4. Existing Conditions Summary
86 Inventory and Analysis
88 Existing Flood Risk
Reduction
96 Existing Water Quality
98 Existing Water Supply
102 Existing Ecosystem and
Habitat Conditions
106 Existing Open Space,
Recreation, and Trails
108 Existing Community, Art,
and Culture
110 Existing Access
112 Existing Demographics
118 Existing Sustainability
and Resiliency
122 Existing Operations
and Maintenance
8 Table of contents
326
125 5. Engagement Summary
126 Engagement Process
138 Key Public Engagement
Takeaways
140 Engagement for
the Public Draft
142 Engagement Incorporation
SECTION III: THE FUTURE OF THE LA RIVER
147 6. Goals, Actions, and Methods
148 Strategic Directions
152 Needs Analysis
155 Goal One:

Reduce Flood Risk and
Improve Resiliency
163 Goal Two:

Provide Equitable, Inclusive,
and Safe Parks, Open
Space, and Trails
175 Goal Three:

Support Healthy, Connected
Ecosystems
185 Goal Four:

Enhance Opportunities for
Equitable Access to
the River Corridor
191 Goal Five:

Embrace and Enhance
Opportunities for Arts
and Culture
199 Goal Six:

Address Potential Adverse
Impacts to Housing
Affordability and People
Experiencing Homelessness
209 Goal Seven:

Foster Opportunities for
Continued Community
Engagement, Development,
and Education
217 Goal Eight:

Improve Local Water Supply
Reliability
225 Goal Nine:

Promote Healthy, Safe,
Clean Water
233 7. Sites
234 Site Specific Opportunities
236 Opportunity: Land Assets
238 LA River Right-Of-Way
240 Opportunity: Geophysical
Conditions
241 Desktop Analysis
242 Industrial Land and
Contamination
244 Projects and Overlays from
Previous Plans
246 Sites and Cadence
248 Impact
250 Sites and Need
252 Major Project Zones
255 8. Design Components
256 Kit of Parts: Infrastructure
and Urban River Typologies
260 Trails and Access Gateways
262 Channel Modifications
264 Crossings and Platforms
327
LA RIVER MASTER PLAN 9
266 Diversions
268 Floodplain Reclamation
270 Off-Channel Land Assets
272 Kit of Parts: Biodiversity
Profiles
276 Using the Kit of Parts and
Biodiversity Profiles
278 Common Elements
280 Pavilions
282 Environmental Graphics
289 9. Project Examples
290 Example Projects
and Systems
292 LA River Trail
294 Existing Project Spotlight:

LA River Valley Bikeways
and Greenway
296 Regional Connectivity Loops
298 Flood Risk Reduction
298 Flood Risk Reduction Along the
51 Miles
304 Flood Risk Reduction in
the Narrows
316 Floodplain-based
strategies for resilience
322 Regional Groundwater
Recharge
326 Affordable and Permanent
Supportive Housing Land
Banking
330 Land Banking Methodology
332 Dry Weather Low Flow
Adjustments
334 Site-Based Project Examples
336 XS and S Pavilion Plan
Examples
338 Shade Pavilions (Tier I)
342 Rest Pavilions (Tier II)
346 Gathering Pavilions (Tier III)
352 Ferraro Fields Side Channel
360 Existing Project Spotlight:

G2 Taylor Yard
362 Connectivity Corridor
368 Existing Project Spotlight:

Rio Hondo Confluence
SECTION IV: IMPLEMENTATION
373 10. Planning Frames
374 Introduction to Frames
376 Frame 9: West Valley
380 Frame 8: Mid Valley
384 Frame 7: East Valley
388 Frame 6: Narrows
392 Frame 5: Heights
396 Frame 4: North Plain
400 Frame 3: Central Plain
404 Frame 2: South Plain
408 Frame 1: Estuary
413 11. Public Stewardship
414 Advocacy Organizations
416 How Can I Get Involved?
417 How Can My Organization
Help?

TABLE OF CONTENTS
10 Table of contents
328
419 12. System Management
422 Property Ownership
424 Management Authorities
426 Other Entities with a Role
427 Advisory Committees
428 Operations and Maintenance
438 Outreach Staff
440 Operations and Maintenance
and Safety Staff
446 Initial Services
448 LA County Hiring Practices
450 LA County Business
Partnerships
453 13. Funding Sources
454 Understanding the Scale of
the LA River
456 Costs
458 Existing LA County
Funding Sources
460 Additional Existing
Funding Sources
461 Potential New Funding Sources
463 14. Implementation and
Funding Matrix

RESOURCES
484 Glossary
488 Endnotes
494 Table of Figures
504 Acknowledgments

APPENDICES
Volume I: Design Guidelines
Volume II: Technical Backup Document
329
LA RIVER MASTER PLAN 11

THE ICONIC
VISION STATEMENT:

GLASSELL
PARK

PARAMOUNT

EAST LA

GLENDALE BURBANK

VAN NUYS
RESEDA
CANOGA
PARK

SHERMAN

OAKS STUDIO
CITY

LOS ANGELES

DOWNTOWN
LA
VERNON

COMPTON
BELL

GARDENS

LONG BEACH
SOUTH
GATE
12 VISION STATEMENT
330
The iconic LA River flows through
a 51-mile connected public
open space that is seamlessly
woven together with neighboring
communities. It is an integral part
of daily life in LA County—a
place to enjoy the outdoors
and to get across town, a place
to appreciate the serene and
to bring all people together,
a place to celebrate a thriving
urban habitat and understand
infrastructure, a place to learn
from the past and to shape
the future.

LA RIVER
331
LA RIVER MASTER PLAN 13
Pages Intentionally Omitted
332

BACKGROUND
Perhaps no other river captures Southern
California’s imagination like the LA River.

The LA River offers an opportunity to bring
17 municipalities and countless communities
together. Unlike highways that divide communities,
the river can be a connector, bringing people
together across 51 miles. This capacity was
recognized in the seminal Olmsted-Bartholomew
1930 regional plan Parks, Playgrounds, and
Beaches for the Los Angeles Region. That plan,
completed at the start of the Great Depression
and just before the catastrophic floods of the
1930s, foresaw the rapid urbanization of LA
County. Olmsted and Bartholomew recognized
that parks, open spaces, and connection to nature
would be essential to the health, environment,
and economy of the region. Unfortunately,
the Olmsted Bartholomew plan was largely
unimplemented. Given the large cost of the plan,
there were challenges with which governing
body would take it on and the need for a new
governance structure.3
While a few parkways and
reserves were created, much of the LA region’s
urbanization was driven by other development
strategies and the LA River was fully channelized
in the following decades without the envisioned
greenway.

In 1996, LA County rediscovered the ambitions
of these past planning efforts and created the
first LA River Master Plan. Numerous residents,
communities, and advocates have pushed for an
inclusive vision of shared public open space and
parks, stewardship of precious water resources,
improved ecosystem function, and continued
flood management during extreme storm events.

Figure 3. Bicycle trails allow cyclists to utilize the river right-of-way near river mile 10.8. Source: LA County Public Works, 2018.

The 2020 LA River Master Plan builds on this
history of planning and includes over two decades
of planning and implementation efforts for the
LA River, including efforts by LA County (1996),
the City of LA (2007), the LA River Ecosystem
Restoration Feasibility Study (also known as
the ARBOR Study, 2015), the Lower LA River
Working Group (2018), and the Upper LA River and
Tributaries Working Group (2019). The research
and project database that forms the foundation
for this plan covers over 140 planning efforts
along the LA River channel, across the LA River
watershed, and throughout the region.

The 2020 Master Plan Update process began in
2016 with a motion by the Board of Supervisors
to update LA County’s 1996 LA River Master
Plan. The update process, led by LA County
Public Works, was supported by several LA
County departments. A steering committee of
41 members representing municipalities, nonprofit organizations, or other governmental and non-governmental entities provided input
and expertise related to water, people, or the
environment. In addition to the technical team
and steering committee, the update process
included a robust public engagement program
designed to provide opportunities for LA County
residents to express ideas for the future of
the river.
18 Introduction // Executive summary
333
Figure 4. The LA River Trail often follows the top of the levee, especially in the Lower LA River. In this image, the landside of the levee is also fortified at river mile 11.7. Source: LA County Public Works, 2018.

The 2020 Master Plan research and analysis is
based on a watershed and community approach.

This approach is unique from previous efforts
in that analysis work, including ecosystem,
demographic, and hydrologic studies were
conducted for the 834-square-mile watershed.

Recognizing that these systemic and natural
elements cannot be studied in isolation, several
studies included information for areas outside the
watershed. This research is now publicly available
and can be utilized for parallel efforts within the
watershed.

There is no singular, 51-mile design strategy
for the LA River. Projects along the river
should reflect the needs and opportunities of
specific reaches and provide multiple benefits.

Projects should respect the needs of flood risk
management while enhancing the environment
and strengthening communities through
multi-benefit investment and the celebration
of local cultures and creation of jobs. While
design strategies in the Master Plan focus on
elements along or within the river right-ofway,4 the Master Plan’s vision, goals, actions, and methods require an understanding of, and
coordination with, communities, the watershed,
and parallel efforts such as the Upper LA River
and Tributaries Working Group, the Lower LA
River Working Group, Metro, the Regional Water
Quality Control Board, the LA County General
Plan, the LA County Sustainability Plan, the City
of Los Angeles’ LA River Revitalization Master
Plan, the LA County Comprehensive Parks
Needs Assessment, the Department of Arts and
Culture Cultural Equity and Inclusion Initiative,
and watershed management plans. Additionally,
coordination between LA County, municipalities,
other governmental entities, and non-profit
organizations will be necessary to achieve the
robust vision and goals of this Master Plan. The
reimagined LA River relies on these collective
efforts to shape the future of the LA River, its
watershed, and all of LA County.

THE 2020 MASTER PLAN RESEARCH AND

ANALYSIS IS BASED ON A WATERSHED

AND COMMUNITY APPROACH
334
LA RIVER MASTER PLAN 19
The iconic LA River flows through a 51-mile connected public open space that is seamlessly woven together with neighboring communities. It is an integral part of daily life in LA County—a place to enjoy the outdoors and to get across town, a place to appreciate the serene and to bring all people together, a place to celebrate a thriving urban habitat and understand infrastructure, a place to learn from the past and to shape the future.

VISION: THE REIMAGINED RIVER

PROJECT THEMES
The Master Plan process was guided by three
overarching and coequal themes--water, people,
and environment. At the heart of this plan is the
realization that infrastructure planning cannot
be isolated from social and environmental
needs. The full integration of the three themes is
fundamental to the LA River’s success.

The three themes proved both broad and robust
enough to capture the key issues from the 1996
plan as well as from related plans that were part
of a literature review for the update. They ensured
that the Master Plan balanced but did not isolate
hydrological, social, and environmental needs.

ENVIRONMENT

WATER PEOPLE
51 miles
The LA River is 51 miles in length, running
from Canoga Park to Long Beach.
2,300acres
There are 2,300 acres of primarily publicly owned land
within the right-of-way, including the river channel.
1,000,000people
Nearly one million people
live within one mile of the LA River.5
20 Introduction // Executive summary
335
Figure 5. The LA River Master Plan builds on over two decades of planning to reimagine the LA River. Source: OLIN, Gehry Partners, Geosyntec, 2021. 0 3mi 6mi
N
M, L, XL Planned Major Project
M, L, XL Proposed Project Site
Existing Park/Protected Land
Pervious and Impervious Surface
336
LA RIVER MASTER PLAN 21
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337
RM 3.7 W 28th St to 405 Freeway
RM 0.8 Drake Chavez Park
RM 0.6 Cesar Chavez
Park Connector

M IMPACT
RM 51.0 River Origin Park
RM 50.9 Canoga Park High School
RM 50.6 Canoga Park River Park
RM 48.9 Pierce College Connector
RM 47.4 Aliso Creek Confluence
Park / Reseda River Loop
RM 41.2 Hazeltine River Edge Park
RM 40.9 Hazeltine Avenue
RM 40.8 Van Nuys Blvd
RM 39.4 West of Coldwater
RM 38.8 Harvard Westlake
River Park
RM 38.2 Upstream from Tujunga
Confluence - Laurel
Canyon Blvd
RM 37.6 Tujunga Wash
Confluence Park
RM 37.5 Tujunga Wash Path
RM 35.9 101 Freeway Crossing
RM 33.5 Sennett Creek
RM 31.0 Glendale Riverwalk
Non-Motorized Bridge
RM 30.7 San Fernando Railroad
RM 30.5 River Glen Wetlands
RM 29.3 Central Service Yard
RM 26.2 G1 Bowtie
RM 25.3 Dorris Place
Sanitation Yard
RM 24.1 Arroyo Seco Confluence
RM 24.0 Arroyo Seco Greenway
RM 23.5 Bending the River
Back into the City
RM 21.6 Downtown Train Yard
RM 21.1 6th Street Viaduct
RM 15.3 Randolph Street
RM 13.9 Cudahy River Park
RM 13.5 U.P.R.R. Spur Line
RM 12.7 South Gate Orchard
RM 12.0 Parque Dos Rios
RM 11.7 SELA Cultural Center
RM 10.2 E Rosecrans Ave
RM 9.4 Compton Blvd
RM 8.1 Connectivity Corridor
RM 2.9 Willow Street
RM 1.7 Middle Long Beach
RM 0.9 Long Beach Municipal
Urban Stormwater
Treatment

XL IMPACT
RM 47.8 LA River Valley
Bikeway and Greenway
RM 44.0 Sepulveda Basin
RM 32.8 Headworks Connector
RM 31.9 Burbank Western
Green Network
RM 22.6 Piggyback Yard
RM 11.9 Western LA River
Levee Bike Path
RM 11.8 Rio Hondo Confluence
RM 1.6 South of Willow Street
RM 0.7 Shoemaker Bridge
Replacement

L IMPACT
RM 47.5 Southern Aliso
Green Network
RM 46.8 Reseda Expansion
RM 46.5 Caballero Creek
Confluence Park
RM 33.0 Headworks Park
RM 30.9 Ferraro Fields
Side Channel
RM 30.8 Glendale Narrows
Riverwalk
RM 30.65 San Fernando Path
RM 30.6 Verdugo Wash
RM 29.5 Atwater Village East Bank
Riverway
Figure 220. Site-Based Projects by Impact. Planned major projects (grey) and proposed project sites (pink) fall into three scales of impact. More information about individual projects and sites can be found in Appendix Volume II: Technical Backup Document.

PROJECT LIST BY IMPACT

PLANNED MAJOR PROJECTS IMPACT
Similar to how opportunity sites were assessed
based on their scale and expected ability to
positively address local needs, existing projects
were also categorized by impact. Existing planned
major projects were reviewed to determine
if prior planning efforts have targeted the
current needs established by the Master Plan. In
situations where current needs are not being met,
further coordination with the project’s planning
organization is recommended.

FOR MORE INFORMATION ON

SITES AND PLANNED MAJOR
PROJECTS, SEE CHAPTER 5
OF APPENDIX II: TECHNICAL

BACKUP VOLUME
RM 30.4 River Glen Wetlands
RM 25.6 G2 Taylor Yard
RM 25.2 Taylor Yard NonMotorized Bridge
RM 24.5 Metro LA River Path
RM 23.2 Main Street Terrace
RM 21.5 First Street to Sixth
Street River Loop
RM 19.9 East Washington Blvd
RM 18.2 West Santa Ana
Branch Bikeway
RM 16.2 Upper Segment Multiuse
Easement and Atlantic
Blvd Area
RM 15.8 Maywood Park Bend
RM 14.1 Clara Street
RM 12.9 Firestone Blvd
RM 10.5 Highway 105
RM 10.4 Terminal Island to
Rio Hondo
RM 7.2 Middle Segment Multi-use
Easement and Crossover
RM 6.3 Sutter Bend at
Del Amo Blvd
RM 5.5 Compton Creek
Confluence Area
RM 5.1 W 47th St / Rancho
Los Cerritos
RM 4.4 Wrigley Heights
River Park
338
LA RIVER MASTER PLAN 249
Pages Intentionally Omitted
339
Figure 346. LA River Planning Frame 2. Source: LA River Master Plan, 2020.

GF
(!
GF
!
!
LA River Mile Point
LA River Channel
Tributaries and Streams
LA River Watershed Boundary
Municipal Boundaries
Supervisorial Districts
Major Roads and Highways
Railroad Lines
Metro Transit Line and Station
Multiuse Trails and Class I Bikeways
Transmission Lines
Existing Private Right-of-Way
Existing Park
Pervious and Impervious Surface
M, L, XL Planned Major Project
M, L, XL Proposed Project Site
XS, S Planned Project
XS, S Proposed Site
Existing Access Point
Existing Access Point to Improve
Planned and Proposed Multiuse Trails and Class I Bikeways Proposed Regional Connectivity Loops
Existing Conditions
LA River Master Plan Design Proposals
!!
FRAME 2: SOUTH PLAIN
Frame 2 Sites List

M, L, XL

11.9 I-710 Corridor Bike Path Project: Western
LA River Levee Bike Path

10.4 I-710 Corridor Bike Path Project: Terminal
Island to Rio Hondo

8.1 Connectivity Corridor

7.2 Middle Segment Multiuse Easement and
Crossover

6.3 Sutter Bend at Del Amo Blvd

5.5 Compton Creek Confluence Area

5.1 W 47th Street/ Rancho Los Cerritos

4.4 Wrigley Heights River Park
See Chapter 5 in Appendix II: Technical
Volume for further information on sites and
planned major projects.
406 Implementation // Plannin g Frames
340
0 0.25mi 0.5mi
N
341
LA RIVER MASTER PLAN 407
Notable Features:
• Estuary (including projections for sea
level rise)
• Important bird habitat area
• Brackish water year round
• Present transition from river channel to soft
bottom estuary at Willow Street
• Wrigley Greenbelt from river mile 2.9 to 4.0
along the left bank
• Santa Cruz Park, Golden Park, and Cesar
Chavez Park from river mile 0.3 to 0.8 along
the left bank, bisected from the river by West
Shoreline Drive.
• Shoreline Aquatic Park and the Queen Mary
at river mile 0
Location: City of Long Beach; river mile 4.0 - 0.0
Channel Characteristics: The channel in this frame is a leveed trapezoidal concrete cross section with a width of approximately 400 feet. The soft channel bottom with year-round water transitions at river mile 3 to a concrete bottom section with hard rip-rap sides, with a typical width of 585 feet.

Average Channel Slope: < 0.1%
Landside Right-of-Way Characteristics: This frame contains east and west facing parcels along levee, with areas that vary from approximately 15 feet to 100-150 feet wide.

Significant Design Considerations for this Frame:
• This frame is in closest proximity to the
ocean and Port of Long Beach, with unique
site conditions for projects along the LA
River.
• Projects here are potentially subject to high
amounts of salt spray and salt content in the
water and soil. Material and plant selections
should be able to tolerate these conditions.
• Raised banks along the channel bottom allow
for planting and should be managed as to not
encourage the spread of invasive species.
• The wide ROW parcels, year-round presence
of water, and proximity to the ocean
provides opportunities for the creation and
enhancement of valuable coastal habitat
such as wetlands and nesting grounds.
• Sea level rise may occur in coming decades
in this frame.

FRAME 1: ESTUARY
408 Implementation // Plannin g Frames
342
RM 2
9 8
7 6
5 4
3 1
2 0
10 20
30 40
50 51
50 46
42 38
34 30
26 22
18 14
10 6
2 48
44 40
36 32
28 24
20 16
12 8
4 0
49 45
41 37
33 29
25 21
17 13
9 5
1 47
43 39
35 31
27 23
19 15
11 7
3 CANOGA PARK
RESEDA

VAN NUYS

SHERMAN OAKS

STUDIO CITY

BURBANK

GLENDALE

DOWNTOWN LA
VERNON

BELL GARDENS

SOUTH GATE

COMPTON

LONG BEACH
Figure 347. LA River Planning Frame 1. Source: LA River Master Plan, 2020. 343
LA RIVER MASTER PLAN 409
Figure 348. LA River Planning Frame 1. Source: LA River Master Plan, 2020.

GF
(!
GF
!
!
LA River Mile Point
LA River Channel
Tributaries and Streams
LA River Watershed Boundary
Municipal Boundaries
Supervisorial Districts
Major Roads and Highways
Railroad Lines
Metro Transit Line and Station
Multiuse Trails and Class I Bikeways
Transmission Lines
Existing Private Right-of-Way
Existing Park
Pervious and Impervious Surface
M, L, XL Planned Major Project
M, L, XL Proposed Project Site
XS, S Planned Project
XS, S Proposed Site
Existing Access Point
Existing Access Point to Improve
Planned and Proposed Multiuse Trails and Class I Bikeways Proposed Regional Connectivity Loops
Existing Conditions
LA River Master Plan Design Proposals
!!
FRAME 1: ESTUARY
Frame 1 Sites List

M, L, XL

11.9 I-710 Corridor Bike Path Project: Western
LA River Levee Bike Path

10.4 I-710 Corridor Bike Path Project: Terminal
Island to Rio Hondo

3.7 W 28th St to 405 Freeway

2.9 Willow Street

1.7 Middle Long Beach

1.6 South of Willow Street

0.9 Long Beach Municipal Urban Stormwater
Treatment

0.8 Drake Chavez Park

0.7 Shoemaker Bridge Replacement

0.6 Cesar Chavez Park
See Chapter 5 in Appendix II: Technical
Volume for further information on sites and
planned major projects.
410 Implementation // Plannin g Frames
344
0 0.25mi 0.5mi
N
Wrigley
Greenbelt
345
LA RIVER MASTER PLAN 411
Pages Intentionally Omitted
346

13. FUNDING SOURCES

EXISTING AND NEW FUNDING WILL BE NEEDED

TO MEET THE MASTER PLAN GOALS
Achieving the goals of the LA River Master Plan
will involve coordinated efforts among public,
private, and nonprofit entities to implement a
myriad of projects over the next 25 years. During
that time frame, physical, political, and financial
conditions will change. The LA River spans
several municipalities and communities that
must provide ongoing financial and political
support to secure the development, operations,
and maintenance of projects within their
jurisdictional limits. Moreover, it is critical to
establish a framework for project funding beyond
individual municipalities to enable support
from federal, state, and LA County funding
mechanisms. The unification of interests and
goals among champions and stakeholders will
help to realize the Master Plan’s goal-driven
implementation framework, ultimately revitalizing
the LA River.
347
LA RIVER MASTER PLAN 453

UNDERSTANDING THE

SCALE OF THE LA RIVER
To better understand costs associated with the LA River Master Plan and the funding needed, it is important to understand the scale of the LA River.

Nearly one million people live within one mile of the LA River and over onethird of Californians live within a one-hour drive.147 The number of people who will directly benefit from the implementation of the LA River Master Plan’s goals for improved quality of life, functioning ecosystems, parks, arts and culture, housing affordability, supportive housing, education, and improved flood risk management, water quality, and water supply is unprecedented in scale by most urban park or infrastructure projects.

The LA River Master Plan proposes a 51-mile connected open space that functions as a multi-benefit resource that will manage flood waters while also improving ecosystems and health and wellbeing. When comparing the scale of the 2,300 acres of the LA River right-of-way to other public parks around the world, the LA River has significant potential to impact the daily lives of Angelenos and the ecosystems of the LA region. The LA River represents one of the most continuous, almost entirely publicly owned opportunities in LA County for public open space. Even Central Park in New York City, which is 843 acres, pales in comparison to the 2,300 acres of the LA River right-of-way.

Reimagining such a large land area that functions as a piece of critical infrastructure may seem daunting. However, within the context of large infrastructure projects across the United States and particularly in California and the Los Angeles region, the costs associated with the LA River Master Plan are not overly ambitious within the plan’s 25 year implementation period.

THE LA RIVER REPRESENTS

ONE OF THE MOST CONTINUOUS,

ALMOST ENTIRELY PUBLICLY

OWNED OPPORTUNITIES IN

LA COUNTY FOR PUBLIC

OPEN SPACE
454 IMPLEMENTATION // Funding Sources
348
Figure 390. The LA River represents a significant opportunity to create 51 miles of connected public open space within and along the 2,300 acre right-of-way. This to-scale comparison shows other significant public parks and open spaces around the world next to the 51-mile LA River.

Figure 391. While the goals of the LA River Master Plan are ambitious, the scale of the project is manageable, as evidenced in this to-scale comparison of other significant infrastructure projects. Project costs above have been adjusted to reflect 2020 dollar value.

Large Park Comparisons
Large Infrastructure Comparisons
LA RIVER MASTER PLAN 455

THE HIGH LINE

NEW YORK CITY, NY

6.73 ACRES

SOUTH PLATTE

RIVER GREENWAY

DENVER, CO
10 MILES

CHEONGGYECHEON STREAM

SEOUL, SOUTH KOREA

3.6 MILES
100 ACRES

SEATTLE WATERFRONT

SEATTLE, WA

1.5 MILES
20 ACRES

CENTRAL ARTERY

BOSTON, MA

7.5 MILES
300 ACRES

BOLSA CHICA

WETLANDS

HUNTINGTON BEACH, CA
1240 ACRES

CENTRAL PARK

NEW YORK CITY, NY
843 ACRES

BALLONA WETLANDS

PLAYA VISTA, CA
600 ACRES

LA RIVER

LA COUNTY
51 MILES
2300 ACRES
T.A.R.P.

CHICAGO, IL
$4,100,000,000149

CENTRAL ARTERY

BOSTON, MA
$26,000,000,000150

LA AQUEDUCT

LOS ANGELES, CA
$1,200,000,000151

MADRID RIO

MADRID, SPAIN
$6,300,000,000152

STATE WATER PROJECT
CALIFORNIA, U.S.
$11,000,000,000153

LA RIVER

LA COUNTY

LAX EXPANSION

LOS ANGELES, CA
$14,000,000,000148

ATLANTA BELTLINE

ATLANTA, GA
22 MILES
2000 ACRES

SAN ANTONIO

RIVERWALK

SAN ANTONIO, TX

2.5 MILES
349
Figure 392. Estimated Costs per Project Sizes in the LA River Master Plan. This table associates project impact levels from XS to XL with estimated cost ranges per project. Given the range of project typologies, these ranges are understandably broad, but provide a basis for planning.

IMPACT
XL
L
M
S
XS

ACREAGE / LENGTH COST
150+ acres / 10+ miles
40 - 150 acres / 5-10 miles
< 40 acres / < 5 miles
1 - 3 acres / 1 - 5 miles
< 1 acre / < 1 mile
$200 million - $1.5 billion
$50 million - $200 million
$10 million - $50 million
$1 million - $10 million
< $1 million
COSTS

CAPITAL COSTS
Achieving the goals of the LA River Master Plan
will involve coordinated efforts among public,
private, and nonprofit entities to implement
a myriad of projects over the next 25 years.

During that time, physical, political, and financial
conditions will change. However, through
research of comparable precedents, an estimated
budget range for the implementation of the
Master Plan’s site- and system-based projects has
been developed and could range from 19 billion
to 24 billion dollars (2020 dollars).

There are several primary cost considerations
with the LA River Master Plan budget. Costs by
improved acre could range from 1 million dollars
(2019 dollars) per acre for trails and similar
basic amenities to 15 million dollars per acre
(2019 dollars) for more robust improvements
such as bridges or sites requiring remediation.

Costs can also be analyzed on a project by
project basis (XS, S, M, L, and XL) and estimated
budget ranges per project (see chart above
for ranges). Given the wide range of project
typologies, these ranges are understandably
broad, but provide a basis for planning for
capital and operational resources.

ONGOING O&M COSTS
In addition to the capital costs of the Master
Plan, it is important to consider operations
and maintenance costs to ensure ongoing
project success. The Design Guidelines (Appendix
Volume I) require every project to have a
three-year maintenance plan in place, as well as
a named entity for ongoing maintenance of any
proposed project.

Using precedent studies, maintenance costs for
the entire LA River right-of-way (51 miles) range
from $1.5-3 million dollars (2019 dollars) per river
mile annually. This includes a range of costs for
flood infrastructure and park space maintenance.

Specific improvements will greatly affect the
type of maintenance required and many areas
along the river already have maintenance funding
in place through partnerships between LA County,
the USACE, municipalities, state conservancies,
and other entities such as non-profits.

In addition to overall operations and maintenance
budgets, programs for full time operations and
safety staff that could monitor trails and parks
along the river right-of-way are important as
more of the river becomes a publicly accessible
connected open space.

Estimated Costs per Project Sizes in the LA River Master Plan 456 IMPLEMENTATION // Funding Sources
350
2020
2021
2022
2023
2024
2025
2026
2027
20282029
2030
2031
2032
2033
2041
2034
2035
2036
2037
20382039
2040
2042
2043
2044
2045
2046
2047
20482049
2050

O&M COSTS
(MILLIONS)
$1
$2
$4
$8
$16
$32
$64
YEARS
2020 - 2045 IMPLEMENTATION OF THE LA RIVER MASTER PLAN
Figure 393. LA River Master Plan Capital Costs Over Time. There are two important patterns to recognize in the allocation of funding resources.

Capital improvements are anticipated to be relatively constant with the exception of inflationary and escalation costs over time. As capital projects are completed these costs will decrease.

Figure 394. LA River Master Plan Operations and Maintenance Costs Over Time. There are two important patterns to recognize in the allocation of funding resources. Operations and maintenance costs, while significantly lower than capital costs, will rise over time as new amenities come on line. During this time, the river’s value as a resource will also increase as the plan achieves the nine goals for water, people, and the environment.

LA River Master Plan Capital Costs Over Time
LA River Master Plan Operations and Maintenance Costs Over Time 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2041 2034 2035 2036 2037 2038 2039 2040 2042 2043 2044 2045 2046
2047
2048
2049
2050

CAPITAL COSTS
(BILLIONS)
$0.1
$0.2
$0.4
$0.8
$1.6
$3.2
$6.4
YEARS
2020 - 2045 IMPLEMENTATION OF THE LA RIVER MASTER PLAN
$B
$M

CAPITAL COSTS DECLINE AT

THE END OF IMPLEMENTATION

MAINTENANCE COSTS

PEAK AT IMPLEMENTATION
351
LA RIVER MASTER PLAN 457

EXISTING LA COUNTY FUNDING SOURCES
Across LA County and the municipalities adjacent
to the LA River, several funding sources are in
place that could support the work of projects
related to this Master Plan. Additionally, state and
federal funding can be leveraged toward projects
in this plan.

WHAM COMMITTEE
In December 2019, LA County formed the WHAM
Committee to facilitate intentional coordination
of funds associated with Measures W, H, A, and M.

These four measures, passed between 2016 and
2018, include hundreds of millions of dollars for
stormwater projects (W), homelessness services
and housing (H), parks (A), and transportation (M).

The WHAM Committee is coordinating planning
to develop multi-benefit projects combining
multiple funding sources, while leveraging
existing county funds with other funding sources,
including local, state, and federal funding
opportunities. The WHAM Committee is charged
with working collaboratively in a systematic
method while engaging municipalities, technical
experts, and other stakeholders where needed.

Integration of the goals of the OurCounty
Sustainability Plan is also a key purpose of the
WHAM Committee.

The associated LA County Measures are
described below:
• Safe, Clean Water (Measure W): Focused
on water quality improvement, Measure W
was passed by LA County voters in 2018.

The measure makes $285 million available
annually for projects with a focus on water
quality improvement and specifically
prioritizes nature based solutions to
stormwater quality challenges. The goals of
Measure W are well aligned to many goals in
the LA River Master Plan.
• The Los Angeles County Homeless Initiative
(Measure H): Approved in 2016, Measure H
increases the county’s sales tax by ¼ percent
to raise an estimated $355 million per year
over ten years. Funds are appropriated for
rental subsidies and housing to pursue a
comprehensive regional approach to combat
homelessness. The measure implements
21 strategies that directly strive to prevent
homelessness, increase affordable and
homeless housing, subsidize housing costs,
increase income, provide case management
and services, and utilize a coordinated entry
system.

THE WHAM COMMITTEE WAS

FORMED TO FACILITATE

INTENTIONAL COORDINATION

OF FUNDS ASSOCIATED WITH

MEASURES W, H, A, AND M
458 IMPLEMENTATION // Funding Sources
352
Figure 395. Existing funding for river related projects includes federal, state, and local sources. • Safe, Clean Neighborhood Parks and Beaches
(Measure A): Measure A is a parcel tax first
approved by LA County voters in 2016. It
provides for safety improvements to existing
park, recreation, and beach facilities, as
well as the acquisition of new parkland and
open space. It can also be used toward the
restoration of rivers and streams, graffiti
prevention, and tree planting. It generates
approximately $96 million annually and could
be used to address several Master Plan
goals, such as those related to parks and
ecosystems.
• LA County Traffic Improvement Plan (Measure
M): Approved in 2016 by LA County voters,
Measure M is a sales tax initiative that
provides funding for new transit and highway
projects, enhanced bus and rail operations,
and other transportation improvements
throughout LA County. It generates
approximately $860 million annually and could
support access-related Master Plan goals.

FLOOD CONTROL DISTRICT FUNDING
The LACFCD is a special district overseen
by the LA County Board of Supervisors. The
LACFCD funds development projects that
relate to their mission of flood risk reduction,
water conservation, and water quality on
lands owned or managed by the District. The
LACFCD mandate also includes the ability to
fund passive recreation projects along LACFCD
property and rights-of-way. Several projects in
the Master Plan could be partially funded by the
LACFCD.

Federal State Local
WRDA: Stormwater Priorities Prop 1, Water Bond (2014):

Remaining Monies
Safe, Clean, Neighborhood Parks
and Beaches (Measure A):
$96 million annually
USACE Continuing
Authorities Plan
USACE Corps Water
Infrastructure Financing
Program
Prop 68, Parks and Water Bond
(June 2018): $4 billion statewide
LA County Traffic Improvement
Plan (Measure M):
$860 million annually
USFWS North American
Wetlands Conservation Act
San Gabriel and Lower Los Angeles
Rivers and Mountains Conservancy
(RMC) and the Santa Monica
Mountains Conservancy (SMMC)
Safe, Clean Water (Measure W):
$285 million annually
NPS Land and Water
Conservation Fund
Coastal Conservancy: Lower River/
Estuary
Homeless Initiative (Measure H):
$355 million annually
SBR Water SMART Wildlife Conservation Board and
California Department of Fish and
Wildlife: Habitat
353
LA RIVER MASTER PLAN 459

GRANTS AND OTHER EXISTING FUNDING
While there have been several successful bond
measures and programs created in the last few
years to support multi-benefit projects similar
to the LA River Master Plan, existing grant and
programmatic funding streams are spread out
through multiple agencies at different levels
of government with varying project scales and
timeline requirements. Grants and existing
funding are great opportunities for short term
funding but unreliable for mid to long term
implementation. During implementation, analysis
of existing programs and available funding at all
levels can allow sources to be generally accounted
for but specifically matched back to Master Plan
goals and projects for short term implementation.

At the state level several bonds exist that relate
to the goals of the LA River Master Plan. The
Water Quality, Supply, and Infrastructure
Improvement Act of 2014 (Proposition 1)
authorized $7.545 billion in general obligation
bonds to fund ecosystems and watershed
protection and restoration, water supply
infrastructure projects, including surface
and groundwater storage, and drinking water
protection. The Parks, Environment, and Water
Bond Act of 2018 (Proposition 68) authorized
$4 billion in general obligation bonds for state
and local parks, environmental protection
and restoration projects, water infrastructure
projects, and flood protection projects. The
San Gabriel and Lower Los Angeles Rivers and
Mountains Conservancy and the Santa Monica
Mountains Conservancy received funding
for LA River planning and projects as part of
Propositions 1 and 68.

State agencies which have previously received
bond funding for grant programs include the
Strategic Growth Council, the Department of
Water Resources, the Department of Parks
and Recreation, the State Water Board, the
San Gabriel and Lower Los Angeles Rivers and
Mountains Conservancy, the Santa Monica
Mountains Conservancy, the California Natural
Resources Agency, the California Department of
Fish and Wildlife, Wildlife Conservation Board, and
the State Coastal Conservancy.

At the federal level, transportation programs
offer potential funding for projects such as
bikeways and trails. Additional funding related
to resiliency may be available through agencies
such as FEMA.

Brownfield funding opportunities are outlined in
detail in Chapter 7.

PARALLEL FUNDING SOURCES
In addition to river-specific funding sources,
projects along the LA River can leverage
funding from parallel efforts within the region.

For example, in 2020 the LA County Board of
Supervisors approved the “Care First, Jails
Last” motion providing 114 recommendation to
help decarcerate the county’s jails, specifically
diverting individuals suffering from poor
mental health, drug and alcohol dependency,
homelessness, and other underlying conditions
into less punitive programs that serves these
vulnerabilities. Many of the county’s systemimpacted communities lie within the same geographic area of those identified by the Master
Plan as high-need communities. Many of the
recommendations of the motion manifest in
similar strategies of those of the Master Plan.

Among the recommendations, there are certain
alignments that can work alongside river
improvements, such as decentralized service
hubs that are similar to the resources provided
in Gathering Pavilions (Tier III), including lowbarrier navigation centers. Additionally, the motion calls for community-based harm reduction
strategies, similar to those called for river
staffers. Lastly, several recommendations call
for affordable and supportive housing to create
secure and safe living environments for systemimpacted individuals. ”Care First, Jails Last” recommends significant funding measures, and
as such, recommendations in alignment with the
Master Plan’s methods can work symbiotically
and share these resources.

ADDITIONAL EXISTING FUNDING SOURCES
460 IMPLEMENTATION // Funding Sources
354

SEVERAL EXISTING

FUNDING SOURCES ARE

IN PLACE THAT COULD

SUPPORT THE WORK OF

PROJECTS RELATED TO

THIS MASTER PLAN

POTENTIAL NEW FUNDING SOURCES
There are several existing options for large scale
financing that should be considered and further
researched during the implementation phase of
this plan. The framework of the LA River Master
Plan allows for key decision-makers including
the public, as well as elected officials at all levels
of government to creatively build a package of
revenue sources over the next 20-25 years in
support of the goals and projects outlined in
this plan. While the following list includes many
existing opportunities for large scale financing,
there may be additional opportunities that can
be brought to the table with further research and
targeted conversations with experts.
• LA River Bond Measure: A bond measure
specifically for LA River funding would give
the public and policymakers an opportunity to
create a dedicated source of revenue over the
course of 25 to 30+ years.
• Enhanced Infrastructure Finance District
(all EIFDs should be written with affordable
housing goals in mind to reserve funding for
affordable housing): EIFDs can be used to
finance public capital facilities, including
affordable housing, by leveraging anticipated
future increases in tax revenue due to these
investments. Creating an EIFD for the LA
River and or specific LA River projects could
create long-term revenue for revitalization
efforts and provide a great opportunity to
directly support the Master Plan’s goal for
housing. EIFDs have been relatively hard
to implement since they generally require
sharing tax revenue from county and local
municipal partners. However, the Master Plan
creates a collective set of goals for all parties
to work toward together.
• Appropriations and Direct Funding: State
member items, state and municipal budgets,
and federal appropriations could be directly
leveraged for the LA River. The appropriation
of funds at all levels would have to be
coordinated individually with policy makers
to ensure funding applicability. It would be a
great opportunity for short-term funding to
jump start Master Plan next steps.
355
LA RIVER MASTER PLAN 461
Pages Intentionally Omitted
356

ACKNOWLEDGMENTS
Supervisor Hilda L. Solis
First District
Supervisor Holly J. Mitchell
Second District
Supervisor Sheila Kuehl
Third District
Supervisor Janice Hahn
Fourth District
Supervisor Kathryn Barger
Fifth District

LA COUNTY BOARD OF SUPERVISORS
Director Mark Pestrella
Angela George-Moody
Dan Lafferty
Keith Lilley
Carolina Hernandez
Ramy Gindi
Genevieve Osmena
Christine Wartman
Ernesto Rivera
Seta Marjanian
Mark Beltran
Alynn Sun
Donna Diaz
Armando D’Angelo
Armando Nunez-Fausto
David Gallagher
Helen To
Iraj Nasseri
James Bazinet
Kenneth Chow
Khai Chung
Luis Garcia
Luis Perez
Mateusz Suska
Nayiri Vartanian
Paul Shadmani
Richard Shieh
Ryan Ong
Stella Quiroz
Stephen Zurek
Yvonne Taylor

LA COUNTY PUBLIC WORKS
This update to the LA River Master Plan, completed in 2022, was initiated by the LA County Board of Supervisors and led by LA County Public Works. The creation of the plan was supported by numerous departments within LA County as well as municipalities, organizations, and individuals that served on the Steering Committee and Subcommittees.

In addition to the named individuals on these pages, many people committed to the future of the LA River contributed significantly to the plan by sharing ideas, priorities, and goals for the river.

This Master Plan was made possible only through their rich contributions. 504 Acknowledgements
357
Figure 398. Students at the LA River Master Plan Youth Summit weave a map tapestry of the LA River. Source: OLIN, 2018.

INTERNAL COUNTY TEAM

BOARD OF SUPERVISORS FIRST DISTRICT
Waqas Rehman
Guadalupe Duran-Medina
Martin Reyes
Aydin Pasebani
Teresa Villegas

BOARD OF SUPERVISORS SECOND DISTRICT
Laura Maraida
Jessalyn Waldron
Karly Katona
Carmen Gosey

BOARD OF SUPERVISORS THIRD DISTRICT
Maria Chong-Castillo
Sophie Freeman
Tessa Charnofsky
Katy Yaroslavsky
Virdiana Velez

BOARD OF SUPERVISORS FOURTH DISTRICT
Daritza Gonzalez
Jocelyn Rivera-Olivas

BOARD OF SUPERVISORS FIFTH DISTRICT
Anish Saraiya
Chris Perry
Edel Vizcarra

CHIEF SUSTAINABILITY OFFICE
Gary Gero
Rita Kampalath

CHIEF EXECUTIVE OFFICE
Vani Dandillaya
Julia Orozco

DEPARTMENT OF ARTS AND CULTURE
Kristin Sakoda
Heather Rigby
Grace Ramirez Gaston
Iris Anna Regn
Pauline Kamiyama
Leticia Rhi Buckley
Mayen Alcantara

DEPARTMENT OF PARKS AND RECREATION
Alina Bokde
Michelle O’Connor
Sheela Mathai
Clement Lau
John Diaz

DEPARTMENT OF REGIONAL PLANNING
Gina Natoli
Patricia Hachiya
Jennifer Mongolo
Connie Chung
Ayala Scott

NATURAL HISTORY MUSEUM OF

LOS ANGELES COUNTY
Carol Bornstein
Lila Higgins

HEALTH SERVICES
Whitney Lawrence
358
LA RIVER MASTER PLAN 505

CITY OF DOWNEY
Sean Ashton

CITY OF LONG BEACH
Kevin Jackson
Lena Gonzalez
Cory Allen
Jennifer Kumiyama
Tyler Curley

CITY OF LOS ANGELES
MAYOR’S OFFICE
Michael Affeldt
Edward Belden
Katie Mika

CITY OF LOS ANGELES

BUREAU OF ENGINEERING
Gary Lee Moore
Deborah Weintraub
Katherine Doherty

CITY OF PARAMOUNT

PUBLIC WORKS
Adriana Figueroa
Christopher Cash
Sarah Ho
Wendy Macias

CITY OF SOUTH GATE

DEPARTMENT OF PUBLIC WORKS
Arturo Cervantes
Gladis Deras

CONSERVATION CORPS

OF LONG BEACH
Dan Knapp
Kayla Kelly-Slatten

COUNCIL FOR WATERSHED
HEALTH
Eileen Alduenda
Yareli Sanchez

EAST YARD COMMUNITIES FOR

ENVIRONMENTAL JUSTICE
mark! Lopez
Alessandro Negrete
Jessica Prieto

FRIENDS OF THE LA RIVER (FOLAR)
Marissa Christiansen
Liliana Griego
Manuel Gonez
Stephen Mejía-Carranza

FROM LOT TO SPOT
Viviana Franco
Berny Orantes
Erique Huerta
Jessica Cervantes
Maria De Leon

HEAL THE BAY
Shelley Luce
Amanda Wagner
Katherine Pease
Stephanie Medina

LOS ANGELES BUSINESS COUNCIL
Mary Leslie
Devon Provo
Jacob Lipa
Rory Stewart

LOS ANGELES CITY/COUNTY

NATIVE AMERICAN INDIAN

COMMISSION
Rudy Ortega
Alexandra Valdes
Andrea Garcia

LOS ANGELES COUNTY

FIRST DISTRICT
Waqas Rehman
Guadalupe Duran-Medina
Martin Reyes
Aydin Pasebani
Teresa Villegas

LOS ANGELES COUNTY

SECOND DISTRICT
Laura Maraida
Jessalyn Waldron
Karly Katona
Carmen Gosey

LOS ANGELES COUNTY

THIRD DISTRICT
Maria Chong-Castillo
Sophie Freeman
Tessa Charnofsky
Katy Yaroslavsky
Virdiana Velez

LOS ANGELES COUNTY

FOURTH DISTRICT
Daritza Gonzalez
Jocelyn Rivera-Olivas

LOS ANGELES COUNTY

FIFTH DISTRICT
Anish Saraiya
Chris Perry
Edel Vizcarra

LOS ANGELES COUNTY

BICYCLE COALITION
Eli Kaufman
Cesar Hernandez
Jesi Harris
Lyndsey Nolan

LOS ANGELES COUNTY

BUSINESS FEDERATION
Hilary Norton
Lori Garcia

LOS ANGELES COUNTY FLOOD

CONTROL DISTRICT
Daniel J. Lafferty
Keith Lilley
Carolina Hernandez

LOS ANGELES COUNTY

METROPOLITAN TRANSPORTATION

AUTHORITY
Lauren Cencic
Julia Salinas
Mitali Gupta
Maressa Sah
Sarah Schurtz

LOS ANGELES DEPARTMENT OF

WATER AND POWER
David Pettijohn
Evelyn Cortez-Davis
Rafeal Villegas
Manuel Aguilar
Scott Hungerford

LOS ANGELES NEIGHBORHOOD

LAND TRUST
Keshia Sexton
Beth Kent
Tamika Butler

LOS ANGELES WATERKEEPER
Bruce Reznick
Melissa von Mayrhauser

MUJERES DE LA TIERRA
Irma R. Muños
Paola Machan

PACOIMA BEAUTIFUL
Veronica Padilla-Campos
Andres Ramirez

PUBLIC COUNSEL
Antonio Hicks

PUBLIC WORKS
Keith Lilley
Carolina Hernandez

STEERING COMMITTEE MEMBERS AND ALTERNATES
506 Acknowledgements
359
Pages Intentionally Omitted
360
361
EXHIBIT 8
362
363
Pages Intentionally Omitted
364
The Lower Los Angeles River Revitalization Plan—at a Glance | iii The Lower Los Angeles
River Revitalization
Plan—at a Glance
The Lower Los Angeles River (the river) is the core of southeast Los Angeles and serves a critical role by managing flood risk. It protects life and property by collecting stormwater from surrounding areas and safely conveying it to the ocean. The river’s paths and trails also provide a space for the community to recreate and travel within the region. Despite these functions, the river’s potential value as a place for relaxation, discovery, recreation, tourism, and economic development has yet to be realized. In 2015, California State Assembly Bill 530 (AB 530) was passed to revive the river through the development of a watershed-based, equitable, community-driven plan.

The language of Assembly Bill 530 (Rendon), called for Secretary John Laird, Natural Resources Agency, in consultation with the Los Angeles County Board of Supervisors, to appoint members to participate in the Lower Los Angeles River Working Group.

The Working Group, chaired by the San Gabriel and Lower Los Angeles Rivers and Mountains Conservancy, included city representatives and community advocates who came together to create the Lower Los Angeles River Revitalization Plan (the Plan). The Plan describes opportunities for improving the environment and residents’ quality of life along the river. This Plan ensures that the voices of the people are heard now and in the future as the river is reimagined and revitalized into an integral part of a healthy, equitable, and sustainable community. 365
Pages Intentionally Omitted
366
Opportunity Assessment

LOWER LOS ANGELES RIVER
Opportunity Description
Opportunity Potential
(Average of Applicable Metrics Advanced)
Plan
Element Objective
Applicable
Metrics
Advanced
(%)
Water and
Environment
Conserve, Enhance, and
Restore Habitat, Biodiversity,
and Floodplain Functions
Enhance Local Water
Capture and Use
Improve Environmental Quality
Manage Flood Risk
Public
Realm
Enhance Connectivity
Improve User Experience and
Equitable Access
Enhance and Create Diverse,
Vibrant Public Spaces
Community Economics,
Health, and Equity
Address Homelessness
Increase Community Green
Infrastructure
Increase Equitable Community
Access to Multi-use Trails, Assets
Prevent Local GentrificationInduced Displacement
Promote Wellness and
Physical Activity
Support and Develop Local
Business and Workforce
Opportunity Area
Opportunity ID Opportunity Driver
San
Diego
Frwy
Interstate 405
Long
Beach
Frwy
Interstate 710
W Wardlow Rd 1
66 66
69 74
83 84
85 94
98 99
112
125
125
125
139
139
City of Long
Beach
68 100
100
100
100
100
100
100
100
100
100
98 100
75 Wrigley Heights River Park
100
Driving Range. Potential to continue Dominguez Gap-like wetland southward. Propose wetland, riparian
woodland, pedestrian and bicycle paths.

Priority/Long Beach
RiverLink
Z
Featured Opportunity
Other Opportunities
City Boundary
0 1,060
Feet
§¨¦405
§¨¦105
§¨¦5
-118.2

33.825
Lat.

Long.

ID
367
ID Building Block Applied
1 Active space
2 Additional permanent
homeless shelters
3 Bioswales
4 Boardwalks and overlooks
5 Brownfields remediation
6 Climbing wall
7 Commercial zone access
9 Community garden
10 Community gateway
12 Continuous park space
13 Curb cuts/street eddy
basins
14 Destination stops
15 Diversion to sanitary sewer
16 Drinking fountains
17 Dry wells
18 Elevated paths
20 Equestrian trails
ID Building Block Applied
21 Bike hubs
22 Floodplain expansion
23 Green infrastructure
24 Habitat area
25 Habitat corridor
26 Historical, cultural,
environmental
education/assets/
signage
27 Homeless space
sharing
28 Infiltration basins and
trenches
29 In-river access and
safety
30 Leverage planned
regional water
recycling projects
31 Leverage pump
stations to convey
stormwater
32 Lighting
36 Loop and spur trails
37 Low income access
38 Low water crossings
39 Low-flow channel
modifications
40 Multi-use publiclyowned properties
41 Onsite water recycling
42 Open space access
ID Building Block Applied
44 Overcrossing
45 Oyster bed restoration
46 Passive space
47 Pedestrian and cyclist
access
48 Permeable paving
49 Plazas
50 Pop-up parks
52 Property acquisition
53 Public art and murals
54 Recreation center
55 Regional gateway
56 Regrading for
landscape topography
restoration
58 Residential zone access
59 Restrooms
60 River amphitheater
61 Rubber dams and
inundation areas
62 Safe crossings
63 Seating
64 Security
65 Shallow groundwater
banking
67 Signage
68 Stream restoration
ID Building Block Applied
69 Sub-regional water
recycling facility
70 Traffic calming
71 Trailheads and staging
areas
72 Transit-oriented
development
73 Tunnels
74 Undercrossing
75 Water capture and
onsite storage
76 Water recreation
78 Shade (veg or
structural)
Opportunity Area
Opportunity ID
Opportunity Assessment

LOWER LOS ANGELES RIVER
Opportunity Assessment

LOWER LOS ANGELES RIVER
68 X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Wrigley Heights River Park
368
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369

3.1 Introduction and Purpose
California Assembly Bill 530 requires the creation of the Lower Los Angeles River Working Group (Working Group) and the development of the Lower Los Angeles River (LLAR) Revitalization Plan (LLARRP). The LLARRP is designed to be a watershed-based, community-centric plan that addresses the diverse needs of the LLAR and its communities.

During development of the LLARRP, the Working Group nominated several projects, templates, and policies to be highlighted as “signature concepts” in the LLARRP. These signature concepts are exemplary of the multi-benefit, community-driven planning process and capture the essence of the LLARRP.

To explore the signature concepts and provide recommendations for subsequent conceptual-level designs, each underwent a planning-level feasibility study to:
• Identify plan element objectives,
• Evaluate site constraints,
• Determine alternative configurations,
• Conduct feasibility level analysis, and
• Review and recommend alternative.

These outcomes enable the evaluation of potential fatal flaws so that each signature concept can be assigned a verdict of “Go” or “No Go” with respect to feasibility of the most critical components. This memorandum addresses each of these outcomes to evaluate only the major feasibility considerations for the seven signature projects in consideration: the Upper Segment Easement (Figure 3.1-1), Cudahy River Road (Figure 3.1-2), Rio Hondo Confluence (Figure 3.1-3), Middle Segment Easement and Multi-Use Crossover (Figure 3.1-4), Compton Creek Confluence (Figure 3.1-5), Wrigley Heights River Park (Figure 3.1-6), and Willow Street (Figure 3.1-7).

Note that detailed evaluation of non-critical components (i.e., those that will not render the project as a whole infeasible) will occur during the next phase of concept development.

The signature templates and policies also underwent feasibility analyses that were slightly different from the process for evaluating the signature projects. The signature templates include concrete channel enhancements, connectivity/complete streets and wayfinding/welcoming, multi-use path enhancements, and improved crossings.

The four signature templates were evaluated for optimal location, physical components, process (including guidelines, best practices, and references for an inclusive design and planning process), operation and maintenance, and programs (lists and examples of current and potential public programs). The concrete channel enhancements were modeled to determine impacts to the water surface elevation and overall conveyance capacity of the river.

The signature policies were evaluated to determine the strengths and weaknesses of the policy, the applicability of the policy to the LLAR, and applicable lessons from existing case studies. The signature policies comprise the Community Stabilization Toolkit and include rent control ordinances, community benefit agreements, no net loss of affordable housing, inclusionary housing policies, locally owned business support, and workforce development. 370
Pages Intentionally Omitted
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3.7 Wrigley Heights River Park
Table of Contents

3.7 Wrigley Heights River Park ....................................................................................................................................... 3.7-1

3.7.1 Background, Objectives, and Building Blocks ............................................................................................ 3.7-3

3.7.2 Existing Conditions, Site Constraints, and Feasibility Considerations .................................................. 3.7-3

3.7.3 Alternative Configurations ............................................................................................................................. 3.7-6

3.7.3.1 Configuration 1: Spreading Basins and Active Recreation ............................................................. 3.7-6

3.7.3.2 Configuration 2: Expanded Spreading Basins.................................................................................... 3.7-6

3.7.3.3 Configuration 3: Based on Long Beach RiverLink ............................................................................ 3.7-6

3.7.3.4 Configuration 4: Active and Passive Recreation............................................................................... 3.7-7

3.7.4 Feasibility-Level Analysis..............................................................................................................................3.7-12

3.7.4.1 Preliminary Hydrologic Modeling ......................................................................................................3.7-12

3.7.4.2 Preliminary Contamination Assessment...........................................................................................3.7-13

3.7.4.3 Infiltration Feasibility Analysis............................................................................................................3.7-18

3.7.5 Alternatives Review and Recommended alternatives ............................................................................3.7-18

3.7.5.1 Initial Cost Estimate ..............................................................................................................................3.7-18

3.7.5.2 Configuration Comparison ..................................................................................................................3.7-18

3.7.5.3 Recommendations.................................................................................................................................3.7-18

3.7.6 Next Steps........................................................................................................................................................3.7-23

3.7.6.1 Additional Required Analyses .............................................................................................................3.7-23 372
List of Figures
Figure 3.7-1. Parcel Ownership Information ....................................................................................................................... 3.7-5 Figure 3.7-2. Plan View of Configuration 1 ......................................................................................................................... 3.7-8 Figure 3.7-3. Plan View of Configuration 2 ......................................................................................................................... 3.7-9 Figure 3.7-4. Plan View of Configuration 3 .......................................................................................................................3.7-10 Figure 3.7-5. Plan View of Configuration 4 .......................................................................................................................3.7-11 Figure 3.7-6. Drainage Area for Wrigley Heights River Park .........................................................................................3.7-12 Figure 3.7-7. GeoTracker Contamination Sites.................................................................................................................3.7-14 List of Tables
Table 3.7-1. Wrigley Heights River Park Site Information ............................................................................................... 3.7-4 Table 3.7-2. Preliminary Hydrologic Modeling Results for Wrigley Heights River Park ..........................................3.7-13 Table 3.7-3. Long Beach Industrial Park .............................................................................................................................3.7-15 Table 3.7-4. Oil Operators, INC............................................................................................................................................3.7-16 Table 3.7-5. BP Pipeline, INC................................................................................................................................................3.7-17 Table 3.7-6. Configuration 1 Initial Cost Estimate ...........................................................................................................3.7-19 Table 3.7-7. Configuration 2 Initial Cost Estimate ...........................................................................................................3.7-20 Table 3.7-8. Configuration 3 Initial Cost Estimate ...........................................................................................................3.7-20 Table 3.7-9. Configuration 4 Initial Cost Estimate ...........................................................................................................3.7-21 Table 3.7-10. Decision Support Matrix...............................................................................................................................3.7-22 373

3.7.1 Background, Objectives, and Building Blocks
The Wrigley Heights River Park area comprises the north and south properties identified in the Long Beach RiverLink Plan, and are located on the east bank of the LA River, north of Wardlow Road and south of the Metro Blue Line in Long Beach, CA. The 405-freeway divides the north and the south properties. The area includes the old Wrigley Heights driving range and the oil operators’ field. This area is approximately 58 acres of blank slate and for this reason, and others, Wrigley Heights River Park has been a prominently discussed opportunity area by the Working Group and the public.

The following suggestions and input were provided by the Working Group, River Segment Committees and the community:
• Expanding Dominguez Gap Wetlands
• Acquire large industrial parcel to create a park
• Habitat restoration
• Trail network along southeastern border and throughout parks • Signage/Navigation
• Capture/treat stormwater
• Groundwater recharge basins with boardwalks and overlooks • Plants/marine species to filter water
• Wetlands
• Soil contamination
• Coastal Prairie
• Multi-purpose bridges
• Active recreation
• Eco-revelatory amphitheater
According to the LLARRP framework (a logical approach developed to assess potential opportunities), all objectives of each plan element apply to the Wrigley Heights River Park site. As such, a cursory desktop review of the site was performed to suggest (based on best professional judgement) what building blocks might be recommended to advance all of the LLARRP objectives. The initial list of recommended building blocks is shown in Attachment A, and was reviewed by the River Segment Committees of the Working Group. The framework suggested that this initial list of building blocks would provide a high progress potential to advance most of the LLARRP objectives.

Per the input from the Working Group and community, and considering the high progress potential implied by the LLARRP framework, the Wrigley Heights River Park site was ultimately nominated by the Working Group as a signature project so that the recommended improvements could be explored in greater detail via a feasibility study.

3.7.2 Existing Conditions, Site Constraints, and Feasibility Considerations Wrigley Heights River Park has been called a gem of the Lower LA River – the area is comprised of two large, empty plots of land – two blank canvasses that present a multitude of options for advancing the objectives of the plan elements. With its proximity to an unconfined aquifer, this site has the potential for groundwater recharge – one of the few locations along the Lower LA River where groundwater recharge is possible.

As shown in Table 3.7-1 and Figure 3.7-1, the majority of this opportunity area is privately owned. The site is primarily owned by Oil Operators Inc, the Sukut Development Inc, and the Los Angeles County Flood Control District. The most apparent constraints include the Metro Blue Line, and the 405 and 710 freeways. The existing stormwater drainage and infrastructure characteristics could pose additional constraints, as could the existence of 374
soil contamination. Each of these constraints could impact the overall feasibility of major building blocks proposed for the Wrigley Heights River Park site.

Therefore, the critical considerations that may impact the advancement of LLARRP objectives at this site are:
• The Metro Blue Line,
• The 405 and 710-Freeway,
• The built environment,
• Gentrification-based displacement,
• Groundwater recharge potential,
• Stormwater and drainage characteristics, and
• Soil contamination.

Table 3.7-1. Wrigley Heights River Park Site Information Attribute Value
Location City of Long Beach
Total opportunity footprint 58 acres (approximately)
Private ownership 55%
Average progress potential per LLARRP framework
(potential objectives advanced)
97%
375
Figure 3.7-1. Parcel Ownership Information
376

3.7.3 Alternative Configurations
Based on site investigations performed and meetings with the Working Group, the following alternatives for the Wrigley Heights Park (North and South). Features proposed as part of all Configurations include:

1. Create bridges and river crossings

2. Remediate Wrigley Heights as required

3. Add Multi-Use paths and trails

3.7.3.1 Configuration 1: Spreading Basins and Active Recreation The proposed variation of this Configuration is to create spreading and recharge basins at Wrigley Heights River Park North and active recreation and park space at Wrigley Heights River Park South (Figure 3.7-2). This Configuration will include:
• At Wrigley Heights River Park North:
o Create wetlands and recharge basins by pulling water from LA River and Dominguez Gap Wetlands – construct spillways between the basins that can double as dry weather overlooks. o Use pump station to pull flows (5-20 cfs) from LA River to the basins. o Construct a culvert to connect Dominguez Gap Wetlands to the basins. • At Wrigley Heights River Park South:
o Create active recreation area (youth soccer fields) with underground stormwater storage and treatment.
o Add a community center and garden with native plantings.

3.7.3.2 Configuration 2: Expanded Spreading Basins
The proposed variation of this Configuration is to create spreading and recharge basins at Wrigley Heights River Park North and South (Figure 3.7-3). This Configuration will include:
• At Wrigley Heights River Park North:
o Create wetlands and recharge basins by pulling water from LA River and Dominguez Gap Wetlands – construct spillways between the basins that can double as dry weather overlooks. o Use the pump station to pull flows (5-20 cfs) from LA River to the basins. o Construct a culvert to connect Dominguez Gap Wetlands to the basins. • At Wrigley Heights River Park South:
o Construct pipes and culverts as necessary under 405 freeway to connect to Wrigley Heights River Park North to continue the wetlands and recharge basins.

3.7.3.3 Configuration 3: Based on Long Beach RiverLink
The proposed variation of this Configuration is to create a wetland connected to Dominguez Gap Wetlands, pull to spreading and recharge basins at Wrigley Heights River Park North, and create an open space destination containing a restored wetland at Wrigley Heights River Park South (Figure 3.7-4). This Configuration will include:
• At Wrigley Heights River Park North:
o Create wetlands and recharge basins by pulling water from LA River and Dominguez Gap Wetlands – construct spillways between the basins that can double as dry weather overlooks. o Use the pump station to pull flows (5-20 cfs) from LA River to the basins. 377
o Construct a culvert to connect Dominguez Gap Wetlands to the basins. o Improve excess River right-of-way as a riparian woodland to complement the adjacent wetland at Dominguez Gap.
• At Wrigley Heights River Park South:
o Create open space destination containing a restored wetland, riparian woodland, pedestrian and bicycle paths, and a neighborhood park with a playground, picnic areas, and other amenities.

3.7.3.4 Configuration 4: Active and Passive Recreation
The proposed variation of this Configuration is to create a wetland connected to Dominguez Gap Wetlands, create active recreation and multi-use trails at Wrigley Heights River Park North, and create an open space destination containing a restored wetland at Wrigley Heights River Park South (Figure 3.7-5). This Configuration will include:
• At Wrigley Heights River Park North:
o Create wetlands by pulling water from LA River and Dominguez Gap Wetlands – construct spillways between the basins that can double as dry weather overlooks. o Create active recreation area (youth soccer fields) with underground stormwater storage and treatment.
• At Wrigley Heights River Park South:
o Create open space destination containing a restored wetland, riparian woodland, pedestrian and bicycle paths, and a neighborhood park with a playground, picnic areas, and other amenities. 378
Figure 3.7-2. Plan View of Configuration 1
379
Figure 3.7-3. Plan View of Configuration 2
380
Figure 3.7-4. Plan View of Configuration 3
381
Figure 3.7-5. Plan View of Configuration 4
382

3.7.4 Feasibility-Level Analysis
As introduced in Section 3.7.2, the major feasibility considerations for the Wrigley Heights River Park site are the built environment (405 and 710 freeways, and Metro Blue Line), stormwater and drainage characteristics, soil contamination, and potential for groundwater recharge (confined aquifer). The following subsections evaluate the alternatives presented in Section 3.7.3 for each of these feasibility considerations.

3.7.4.1 Preliminary Hydrologic Modeling
Desktop analysis of the subwatersheds which drain to Wrigley Heights River Park demonstrates that the storm drains flow to the major trunk lines south of Wrigley Heights River Park and discharge at the outfall point south of Wardlow (Figure 3.7-6). Therefore, this site would not be ideal for any type of regional stormwater capture from the surrounding neighborhoods. Volumes, flows, and contaminant loads for this area are presented in Table 3.7-2.

Figure 3.7-6. Drainage Area for Wrigley Heights River Park 383
Table 3.7-2. Preliminary Hydrologic Modeling Results for Wrigley Heights River Park Modeled Parameter Result
Drainage Area (ac) 412
AAFV (ac-ft/yr) 226
Avg. Annual Depth (in.) 6.6
Avg Annual TN (lb) 2112.6
Avg Annual TP (lb) 331.9
Avg Annual TCu (lb) 37.8
Avg Annual TPb (lb) 35.1
Avg Annual TZn (lb) 155.9
Avg Annual Fecal 10^12 (MPN) 17.2

3.7.4.2 Preliminary Contamination Assessment
The California State Water Resources Control Board GeoTracker database was reviewed to determine if any known contamination issues exist at the site. Three cleanup sites were found – one at Wrigley Heights North, the southeast corner, and two at Wrigley Heights River Park South (Table 3.7-3 through Table 3.7-5 and Figure 3.7-7).

This contamination could potentially interfere with improvements proposed at the site and the next phases of project development should consider whether soil remediation would be included during site redevelopment. 384
Figure 3.7-7. GeoTracker Contamination Sites
385
Table 3.7-3. Long Beach Industrial Park
Field Value
BEGIN_DATE 1/6/2002
BUSINESS_N Long Beach Industrial Park
CALWATER_W Los Angeles River - Los Angeles (412.10)
CASE_TYPE LUST Cleanup Site
CASEWORKER Carmen Piro, Yue Rong (LARWQCB)

CITY LONG BEACH
COUNTY Los Angeles
CUF_CASE NO
DWR_GROUND Coastal Plain Of Los Angeles - Central (4-11.04) GLOBAL_ID SL0603792443
HOW_DISCOV Leak Discovered
LEAD_AGENC LOS ANGELES RWQCB (REGION 4)
LOCAL_AGEN LONG BEACH, CITY OF
POTENTIAL_ OTHER SOLVENT OR NON-PETROLEUM HYDROCARBON
POTENTIAL1 Soil
RB_CASE_NU 70000161
STATUS Inactive
STATUS_DAT 1/29/2015
STREET_NAM Pacific Place
STREET_NUM 4021
ZIP 90806
386
Table 3.7-4. Oil Operators, INC
Field Value
BEGIN_DATE 1/2/1965
BUSINESS_N Oil Operators, INC
CALWATER_W Los Angeles River - Los Angeles (412.10)
CASE_TYPE Leak Action – clean up
CASEWORKER Rebecca Orr

CITY LONG BEACH
COUNTY Los Angeles
CUF_CASE NO
DWR_GROUND Coastal Plain Of Los Angeles - Central (4-11.03) GLOBAL_ID SL2044M1596
HOW_DISCOV Leak Discovered
LEAD_AGENC LOS ANGELES RWQCB (REGION 4)
LOCAL_AGEN LONG BEACH, CITY OF
POTENTIAL_ ARSENIC, BENZENE, CHROMIUM, CRUDE OIL, GASOLINE, LEAD, NICKEL,

TOLUENE, XYLENE
POTENTIAL1 AQUIFER USED FOR DRINKING WATER SUPPLY, OTHER GROUNDWATER (USES OTHER THAN DRINKING WATER), SOIL, SOIL VAPOR
RB_CASE_NU 0093
STATUS Open, Site assessment as of 1/2/2015
STATUS_DAT 1/2/2015
STREET_NAM West Baker Street
STREET_NUM 712
ZIP 90806
387
Table 3.7-5. BP Pipeline, INC
Field Value
BEGIN_DATE 1/2/1965
BUSINESS_N BP Pipeline, INC
CALWATER_W Los Angeles River - Los Angeles (412.10)
CASE_TYPE Leak Action – clean up
CASEWORKER Rebecca Orr

CITY LONG BEACH
COUNTY Los Angeles
CUF_CASE NO
DWR_GROUND Coastal Plain Of Los Angeles - Central (4-11.03) GLOBAL_ID T10000004182
HOW_DISCOV Leak Discovered
LEAD_AGENC LOS ANGELES RWQCB (REGION 4)
LOCAL_AGEN LONG BEACH, CITY OF
POTENTIAL_ BENZENE, DICHLOROETHANE (DCA), GASOLINE
POTENTIAL1 OTHER GROUNDWATER (USES OTHER THAN DRINKING WATER), SOIL,

SOIL VAPOR
RB_CASE_NU 0093A
STATUS OPEN - ASSESSMENT & INTERIM REMEDIAL ACTION AS OF 1/2/2015 STATUS_DAT 1/2/2015
STREET_NAM Golden Avenue
STREET_NUM
ZIP 90806
388

3.7.4.3 Infiltration Feasibility Analysis
A desktop infiltration analysis was performed for the Wrigley Heights River Park site to determine if the site would be suitable for the following:
1) Divert stormwater from the LA River for groundwater recharge/infiltration purposes. a. Approximately 100 cfs of storm-flow from the LA River (either via a pump station or an upstream diversion structure) to the recharge basins.
b. Area for recharge basins is 18-acres, and the depth of each basin would be about 10 feet deep, for a total 180 acre-feet.
2) Structures to be built include:
a. A series of basins that have concrete spillways or pipes to transfer flows between basins. b. A culvert to connect the basin from Dominguez Gap Wetlands to these recharge basins. c. A pump station that will pump flows (5-20 cfs) from the LA River to the recharge basins.

Based on this preliminary analysis, the sites appear suitable for infiltration based on the hydrogeological groups of the surficial soils at the sites; therefore, the proposed spreading basins would be feasible at this location. However, the significant grading and bioremediation efforts at the South site may have significantly altered the near-surface native soils and therefore further evaluations are needed. It is expected based on the history of the site that remediation efforts are still needed at the North site before this site could be considered suitable for stormwater infiltration. The South site has been subject to cleanup efforts and depending on the assessment by the DTSC the site may or may not require additional remediation before it is considered suitable for infiltration.

The full analysis is available in Attachment B.

3.7.5 Alternatives Review and Recommended alternatives
This section forwards the estimated costs associated with the four configurations, the comparison of these four configurations in advancing the objectives of the plan elements, and the final recommended configuration.

3.7.5.1 Initial Cost Estimate
This section forwards the initial cost estimate for the 4 configurations considered (Table 3.7-6 through Table

3.7-9). The assumptions supporting these costs are provided in the table.

Cost Estimate Disclaimer: Please note, these numbers represent the initial cost estimates and are within an orderof-magnitude estimates. These are not AACE Class IV cost estimates.

3.7.5.2 Configuration Comparison
A comparison of the configurations, or configuration screening analysis, was performed and is presented in Table

6.2. This compares each configuration and its ability to advance the objectives of the plan elements. The comparison also includes costs and operation and maintenance considerations.

3.7.5.3 Recommendations
Based on the configuration comparison and the initial cost estimates, as well as feedback from the Lower River Segment Committee and Working Group, Configuration 3 is most ideal for the Wrigley Heights River Park site.

Configuration 3, which draws heavily on the project proposed in the Long Beach RiverLink Plan. As discussed above, this configuration would include:
• At Wrigley Heights River Park North:
o Create wetlands and recharge basins by pulling water from LA River and Dominguez Gap Wetlands – construct spillways between the basins that can double as dry weather overlooks. o Use the pump station to pull flows (5-20 cfs) from LA River to the basins. 389
o Construct a culvert to connect Dominguez Gap Wetlands to the basins. o Improve excess River right-of-way as a riparian woodland to complement the adjacent wetland at Dominguez Gap.
• At Wrigley Heights River Park South:
o Create open space destination containing a restored wetland, riparian woodland, pedestrian and bicycle paths, and a neighborhood park with a playground, picnic areas, and other amenities The other three configurations each present valuable projects proposals that would provide their own benefits to the communities the site serves. Each configuration advances the objectives of the plan elements; however, as demonstrated in Table 6.2, Configuration 3 best advances all the objectives of the plan elements.

Table 3.7-6. Configuration 1 Initial Cost Estimate
Description Quantity Unit Unit Cost Cost
Wetlands 25 AC $36,000 $900,000
Active Recreation Area 700,000 SF $13 $9,100,000
Passive Open Space 139,000 SF $8 $1,042,500
Community Center 1 EA $1,400,000 $1,400,000
Community Garden 1 EA $150,000 $150,000
Culvert 200 LF $500 $100,000
Parking 160,000 SF $7.00 $1,120,000
Picnic Area 1 EA $195,000 $195,000
Multi-use bridge 1 EA $10,000,000 $10,000,000
Multi-use Trails 28500 LF $75.00 $2,137,500
Overlook (bridge) 1 EA $5,000,000 $5,000,000
Overlook/Spillway 2 EA $5,000,000 $10,000,000
Stormwater Treatment Unit 1 EA $1,500,000 $1,500,000
Remediation 150000 CY $300 $45,000,000
Subtotal $87,645,000
Mobilization (10%) $8,764,500
Contingency (40%) $35,058,000
Rounded Total $132,000,000
390
Table 3.7-7. Configuration 2 Initial Cost Estimate
Description Quantity Unit Unit Cost Cost
Wetlands 45 AC $36,000 $1,620,000
Culvert 700 LF $500 $350,000
Multi-use bridge 1 EA $10,000,000 $10,000,000
Multi-use trail 28500 LF $75.00 $2,137,500
Picnic Area 3 EA $195,000 $585,000
Parking 160,000 SF $7.00 $1,120,000
Passive Open Space 139,000 SF $8 $1,042,500
Bridge overlook 1 EA $5,000,000 $5,000,000
Overlook Spillway 3 EA $5,000,000 $15,000,000
Remediation 300000 CY $300 $90,000,000
Subtotal $126,855,000
Mobilization (10%) $12,685,500
Contingency (40%) $50,742,000
Rounded Total $191,000,000
Table 3.7-8. Configuration 3 Initial Cost Estimate
Description Quantity Unit Unit Cost Cost
Culvert 700 LF $500 $350,000
Gateway 2 EA $6,400 $12,800
Wetland 25 AC $36,000 $900,000
Multi-use trail 28500 LF $75.00 $2,137,500
Parking 160,000 SF $7 $1,120,000
Spillway/Overlook 2 EA $5,000,000 $10,000,000
Bridge/overlook 2 EA $5,000,000 $10,000,000
Passive open space 139,000 SF $8 $1,042,500
Amphitheater 1 EA $2,500,000 $2,500,000
Remediation 150000 CY $300 $45,000,000
Subtotal $73,062,800
Mobilization (10%) $7,306,280
Contingency (40%) $29,225,120
Rounded Total $110,000,000
391
Table 3.7-9. Configuration 4 Initial Cost Estimate
Description Quantity Unit Unit Cost Cost
Active Recreation Area 700,000 SF $13 $9,100,000
Gateway 2 EA $6,400 $12,800
Wetland 25 AC $36,000 $900,000
Multi-use trail 25 LF $75.00 $1,875
Parking 160,000 SF $7 $1,120,000
Overlook 2 EA $5,000,000 $10,000,000
Community Center 1 EA $1,400,000 $1,400,000
Community Garden 1 EA $150,000 $150,000
Bridge/overlook 2 EA $5,000,000 $10,000,000
Passive open space 139,000 SF $8 $1,042,500
Amphitheater 1 EA $2,500,000 $2,500,000
Subtotal $36,227,175
Mobilization (10%) $3,622,718
Contingency (40%) $14,490,870
Rounded Total $55,000,000
392
Table 3.7-10. Decision Support Matrix
(1 = most desired, 2 = moderately desired, 3 = moderately less desired, 4 = least desired) Alternative
Connectivity +
Equitable Access Public Space User Experience
Community
Identity Local Economy Education
Habitat
Benefits
Water Quality
Improvements
Water
Retention Amenities
O&M
Requirements
Existing
Infrastructure
Impacts
Estimated
Cost
Configuration 1
Spreading Basins
and Active
Recreation
2 2 1 1 2 2 2 2 2 2 3 1 3
Additional bike and
ped crossings
proposed over
Metro Blue Line
and connecting
DGW West with
East side of LA
River
Active recreation,
community center,
overlooks and
boardwalks
Variety of space
along multi-use
path, connections
to “natural”
processes through
habitat trail and
overlooks, passive
and active
recreation
Large regional
park space with
habitat area,
active
recreation,
trails, and
educational
kiosks
Limited
opportunity at
this stage
Outdoor
education
includes
habitat trail,
and overlooks
Some habitat
and vegetation
opportunities;
active space
impedes
habitat space
development
Stormwater
treatment unit;
spreading
basin and
groundwater
recharge
provide
opportunities
Spreading
basin and
groundwater
recharge in
Wrigley
Heights North
Community
center and
picnic areas,
rest stop,
restrooms,
drinking
fountains
Routine
maintenance of
rest stop area;
periodic clearing
of spreading
basin; repair of
the ball fields
New bridges
across Metro
Blue Line and
LA River;
culvert
connecting to
DGW
$132M
Configuration 2
Expanded
Spreading Basins
2 3 1 1 2 1 1 2 1 3 1 3 4
Additional bike and
ped crossings
Picnic areas and rest
stops with restrooms
and drinking
fountains, overlooks
and boardwalks
Variety of space
along multi-use
path, connections
to “natural”
processes through
habitat trail and
overlooks
Large regional
spreading basin
with habitat
area and
overlooks,
trails, and picnic
areas
Limited
opportunity at
this stage
Outdoor
education
includes
habitat trail,
overlooks
Some habitat
and vegetation
opportunities
Spreading
basin and
groundwater
recharge
provide
opportunities
Spreading
basin and
groundwater
recharge in
Wrigley
Heights North
and South
picnic areas,
rest stop,
restrooms,
drinking
fountains
Rest stop area
will require
routine
maintenance;
spreading basin
will need debris
removed
periodically
New bridges
across; culvert
connecting to
DGW; culvert
or pipes under
the 405
Freeway
$191M
Configuration 3
Based on Long
Beach RiverLink
1 1 1 1 2 2 1 1 2 1 1 2 2
Additional bike and
ped crossings;
gateway from
Wrigley Heights
neighborhood into
park and from park
onto LA River Bike
Path
Open space
destination with
restored wetland,
riparian woodland,
pedestrian and
bicycle paths, and a
neighborhood park
with a playground,
picnic areas
Variety of space
along multi-use
path, connections
to “natural”
processes through
habitat trail and
overlooks; ecorevelatory
amphitheater
Variety of
spaces, habitat
area, trails,
passive and
reflective
space, and
educational
kiosks
Limited
opportunity at
this stage
Outdoor
education
includes
habitat trail,
overlooks, ecorevelatory
amphitheater
Wetland areas
are habitat and
vegetation
opportunities
Stormwater
treatment unit
under;
spreading
basin and
groundwater
recharge
provide
opportunities
Spreading
basin and
groundwater
recharge in
Wrigley
Heights North
Park with a
playground,
picnic areas,
rest stop,
restrooms,
drinking
fountains
Rest stop area
will require
routine
maintenance;
spreading basin
will need debris
removed
periodically
New bridges
across Metro
Blue Line and
LA River;
culvert
connecting to
DGW
$110M
Configuration 4
Active and
Passive
Recreation
1 1 1 1 2 1 1 1 3 1 2 1 1
Additional bike and
ped crossings;
gateway from
Wrigley Heights
neighborhood into
park and from park
onto LA River Bike
Path
Open space
destination with
restored wetland,
riparian woodland,
pedestrian and
bicycle paths, and a
neighborhood park
with a playground,
picnic areas; active
space
Variety of space
along multi-use
path, connections
to “natural”
processes through
habitat trail and
overlooks, passive
and active
recreation
Variety of
spaces, habitat
area, trails,
passive and
reflective
space, and
educational
kiosks
Limited
opportunity at
this stage
Outdoor
education with
habitat trail,
overlooks, ecorevelatory
amphitheater
Wetland areas
are habitat and
vegetation
opportunities
Stormwater
treatment unit
under Wrigley
Heights south
Limited water
retention with
wetlands areas
Park with a
playground
picnic areas,
restrooms,
ecoamphitheater
Rest stop area
will require
routine
maintenance;
active recreation
areas will require
repair to the ball
fields
New bridges
across Metro
Blue Line and
LA River
$55M
393

3.7.6 Next Steps

3.7.6.1 Additional Required Analyses
The initial configurations and considerations above are planning level; a specific site analysis during the design stage would be required to understand precisely how each element fits given a more refined project program. The following additional analyses are recommended.

3.7.6.1.1 All Configurations
Additional required analyses for all the configurations proposed include:
• Collection capacity and storage of stormwater capture along the Wrigley Greenbelt South should be determined,
• Priority species (both plant and animals) should be determined for the habitat and wetland areas, • Flow conditions should be investigated to determine if there is adequate volume for stormwater capture and habitat and wetland area,
• The appropriate water rights for river diversions should be obtained, • Access to the transmission towers should be evaluated, • Structural analysis for all proposed crossings should be conducted for final design, • All proposed crossing should be reviewed and approved by LADWP, • Structural analysis for overlooks should be conducted, • Deeper geotechnical evaluation should be performed,
• Geotechnical evaluation for potential placement of nature center or education signage and kiosks should be performed,
• Wetlands park - hydrologic analysis for flow, capacity, and infiltration should be conducted, • An Environmental Impact Report/Statement (EIR/EIS) may need to be completed to assess any potential environmental impacts, and
• Key studies to assess the potential for environmental and habitat restoration should be performed, and local and native vegetation should be planted to support the native habitat and restore the natural and historical ecosystem wherever possible.

3.7.6.1.2 Configuration 1
Additional required analyses for Configuration 1 proposed include:
• Soil, permits, leadership for community garden should be established, • Grading and soil analysis for ball park and soccer field area should be conducted, and • Soil remediation analyses to determine extent of contamination should be performed.

3.7.6.1.3 Configuration 2
Additional required analyses for Configuration 2 include:
• Permits and requirements for culvert or pipes under the 405-freeway to connect north and south spreading basins should be obtained, and
• Soil remediation analyses to determine extent of contamination should be performed.

3.7.6.1.4 Configuration 3
Additional required analyses for Configuration 3 include:
• Soil remediation analyses to determine extent of contamination should be performed, and • Soil, permits, leadership for community garden should be established. 394

3.7.6.1.5 Configuration 4
Additional required analyses for Configuration 4 include:
• Soil, permits, leadership for community garden should be established, and • Grading and soil analysis for ball park and soccer field area should be conducted. 395
EXHIBIT 9
396
element
City of Long Beach General Plan
creating vibrant and exciting places

LAND USE
DECEMBER 2019
397
“Growth is inevitable
and desirable, but
destruction of
community character is
not. The question is not
whether your part of the
world is going to change.

The question is how.”
Edward T. McMahon
The Conservation Fund
land use
398
Adopted by the City Council on
December 3, 2019
Prepared by Long Beach Development Services
Assisted by MIG and Cityworks Design
City of Long Beach
element
of the City’s General Plan

LAND USE
399

ACKNOWLEDGEMENTS
Mayor and City Council
Honorable Mayor Dr. Robert Garcia, Ed.D.

Dee Andrews, Vice Mayor, 6th District
Lena Gonzalez, Councilmember, 1st District (Former)
Jeannine Pearce, Councilmember, 2nd District
Suzie Price, Councilmember, 3rd District
Daryl Supernaw, Councilmember, 4th District
Stacy Mungo, Councilmember, 5th District
Roberto Uranga, Councilmember, 7th District
Al Austin, Councilmember, 8th District
Rex Richardson, Councilmember, 9th District
Office of the City Manager
Tom Modica, Acting City Manager
Patrick H. West, City Manager (Ret.)
Rebecca Guzman, Acting Assistant City Manager
Kevin Jackson, Deputy City Manager
Teresa Chandler, Interim Deputy City Manager
City of Long Beach Planning Commission
Richard Lewis, Chair
Mark Christoffels, Vice Chair
Ron Cruz
Josh LaFarga
Andy Perez
Jane Templin
Erick Verduzco-Vega
Donita Van Horik, Retired
City of Long Beach Department of Development Services Staff Linda F. Tatum, FAICP, Director
Amy J. Bodek, AICP, Director (Former)
Christopher Koontz, AICP, Planning Bureau Manager
Patricia Diefenderfer, AICP, Advance Planning Offi cer
Alexis Oropeza, Current Planning Officer
Alison Spindler-Ruiz, AICP, Planner
Ira Brown, Planner (Former)
Craig Chalfant, Planner (Ret.)
Fern Nueno, AICP, Planner (Former)
Angela Reynolds, AICP (Ret.)
Pat Garrow (Ret.)
Steve Gerhardt, AICP (Ret.)
Special Thanks
A special thanks is extended to the Long Beach Technology & Innovation Department for their able assistance in the preparation of the maps contained in this document. 400
Pages Intentionally Omitted
401
Context | Understanding Long Beach 55
3Context
and daycare centers and educational health-outreach
programs for families and seniors.

Many of the equity-focused policies contained in this
LUE seek to lessen the disproportionate impacts that
previous land use policies and practices have had on
these communities. In addition, the City has committed
to addressing disparities in impacts and resources by
prioritizing investments in underserved communities. The West Long Beach Livability Implementation Plan and the
Communities of Excellence (CX3) Physical Activity and
Obesity Prevention Plan both guide future improvements in parks and open space, active transportation infrastructure and social and environmental programming to address
health disparities.

SMART CITY
Facets of a Smart City
A “smart” city is one that uses information and
communication technologies to be more intelligent and
efficient in the use of resources. Smart cities are tying together technology innovation, sustainability and energy reduction strategies aimed at reducing municipal costs, minimizing energy use, improving service delivery and
reducing impacts to the environment. Through these
means, smart cities are achieving greater efficiencies in many facets of the urban environment: people, building
and facilities, and government.

Smart Transportation
Smart transportation is a major component of Smart City.

The Mobility Element covers smart transportation features including driverless technology, real-time traffic and
parking data, zero emission technology and intelligent
transportation systems (ITS).

Smart People
Smart cities include smart schools and libraries, which help create smarter people. One of the greatest challenges facing cities and school districts is making education
technologies more efficient. The Long Beach Unified
School District developed a Technology Master Plan that provides a long-term roadmap for the use of technology.

New schools, such as Jessie Elwin Nelson Academy, have
opened with new state-of-the-art technologies, including wireless network systems and the use of tablets, allowing teachers and students to engage in new methods of
teaching and learning. In addition, all of Long Beach’s public libraries offer free Wi-Fi, and library card holders can check out and download digital media free of charge.

Smart Buildings and Facilities
Smart living focuses on the technological advances at home that can provide residents with the comforts of modern
conveniences. Homes can include new technologies to
remotely control lighting, security, energy usage and
landscaping irrigation. Southern California Edison has
implemented smart meters, which enable customers to
review hourly, daily and weekly electricity usage. Through the use of online tools, customers can better understand how much electricity is being consumed, and they can
better manage their energy usage based on real-time
feedback.

Other smart living technologies for the home include
solar power products, smart thermostats, light occupancy sensors, smart phone home automation, home energy
manager, hybrid/electric vehicle plug-in charging stations and smart-grid-ready appliances.

These technological systems aimed at making a building
anticipate energy and water needs and efficiencies can
make a huge difference in consumption, conservation of
resources and homeowner finances.

Smart Government
Long Beach has been active in implementing technological innovations to improve operational efficiencies and
reduce municipal costs. The City created a Technology
and Innovation Commission aimed at advising and
making recommendations to the City Council on matters
pertaining to technology and innovation. The City’s newly renamed Technology and Innovation Department has
completed a number of major initiatives to modernize
its information and communications systems, such as
implementing a new utility customer information system, Wi-Fi in parks deployment, fiber optic network expansion, and developed a series of smart device apps.

The City has launched custom websites to improve
communications with the community. The City also
launched a new online service making it easier for residents to submit code enforcement complaints via website and to obtain various permits online.

December 2019
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132 Land Use Element | City of Long Beach
Implementation
5 No. Implementation Strategies
Time Frames
ShorttermMidtermLongterm Ongoing
LU- M-46
Inventory vacant lots citywide.

Responsible Department: Development Services
Related Policies: LU Policy 18-10, 18-11, 19-2
•
LU- M-47
Work with non-profit housing developers to create and develop affordable housing options.

Responsible Department: Development Services, Health and Housing Services Related Policies: LU Policy 12-1, 13-1
•
LU- M-48
Implement the Housing Element.

Responsible Department: Development Services
Related Policies: LU Policy 12-1, 12-4, 13-1
•
Fair and Equitable Land Use Plan
LU- M-49
Conduct neighborhood and community area assessments to better understand current businesses and services, public facilities and amenities. Determine neighborhoods’ needs for services and facilities and develop strategies to address deficiencies.

Responsible Department: Development Services
Related Policies: LU Policy 14-1, 14-3, 15-1, 17-3
•
LU- M-50
Develop an engagement process to actively involve residents, businesses, property owners and organizations within low-income and minority neighborhoods early in planning development processes involving projects that may result in disproportionately high and adverse human health or environmental burdens to these neighborhoods. Utilize multilingual outreach methods to allow residents whose primary language is not English to be involved in decision-making processes.

Responsible Department: Development Services
Related Policies: LU Policy 15-2, 16-7, 16-11
•
LU-M-51
Work with agencies and organizations to prepare environmental justice studies that evaluate and mitigate the adverse effects of new projects and operations that have the potential to result in disproportionately high and adverse human health or environmental effects on low-income and minority populations.

Responsible Department: Development Services
Related Policies: LU Policy 15-2, 16-6, 16-8, 16-9, 16-10 •
LU- M-52
Continue the community engagement process and outreach to surrounding neighborhoods, stakeholders and businesses to stimulate dialogue and more proactively address community concerns.

Responsible Department: Development Services
Related Policies: LU Policy 15-1, 15-2
•
LU- M-53
Continue to implement the Long Beach I-710 Community Livability Plan aimed at incorporating and prioritizing livability improvements in the I-710 freeway corridor neighborhoods.

Responsible Department: Public Works
Supporting Departments: Development Services; Harbor Department; Health and Human Services; Police Department and Parks, Recreation and Marine
Related Policies: LU Policy 16-4
•
LU- M-54
Continue to implement the West Long Beach Livability Implementation Plan to improve the quality of life in West Long Beach and to bring to fruition the community’s vision of a healthy, vibrant and livable neighborhood though land use planning and capital improvement projects.

Responsible Department: Development Services
Related Policies: LU Policy 16-2, 16-3
•
LU- M-55
Continue to develop and implement innovative programs aimed at reducing the air pollutants from port operations (e.g., San Pedro Bay Clean Air Action Plan, Clean Truck Programs, Main Engine Low-Sulfur Fuel Incentive Program and Shoreside Electricity).

Responsible Department: Harbor Department
Related Policies: LU Policy 10-6, 16-2, 16-3
•
December 2019
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Pages Intentionally Omitted
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136 Land Use Element | City of Long Beach
Implementation
5 No. Implementation Strategies
Time Frames
ShorttermMidtermLongterm Ongoing
LU- M-83
Consult with the US Navy NWS Seal Beach Community Planning Liaison Officer (CPLO) to help identify any critical issues to be considered or addressed in the planning process, define the “military influence area” (MIA), and ensure that the MIA addresses the health and welfare of the public, as well as the military mission. Ensure compliance with SB 1468, to ensure consideration of military readiness in the planning process, compliance with CA 1462 to ensure proper notification to the military..

Responsible Department: Development Services
Supporting Departments: Public Works, Government Affairs Related Policies: LU Policy 8-3
•
Increased and Diversified Open Space
LU- M-84
Increase parks and open space areas to meet the City standard of eight acres of park land for every 1,000 Long Beach residents, particularly in neighborhoods where there is a deficiency in park space.

Responsible Department: Development Services
Supporting Department: Parks, Recreation and Marine
Related Policies: LU Policy 19-1, 19-2, 20-1, 20-6, 20-7 •
LU- M-85
Continue to implement and update the Department of Parks, Recreation and Marine Strategic Plan and the Open Space and Recreation Element.

Responsible Departments: Development Services and Parks, Recreation and Marine Related Policies: LU Policy 19-1, 19-3, 20-2
•
LU- M-86
Update and implement the Long Beach Riverlink Plan to create a continuous greenway of pedestrian and bike paths and linkages along the east bank of the Los Angeles River, as well as to connect to existing and future parks, open space and beaches along western portions of the City.

Responsible Department: Parks, Recreation and Marine
Supporting Departments: Public Works, Development Services Related Policies: LU Policy 19-1, 19-2, 19-3, 20-1, 20-2, 20-3, 20-4, 21-1 •
LU- M-87
Pilot streetlet demonstration projects along Long Beach Boulevard to test the effectiveness and design for permanent streetlet projects. Pilots will range from one day to a yearlong demonstration.

Responsible Department: Development Services
Supporting Department: Public Works
Related Policies: LU Policy 18-7, 18-9, 19-1, 19-2, 19-3 •
LU- M-88
Increase the diversity of urban recreational spaces to include pocket parks, infill parks, community gardens, small green spaces, rooftop gardens, urban agriculture and gardening spaces, paseos, linear parks, small play fields and courts, playgrounds, urban trails and similar urban open spaces.

Responsible Department: Development Services
Supporting Department: Parks, Recreation and Marine
Related Policies: LU Policy 19-2
•
LU- M-89
Focus on locating new parks and open spaces in residual and innovative areas such as remnant freeway rights-of-way, abandoned railway lines, utility corridors, riverfronts and waterfronts, vacant lots, underutilized or irregular parcels and rooftops.

Responsible Department: Development Services
Supporting Department: Parks, Recreation and Marine
Related Policies: LU Policy 18-9, 19-1, 19-2, 20-1
•
LU- M-90
Create joint-use park facilities and work with Long Beach Unified School District to enhance school sites for public use.

Responsible Department: Parks, Recreation and Marine
Related Policies: LU Policy 18-6, 19-1, 19-2
•
December 2019
406
Implementation | Identifying Working Solutions 137
Implementation
5 No. Implementation Strategies
Time Frames
ShorttermMidtermLongterm Ongoing
LU- M-91
Continue to require all new developments to provide usable open space or in-lieu fees aimed at meeting recreational demands.

Responsible Department: Development Services
Related Policies: LU Policy 18-1
•
LU- M-92
Explore development of an aggressive urban forestry plan to enhance existing tree planting programs to increase the number of trees and improve the urban forest along corridors and in neighborhoods.

Responsible Department: Public Works
Related Policies: LU Policy 18-4; UDE Strategy No. 61
•
LU- M-93
Aggressively promote tree planting in City parks and open spaces and promote the tree dedication program.

Responsible Department: Public Works
Related Policies: LU Policy 18-4
•
LU- M-94
Provide opportunities for nontraditional parks and park amenities such as skate/bicycle parks and plazas, roller hockey courts, small tot lots, spray pools, dog parks and ball courts (handball, tetherball, volleyball).

Responsible Department: Parks, Recreation and Marine
Related Policies: LU Policy 19-3
•
LU- M-95
Reuse vacant properties as community amenities such as gardens, parks or temporary green spaces to reduce blight and safety issues, increase residents’ access to needed parks and open spaces, and spur additional investment in neighborhoods.

Responsible Department: Development Services
Supporting Departments: Parks, Recreation and Marine, City Manager (Sustainability) Related Policies: LU Policy 19-2
•
LU- M-96
To address existing homes in the designated “Open Space” area of Rosie’s Dog Beach, balancing the needs of private property owners and beach visitors, continue the Zoning Code provision to allow basic remodels by-right as well as additions up to 250 square feet for residential uses located within the Open Space PlaceType.

Responsible Department: Development Services
Related Policies: LU Policy 16-6
•
Natural Resources Restoration and Reconnection
LU- M-97
Leverage public and private dollars to implement habitat and wetland restoration projects in the community. Develop new and enhance existing marine life habitats.

Responsible Departments: Development Services, Parks, Recreation and Marine Related Policies: LU Policy 20-1, 20-3, 20-4, 20-8
•
LU- M-98
Consult with non-profit organizations, regional agencies and property owners to develop programs and mechanisms to acquire and restore lands.

Responsible Department: Development Services
Supporting Department: Harbor Department
Related Policies: LU Policy 20-1 , 20-8, 20-11, 21-3
•
LU- M-99
Develop feasibility plans that identify approaches and financial opportunities to protect and restore the City’s urban creek system, storm channels, river channels, wetlands and habitat areas.

Responsible Department: Public Works
Supporting Department: Development Services
Related Policies: LU Policy 20-3, 20-4, 20-8
•
December 2019
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Pages Intentionally Omitted
408
Implementation | Identifying Working Solutions 147
Implementation
5 10. Improve quality of life, health and overall livability through the implementation of the West Long Beach
Livability Implementation Plan.

11. Respect and maintain the equestrian uses within
Wrigley Heights and promote shared use and
maintenance of the area trail system.

December 2019
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Pages Intentionally Omitted
410
Long Beach Development Services
411 W. Ocean Blvd., 3rd Floor
Long Beach, CA 90802
Visit us at longbeach.gov/lbds
Email us at [email protected]
@LongBeachBuilds
This information is available in alternative format by request at (562) 570-3807 For an electronic version of this document, visit our website at longbeach.gov/lbds. 411
EXHIBIT 10
412
413
414
415
416
City of
Signal Hill

ORANGE CO
(Rossmoor)
City of
Paramount
City of
Los Angeles
LA
CO
City of
Artesia
City of
Cerritos
City of
Hawaiian Gardens
LA CO
(Rancho Dominguez)
LA
CO
City of
Compton
LONG
10TH
WILLOW
SPRING
CLARK

ARTESIA

STEARNS

WARDLOW

BELLFLOWER
OCEAN

ATLANTIC

ARTESIA

PALO VERDE
FWY
DIA

LAKEWOOD
ISLAND
BIXBY

MAGNOLIA

ATHERTON
PARK

PACIFIC

WOODRUFF
MARKET
XIMENO

PACIFIC

SAN ANTONIO
DOWNEY
LOYNES
APPIAN

PARAMOUNT
SHORE

HARDING

ALAMITOS
GARDEN

GROVE FWY

LIVINGSTON

GREENLEAF

NORWALK
72ND

SAN GABRIEL RIVER FWY

SANTA FE

DEL AMO
70TH

HILL LOS COYOTESCHERRY
WILLOW

ATLANTIC

REDONDO
OCEAN

CARSON CARSON
LONG
SOUTH
SPRING
ORANGE
LUTHER

BROADWAY HARBOR SCENIC

CLARK NIETO
2ND
7TH
FWY
FWY

PACIFIC COAST
CHERRY

KING JR
TEMPLE

ANAHEIM
CHERRY
ORANGE
4TH

STUDEBAKER
COAST
NE LI
BEACH
BEACH

TERM INAL
MARTIN
City of
Carson
City of
Lakewood
City of
Seal Beach
City of
Bellflower
City of
Norwalk
City of
Los Alamitos
5 3
7 2
8 9
1 6 4
H
H
H
H
H
H
q
T:\_DevelopmentServices\2017\Planning\HL and HR overlays in GIS CHG142109 0 0.5 1 2
Miles
Horse Overlay

CITY OF LONG BEACH
LEGEND
Council District
H (Horse Overlay)
417
EXHIBIT 11
418
8/29/22, 10:55 PM Long Beach keeps pace, leads efforts to become water independent – Press Telegram https://www.presstelegram.com/2022/08/16/long-beach-keeps-pace-leads-efforts-to-become-water-independent/ 1/4 By HARRY SALTZGAVER | [email protected] | Grunion Gazette PUBLISHED: August 16, 2022 at 5:15 a.m. | UPDATED: August 16, 2022 at 11:01 a.m.

Commission 22A in area III of El Dorado Park East, is under construction for a water well, in Long Beach on Monday, August 15, 2022. (Photo by Brittany Murray, Press-Telegram/SCNG)
California’s mega-drought continues worsening and now officials say it’s time to prepare for a drier, hotter future here.

Earlier this month, Gov. Gavin Newsom released his updated water supply plan for the state, concentrating on recycling, conservation, more storage and the once-too-expensive desalination process as sources for more water. Gone is the emphasis on capturing snow runoff and shipping it to Southern California with a more efficient State Water Project.

Long Beach keeps pace, leads efforts to become
water independent
Gov. Newsom’s new water policy focuses on local, regional solutions — but Long Beach is ahead of the game.
419
8/29/22, 10:55 PM Long Beach keeps pace, leads efforts to become water independent – Press Telegram https://www.presstelegram.com/2022/08/16/long-beach-keeps-pace-leads-efforts-to-become-water-independent/ 2/4 Recycled water
But Long Beach’s Water Department hasn’t been waiting for state leadership:

Even before a Fiscal 2023 budget is approved, new wells are being poked into the groundwater aquifer. “Local groundwater is key for us,” Chris Garner, the Water Department’s general manager, said last week. “We’re replacing wells that are 80 to 100 years old. These new wells will have 10 times the capacity.” Five wells are in the works or underway. Three will replace old wells and two more are being drilled to add capacity.

Long Beach traditionally gets 60% of the 50,000 acre feet of water the city uses on average annually from ground wells.

Another 30% is imported through the Metropolitan Water District from the Colorado River and Northern California. The final 10% is recycled water.

Except currently, the city’s wells can provide no more than 55% of the city’s needs. That’s expensive, because the city can pump and treat water for a far lower cost than what it takes to buy water from MWD.

Ground water is important in many areas of the state, and one of Newsom’s area of emphasis is desalinating brackish and salty water in groundwater basins. But during the drought that has been a frequent challenge over the last decade, overuse of ground basins — over-pumping in the Central Valley literally caused land there to sink — prompted a state law requiring groundwater pumpers to come up with a way to regulate how much water is taken out of the ground. “Our ground water level is pretty healthy,” Anatol Falagan, Long Beach Water’s assistant general manager, said. “We’ve been adjudicated (regulated) since the 1950s. The WRD (Water Replenishment District) has done a pretty good job with the legal restrictions.”
Long Beach owns water rights that would allow the city to pump 35,000 acre-feet of water a year.

An acre-foot once was enough water to supply two average households a year — but conservation in California has raised that to about three households. In fact, Long Beach long has been a leader in water conservation, Garner said, and that has continued into the current drought.

In order to find fresh water, wells are drilled hundreds of feet, sometimes a thousand feet, down. And the aquifer is not an underground lake — it is water suspended in sandy layers of soil — so well technology can be complex. It costs around $4 million to drill a well.

Newsom’s statement touted the $8 billion earmarked for water infrastructure and management over the last three years.

Another $5.2 billion for the next three years was part of the current state budget, with an additional $2.8 billion for drought relief to hard-hit communities, water conservation, environmental protection for fish and wildlife and long-term droughtresiliency projects. It’s unclear how much of that will come to Long Beach.

Newsom’s water plan calls for at least 800,000 acre-feet of new water per year by 2030 to be created through treating recycled water for reuse. That policy already is in place in several areas, including Long Beach.

The Water Replenishment District partners with the Los Angeles County Sanitation Districts to take treated sewage water and treat it even further, to the point it would be safe to drink. 420
8/29/22, 10:55 PM Long Beach keeps pace, leads efforts to become water independent – Press Telegram https://www.presstelegram.com/2022/08/16/long-beach-keeps-pace-leads-efforts-to-become-water-independent/ 3/4 Stormwater
They have been doing this for years at the Leo J. Vander Lans facility in Long Beach, near the San Gabriel River. After an expansion in 2014, the plant is now capable of treating 8 million gallons of water a day, which is used to create the saltwater barrier, provide recycled water to the Long Beach Water Department for industrial uses and in irrigation, and to help replenish the groundwater basin.

In recent years, WRD has ratcheted up its efforts, pumping waste water to Pico Rivera, where it is treated at the Albert Robles Center then sent back into the top of the groundwater basins in LA County. The Robles plant can treat up to 14.8 million gallons a day.

The Metropolitan Water District, meanwhile, once focused solely on importing as much water as possible into Southern California. But it is now getting into the recycled water business as well.

A demonstration plant is operating at the Joint Water Pollution Control Plant in Carson, processing up to 500,000 gallons of water a day.

Treatment involves a three-step process that takes already purified wastewater to the potable reuse level.

Now called Pure Water Southern California, the full-scale project is in the environmental review stage now. Current estimates are that the project would cost $3.4 billion to build and $129 million annually to operate, resulting in a water cost of $1,830/acre-foot.

It won’t happen tomorrow, though.

The environmental review and permitting is expected to take through 2024. It will take another eight years to build the project and attendant pipelines. But it will be able to produce 150 million gallons of water daily, enough to serve more than 500,000 homes.

Newsom’s plan also calls for capturing stormwater — particularly when there are high flows because of rainstorms — treating and storing it as another water source. While there are several studies underway, that source is not as developed as other options.

In Long Beach, for example, the stormwater capture system is operated by the city’s Public Works Department while the water and sewer systems are the Water Department’s responsibilities. There are no current plans to combine the systems’ management or operation.

Working together — regionally and statewide, as well as locally — ultimately will be the key to solutions, Garner said. “Without Metropolitan’s help, we can’t get all the agencies together,” he said. “In Southern California, there are five electricity providers, 40 natural gas providers. There are thousands of water agencies. “We all have a problem,” Garner added, that “we all need to solve.” 421
EXHIBIT 12
422
712 Baker St FEIR - Tribal Culture
Comments re IVN. Tribal Cultural Resources
The potential impacts of the 714 Baker St Project on tribal cultural, archaeological, and historic resources are highly significant and the proposed mitigations are grossly insufficient.

The project site has cultural and historic significance to tribal peoples.

For thousands of years, the Tongva village of Tevaaxaanga was located along the river here. Sacred objects (cogstones) and other tribal cultural materials (obsidian flakes) have been unearthed nearby.

As stated in LSA’s Cultural Resource Study for the nearby Pacific Place project, “Creeks and rivers are of importance to humans - pre-contact populations included - and archaeologists acknowledge that archaeological sites are often located near natural water sources....there is always a potential for archaeological resources to be uncovered during grading activities, thus resulting in a potentially significant impact…..the absence of specific site information in the sacred lands file database does not indicate the absence of cultural resources.”
EIR omits factual documentation re tribal sites and history Tribal history has always been known to tribal peoples. Indigenous cultures are now understood in the context of human history, and what was once presumed to be unknowable is now recognized as factual evidence. Yet this report omits the well documented history of the Tongva, a culture that has occupied the project area for more than 10,000 years and had multiple villages, including Tevaaxaanga and Tibahanga, along this section of the river in Long Beach. The highly significant cogstones found at Rancho Los Cerritos should be referenced as should the Tongva’s spiritual beliefs, skill in land management, navigation and trade, and the the tribe’s considerable status and influence on Southern CA tribal culture.

There is no mention of tribal life after invasion and colonization, including tribal contributions to/suffering at Mission San Gabriel, Rancho Los Cerritos, Rancho Los Alamitos, and into modern times. Nor is the history of tribal resistance to genocide, including that of contemporary Tongva descendants who continue to maintain tribal lifeways, protect tribal lands, and advocate for indigenous rights, acknowledged here.

From the Spanish Rancho Period until the late 20th century, the project site was part of Rancho Los Cerritos and home to Tongva peoples. The report makes no mention of the historic Rancho Los Cerritos adobe built by the Tongva and within a mile of the project area. While the Flints and the Bixby’s and Mr.

Wilmore are presumed to have a cultural connection to the project site, the Tongva who continue to live in Long Beach and contribute community knowledge and to cultural events in the neighborhood at Rancho Los Cerritos are MIA.

There are multiple sources that document tribal culture in the immediate vicinity of the project site at Rancho Los Cerritos, including the discovery of highly significant and rare cogstones. Additionally both Rancho Los Cerritos and Rancho Los Alamitos have their own archives and publications (ie Ancestor, Oh My Ancestor), documenting local tribal history. UCLA has a mapping project of Tongva village sites, several in Long Beach. Additionally, there are interviews with tribal historians and scholars - the problem is not a lack of information, it is the systemic refusal to consult anything other than what someone dug up and decided to write about as an ‘archaeological” find. 423
The Cumulative Impacts to tribal culture and peoples have not been discussed.

The analysis of cultural resources neither acknowledges the existence of nor considers the cumulative impact on these resources. According to CEQA, the importance of tribal cultural resources is the value of the resource to California Native American tribes culturally affiliated with the Project Area. Therefore, the issue that must be explored in a cumulative analysis is the cumulative loss of tribal cultural resources.

For tribal cultural resources that are avoided or preserved through dedication within open space, no impacts would occur. However, if avoidance or dedication of open space to preserve tribal cultural resources is infeasible, those impacts must be considered in combination with tribal cultural resources that would be impacted for other projects.According to CEQA, the importance of tribal cultural resources is the value of the resource to California Native American tribes culturally affiliated with the Project Area.

Therefore, the issue that must be explored in a cumulative analysis is the cumulative loss of tribal cultural resources.

The cumulative impact of construction on unceded tribal lands, with or without salvage archaeology, is the ongoing erasure of recognizable and ancient landforms that hold the history of the first peoples and possibly their ancestors as well. Especially in urban areas, this is of little consequence to private and public landowners and regulatory agencies who see land as without spirit, without agency, without power.

There is no mitigation for this lack of consciousness and the fact that it continues to destroy tribal places and ways of life.

Alternatives to project that protect and respect tribal culture not been considered.

While the Lead Agency (the City of Long Beach) may not yet have determined that the project site is eligible for Tribal Cultural Landscape Status, we ask that the City consider doing so and set aside funds to purchase the property as park space in a park poor section of the city. The City of Long Beach has not officially recognized any sites honoring the Tongva, not even the Puvungna Village Site, listed National Register site of Places.

Nor, in spite of SB 18, has there been an effort to set aside known tribal cultural or archaeological sites as protected/undisturbed public open space. Instead, it is routine to undervalue and under report the significance of sites slated to be developed in terms of both existing and potential tribal and archaeological resources.

The mitigations in the DEIR lack a basic commitment to tribal survival and continue to rely on the power of the state over the lands and the culture of the indigenous peoples of California. The LCWTF acknowledges the right of California’s tribal peoples to define tribal culture and determine the significance of certain places and tribal cultural resources. We do not accept as legal or ethical the current practice of allowing the archaeologist, the Lead Agency, and/or the property owner to determine mitigation measures for tribal lands, human remains, and objects because this denies both tribal sovereignty and equity.

The NAHC identifies a primary goal for Lead Agencies under AB 52 to “Build working relationships with tribes that are traditionally and culturally affiliated to the project area or to your agency’s geographic area of jurisdiction.” The City of Long Beach, most especially the Department of Development Services, has failed to do so. As a result, tribal leaders who seek to protect tribal Sacred Sites, village sites, and natural open spaces from development have NO ALLIES at any level of City government. As individual projects 424
are proposed and move through the regulatory process, the response from City staff to tribal groups is lacking in cultural sensitivity if not outright hostile. 425
No salvage archaeology is proposed for this project. Therefore, the archaeologist and tribal monitor can only hope to spot evidence of human occupation in soils as they are exposed, scooped up, graded, and bulldozed by heavy machinery during construction itself. This is not really a legitimate methodology or valid scientific approach, but simply a cost effective way of moving the project forward at the expense of both academic and tribal cultural knowledge.
426
EXHIBIT 13
427

CARLSBAD
FRESNO
IRVINE

LOS ANGELES

PALM SPRINGS

POINT RICHMOND

RIVERSIDE

ROSEVILLE

SAN LUIS OBISPO
20 Executive Park, Suite 200, Irvine, California 92614 949.553.0666 www.lsa.net August 21, 2020
Annie Baek
Artesia Acquisition Company, LLC
811 North Catalina Avenue, Suite 1306
Redondo Beach, CA 90277
Subject: Focused Special-Status Plant Species Surveys for the Industrial Self-Storage/RV Parking Project at 3701 Pacific Place, Long Beach, California
Dear Ms. Baek:

This letter report summarizes the findings of special-status plant species surveys conducted for the Industrial Self-Storage/RV Parking Project at 3701 Pacific Place (project), Long Beach, California (see Figure 1; all figures are provided in Attachment A).

INTRODUCTION
The surveyed project area is located north of Interstate 405 (I-405), east of Interstate 710 (I-710) and the Los Angeles River, and west of the Los Angeles Metropolitan Transportation Authority (Metro) A Line light rail tracks and Los Cerritos Park. Access to the site is currently provided at the intersection of Pacific Place/I-405 and the I-710 northbound on-ramps. In 1926, oil operators owned the site, which functioned as a receiving terminal for waste material from oil production activities.

Partial cleanup took place in the 1970s and involved removal, treatment, and replacement of sump materials. Prior to the 2000s, the entire site was covered with fill material, which varied in thickness from 2 to 10 feet.

In the mid-2000s, the site operated as the Long Beach Golf Learning Center. The Golf Learning Center is no longer in operation and is vacant. Ornamental plants dominate the parking lot area on the south side of the project site, and the remaining project area (the former driving range) to the north has become dominated with nonnative vegetation and scattered native plant species. In addition, the site is currently highly disturbed by unauthorized off-road vehicle use. The Artesia Acquisition Company, LLC, (client) is the current owner of the project site.

METHODOLOGY
On August 7, 2020, LSA senior biologist Jim Harrison conducted a site visit to survey for specialstatus plant species occurring on site. However, the survey was only partially completed (with the client’s knowledge). During an unrelated site visit conducted by LSA senior biologist Lonnie Rodriguez on August 12, 2020, it was observed that an on-site area having vegetation that had not been surveyed on August 7 had been cleared (see Figure 2). The client was notified and indicated that no further vegetation clearing would occur on site until after completion of the focused surveys. On August 17, 2020, LSA senior biologists Jim Harrison and Lonnie Rodriguez returned to the project site and completed the focused survey for special-status plant species occurring on site. 428
8/21/20 «\\vcorp12\projects\ISP1901\Biology\Special-Status Plant Surveys\Special-Status Plant Surveys_Letter Report.docx» 2 At that time, LSA surveyed the remaining areas not surveyed on August 7 and mapped the area where vegetation had been removed (see Figure 2). At the completion of the August 17 survey, all vegetated areas had been surveyed on foot to identify the potential for or actual occurrence of any special-status plant species in the project area.

In addition, LSA completed mapping the locations of, and quantifying/estimating, the only specialstatus plant species (i.e., the southern tarplant [Centromadia parryi ssp. australis]) observed on site.

See Figure 2 for locations of the southern tarplant on site. Areas having more than 15 southern tarplant individuals were mapped electronically using the ArcGIS Collector App and were physically demarcated in the field with wooden lath and flagging ribbon in order to facilitate the salvage of the associated topsoil for future translocation of the southern tarplant. This mapping information was used to create Figure 2.

FINDINGS
During a biological resources assessment conducted by LSA biologists Lonnie Rodriguez and Jeremy Rosenthal on December 6, 2019, LSA identified and mapped the occurrence of approximately 250 southern tarplant individuals within the project area limits (see Figure 2). The southern tarplant, having a California Native Plant Society (CNPS) Rare Plant Rank of 1B.1, was the only special-status plant species observed on site, both in December 2019 and in August 2020.

Based on the conclusions in the Biological Resources Assessment report, 1 the special-status plants of
primary focus during the surveys conducted on August 7 and 17, 2020, were Coulter’s saltbush (Atriplex coulteri), Parish’s brittlescale (Atriplex parishii), lucky morning glory (Calystegia felix), decumbent goldenbush (Isocoma menziesii var. decumbens), Coulter’s goldfields (Lasthenia glabrata ssp. coulteri), prostrate vernal pool navarretia (Navarretia prostrata), San Bernardino aster (Symphyotrichum defoliatum), and any additional southern tarplant individuals. The area where vegetation had been cleared (see Figure 2), which had not been surveyed on August 7, was surveyed and mapped on August 17, 2020; however, while most of the cleared vegetation had been removed from the area, some remnant vegetative material was present. Among this remaining plant material were some southern tarplant branches with flowers. Nevertheless, there was no way to ascertain how many or how widespread these southern tarplant individuals may have been in the cleared area.

During focused surveys conducted in August 2020, LSA observed and mapped approximately 580 additional southern tarplant individuals located in areas where they were not observed in 2019.

Therefore, when combining the results from 2019 and 2020, LSA has estimated a total of approximately 830 southern tarplant individuals occurring within the project limits, all of which would be permanently impacted by the proposed project.

No other special-status plant species were observed during site surveys conducted in 2019 or 2020.

Furthermore, due to the high level of ongoing disturbance within the project area and the

1 LSA, Inc. 2020. Biological Resources Assessment for the Industrial Self-Storage/RV Parking at 3701 Pacific Place, Long Beach, California. Prepared for InSight Property Group. 429
8/21/20 «\\vcorp12\projects\ISP1901\Biology\Special-Status Plant Surveys\Special-Status Plant Surveys_Letter Report.docx» 3 prevalence of ruderal, nonnative plant species on site, it is highly unlikely that any of the other special-status plant species identified in the Biological Resources Assessment will occur in the project area.

Should you have any questions regarding the findings of this focused special-status plant species letter report, please contact me at (949) 553-0666 or [email protected].

Sincerely,
LSA Associates, Inc.

Jim Harrison
Senior Biologist
Attachments: Figures 1 and 2
430

FOCUSED S PECIAL - S TATUS P LANT S PECIES S URVEYS
A UGUST 2020
INDUSTRIAL S ELF - S TORAGE /RV P ARKING AT 3701 P ACIFIC PLACE

LONG BEACH , C ALIFORNIA
\\vcorp12\projects\ISP1901\Biology\Special-Status Plant Surveys\Special-Status Plant Surveys_Letter Report.docx «08/21/20»

ATTACHMENTS
FIGURES 1 AND 2
Figure 1: Regional and Project Location
Figure 2: Locations of Southern Tarplant Occurrences
431
Project Location
SOURCE: USGS 7.5' Quad - Long Beach (1978), CA
I:\ISP1901\GIS\MXD\ProjLoc.mxd (12/30/2019)
FIGURE 1
Industrial-Self Storage/RV Parking at
3701 Pacific Place
Regional and Project Location
0 1000 2000
FEET
LEGEND
Project Location
Los Angeles
County
Orange
County
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Project Location
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§¨¦605 §¨¦5
§¨¦405
Project Vicinity
432
MARION

SAN ANTONIO
AMEBCO

DEL MAR

PACIFIC

TERRYLYNN
§¨¦405
LEGEND
Project Limits
Southern Tarplant, Observed December 2019 (250±)
Southern Tarplant, Observed August 2020 (580±)
Vegetation Removal between 8/7/2020 and 8/17/2020
SOURCE: Nearmap (5/19/2020)
I:\ISP1901\GIS\MXD\Bio\SouthernTarplant_2019_2020_Observations.mxd (8/21/2020) FIGURE 2
Industrial-Self Storage/RV Parking at
3701 Pacific Place
Locations of Southern Tarplant Occurrences
0 60 120
FEET
433
EXHIBIT 14
434
435
436
1 Scott Kinsey
From: Richard Gutmann
Sent: Thursday, September 01, 2022 1:17 PM
To: Charles Parkin; CityAttorney; Christopher Koontz; Amy Harbin; Scott Kinsey; PlanningCommissioners; Subject: Postpone Planning Commission Meeting
‐EXTERNAL‐
To whom it may concern,
I would ask that tonight's Planning Commission meeting on the 712 W.

Baker Street project be postponed until the legality of Mayor Garcia's letter in support of the project can be clarified.

Also, I do not think it is legal to approve this project before the cleanup of the polluted site has been signed off on by the Los Angeles Regional Water Quality Control Board. Cleanup efforts have been going on for three decades and the job is still not finished. It makes no sense to approve a project when there is no telling how long, if ever, it will take to make the site inhabitable.

Sincerely,
Richard Gutmann
Long Beach, CA 90806-1117

1 Scott Kinsey
From: Renee Lawler
Sent: Thursday, September 01, 2022 1:51 PM
To: PlanningCommissioners; Scott Kinsey; Amy Harbin; Christopher Koontz; Cc:; Cc:

Subject: Planning Commission Agenda - Item 2 Sept. 1, 2022 Agenda 712 Baker St. FEIR Attachments: Horse Overlay District Municipal Code Chapter 21.38 and Planning commission Horse Overlay Ordinance letter 08 30 1977.pdf; Chris Koontz Horse Overlay Zones LUE 12 06 19.pdf; 1977EIREquestrianZoneMapSanFranciscoAve.pdf; City Council Meeting 08 30 1977 Horse Overlay Ordinance NO C3600 discussion and vote.pdf
‐EXTERNAL‐
Dear Commissioners and Decision-Makers:

I respectfully ask you stand by and adhere to your predecessors’ zoning decisions, and not approve this FEIR, Zoning Change, Site Plan Review, Tract Map, Development Agreement, and Street Vacations of Baker St. and Wardlow Rd. right of way.

This site carries a Horse Overlay zoning created to protect and preserve a specific community, the equestrians dating to the Spanish and rancho periods, who have cultural significance.

Tongva tribal representation and cultural preservation is also of a high level of importance and should be a consideration at this location as well.

The Horse Overlay has additional requirements, which supersede any “underlying zoning” requiring added low density to provide sufficient space for the health, safety and survival of the horse community in the region.

When a Horse Overlay Zone is residential, R-1, for instance - the lot sizes must be at least 8000 s.f., and the livable housing built only on the front 50% of the lot, 25-100’ set-backs from the house to the horse barn or corral at the back of any lot, and private trail easements to the main regional trail, along the base of the LA River. This proposal does not meet that minimum lot size, set back and trail easement criteria!
Furthermore, the proposed Wardlow right of way ingress/egress will remove one of the current trail easements that runs parallel along Wardlow from the site to the Regional Trail and will create substantial traffic hazards. That easement provides connectivity from this horse zone to the regional LA River trail and to other horse communities to the south and north.

The 6 zones were established in 1977 - most along the LA River Bridle and Hiking trail, which has been in continuous use by horses since the 1700s. This adjacent regional trail is the linear “mobility corridor” providing connectivity between the Horse overlay zones and the equestrian communities to the north and south. To develop any Horse zone into high density that does not provide sufficient lot sizes and open 2 space connections to allow for equestrian use now or in the future, is the same as removing that zoning. The result will be furthering the demise of a minority group with cultural significance and doing so in a manner of social inequity and injustice.

The proposed plan does not meet the low density and open space Horse Overlay requirements for residential or commercial equestrian activities as provided for in 1977. That decision came after full EIR review, which clearly identified the need to protect and preserve the equestrian community for their historic and cultural contributions to the growth of California and its economy. The Horse overlay and 6 zones were created in order to do just that - protect a lifestyle and living history; and it received full approval by the Planning Commission and unanimous approval by City Council as well.

Both Planning Commission and City Council had the foresight to protect our living history through the Horse Overlay in 1977, and again in the LUE/General Plan stating in 2019 the “Wrigley Heights Equestrian Zone will remain”.

As a board member of Riverpark Coalition, I agree with the comments made by our attorneys, Chatten-Brown, Carstens & Mineer and ask that you not approve this FEIR, Zoning Change, Site Plan Review, Tract Map, Development Agreement, and Street Vacations of Baker St. and Wardlow Rd. right of way.

Sincerely,
Renee Lawler

1 Scott Kinsey
From:

Sent: Thursday, September 01, 2022 12:47 PM
To: Charles Parkin; CityAttorney; Christopher Koontz; Amy Harbin; Scott Kinsey; PlanningCommissioners; Subject: Mayor violates law
‐EXTERNAL‐
To Whom It May Concern:

In the staff report for today's Planning Commission hearing for 712 Baker St. Project, there is letter of support from Mayor Garcia. It is my understanding that neither the Council nor the Mayor can comment on issues before the Planning Commission, as these will be coming to them for a vote.

It would appear that today's hearing should be postponed until this matter is clarified, along with other possible violations, such as no Story Poles for the 3 story height increase and an illegal requirement for name and address in order to make public comment.

I would appreciate a prompt response to these violations.

Ann Cantrell
From:

To: Charles Parkin; CityAttorney; Christopher Koontz; Amy Harbin; Scott Kinsey; PlanningCommissioners; Subject: Mayor violates law
Date: Thursday, September 01, 2022 1:13:50 PM
-EXTERNALTo Whom It May Concern:

I have been informed that the mayor has tendered a letter of support for the 712 Baker St. project, which is NOT LEGAL. Neither he nor council can comment on issues before the Planning Commission, as the subjects of commission meetings are later tendered to council for their approval or denial (of course the latter never happens).

Today’s hearing MUST be postponed until this matter is clarified, along with other possible violations for the project. Your defiance of this issue will force me too start a petition to recall every last one of you. Starting with Robert Garcia, whose dictatorial rule of this city has made it nearly unlivable.

Anne Proffit
90802
1 Scott Kinsey
From: R.M. Holman
Sent: Thursday, September 01, 2022 12:32 PM
To: CityAttorney; Christopher Koontz
Cc: Amy Harbin; [email protected]; PlanningCommissioners; Scott Kinsey; CityClerk;
Heather Flores;
Subject: Re: Planning Commission 9/1/22 Agenda
‐EXTERNAL‐
Mr Koontz,
I support Mr Ovalle's comments and stand with him against this unacceptable behavior by the City.

The information for the registration is marked as "Required" on this survey, one cannot complete it and submit it without providing the information, therefore it is grossly illegal and clearly demonstrates that the City of Long Beach is in violation of state law, and based on your comments, apparently nobody even knows what or how it is being asked for.

I demand that the meeting be postponed and then rescheduled once this issue has been resolved to the satisfaction of all taxpayers involved.

I have included the city attorney on this message in the hope that they too will recognize this failure of democracy and assist leadership in correcting this properly.

Sincerely,
Roger Martin Holman
On Thu, Sep 1, 2022 at 11:56 AM Carlos Ovalle > wrote:

Mr. Koontz,
You're incorrect. The Planning Commission page specifically states, "If you plan to attend virtually and wish to speak on an item, please fill out the virtual speaker card." It does not state that it is voluntary as required by law. Furthermore the link to the Virtual Speaker Card Form results in the attached form that clearly requires those items specifically prohibited by California law such as name, address, and 2 whether one is for or against the agenda item. It is impossible to submit the form without any of the required information completed.

My requests stand.

Sincerely,
Carlos Ovalle
On Thu, Sep 1, 2022 at 11:45 AM Christopher Koontz <[email protected]> wrote:

Mr. Ovalle,

The city requests but does not require that information. Please submit what you are comfortable submitting, only your name and item # are required.

Thank you,

Christopher Koontz, AICP
Acting Director

Development Services
411 W. Ocean Blvd., 3rd Floor | Long Beach, CA 90802
Office: 562.570.6288 | Fax: 562.570.6068

Once your permit application has been processed/approved, you may schedule a building inspection by using the link below. For applications requiring plan check, project status may be viewed online using the appropriate link below. Please visit our website to view current processing times. 3 From: Carlos Ovalle >
Sent: Thursday, September 1, 2022 11:39 AM
To: Amy Harbin <[email protected]>
Cc: ; PlanningCommissioners <[email protected]>; Scott Kinsey <[email protected]>; Christopher Koontz <[email protected]>; Heather Flores <[email protected]>
Subject: Re: Planning Commission 9/1/22 Agenda

‐EXTERNAL‐

Good morning Amy, Planning Commissioners, et al

I am interested in attending via zoom and speaking on the Baker Street project. The Planning Commission page asks me to submit a speaker card in order to speak on the item. The speaker card requires me to include identifying information such as name, address, and whether I am in favor or in opposition to the item.

Because this is a public meeting by a public entity it is subject to the Brown Act, the Planning Commission is in violation of the Brown Act. I am hereby exercising my right to not provide the information requested. I request that the Planning Commission cease and desist the practice of requiring identifying information as a prerequisite to virtual or in‐person attendance. Furthermore I request that the Planning Commission delete all requests to speak that are in violation of the Brown Act or amend the requests and forms to be in compliance with California law.

4 Sincerely,

Carlos Ovalle

If you plan to attend virtually and wish to speak on an item, please fill out the virtual speaker card.

Virtual Speaker Card Form
The

On Thu, Sep 1, 2022 at 10:14 AM Amy Harbin <[email protected]> wrote:

Good morning,
Below it’s mentioned that you agree with the comments made by your attorneys Chatten-Brown, Carstens & Mineer. We have looked and do not have these comments. Can you please forward over?
Thank you,
Amy
5 Amy L. Harbin, AICP
Planner
Long Beach Development Services | Planning
411 W. Ocean Blvd., 3rd Fl. | Long Beach, CA 90802
Office: 562.570.6872

From: >
Sent: Thursday, September 01, 2022 9:48 AM
To: PlanningCommissioners <[email protected]>; Scott Kinsey <[email protected]>; Amy Harbin <[email protected]>; Christopher Koontz <[email protected]> Cc:

Subject: Planning Commission 9/1/22 Agenda

‐EXTERNAL‐

To: Planning Commissioners and Development Services
Re: Item 2 Sept. 1, 2022 Agenda 712 Baker St. FEIR
Dear Decision Makers:
6 As a board member of Riverpark Coalition, I agree with the comments made by our attorneys, Chatten-Brown, Carstens & Mineer. I would like to elaborate on some of the reasons I believe you should not approve this FEIR, Zoning Change, Site Plan Review, Tract Map, Development Agreement, and Street Vacations of Baker St. and Wardlow Rd. right of way.

1. The City did not address the Parks, Recreation and Marine Strategic Plan for 2022-2032, the Racial Equity and Reconciliation Initiative of June 2020, nor the recently adopted Climate Action Plan when considering this EIR and Zoning change.

On January 18, 2022, the following was part of the Parks & Rec Strategic Plan adopted by council:
"The City of Long Beach released the Racial Equity and Reconciliation Initiative [RERI], an evolving report that was unanimously adopted by Long Beach City Council on June 23, 2020. The Racial Equity and Reconciliation Initiative identifies Equity Goals and Strategies that address issues of systemic racial inequality based on community feedback , national best practices, existing City data, and City Council priorities. The four key goals for the City are: GOAL 1 End systemic racism in Long Beach, in all local government and partner agencies, through internal transformation. GOAL 2 Design and invest in community safety and violence prevention. GOAL 3 Redesign police approach to community safety. GOAL 4 Improve health and wellness in the City by eliminating social and economic disparities in the communities most impacted by racism.

PARK EQUITY Numbers of acres per thousand people
Up to 1.5 Light blue 1.6-2.52.6-5.0 Medium blue 5.1-16.3 (max) Dark blue
7 Death at Age 79.7-82.7 Lightest 76.4-77.9 74.2-76.4 Medium 74.2 or younger Darkest
Parks, beaches, and open space are a vital part of any thriving community, and the City of Long Beach has made a commitment to work towards achieving health equity across all zip codes. Although our parks are static pillars in the neighborhoods they are in, the PRM Department has the ability to be nimble and adapt to changing demographics and community needs. We are actively looking for opportunities to partner with other civic institutions, affordable housing developers, nonprofit organizations, or other groups that will expand our ability to serve Long Beach residents,
We can all agree that our neighborhood should not determine our life expectancy —everyone deserves a safe, clean place to live.

We are actively looking for opportunities to partner with other civic institutions, affordable housing developers, nonprofit organizations, or other groups that will expand our ability to serve Long Beach residents. "

2. This project should also reflect the goals of the recent Climate Action Plan and include requirements for solar energy, electric heating and appliances, irrigating with recycled 8 water, planting more trees, no artificial turf, reducing density, thereby reducing vehicle trips, energy consumption, water usage and greenhouse gases.

3. There was no effort by the City to find grant funds with which to purchase this site as park/open space, even though it was included as parkland in many plans for the LA River. (Please see letters from Congressman Lowenthal, Senator Rendon and Assemblymember O'Donnell in the staff report.)

4. In addition to the many inadequacies of the EIR, I urge you to deny the Zoning Change from Commercial/ Storage to R-15, allowing 15 dwelling units per acre. (In 2015, the Riverwalk/dale project received a new zoning designation of RP-13, specifying a maximum density of 13 DU/ac. Prior to this, there was a limit of 8 dwelling units per acre in most of residential Long Beach.)
In addition, this project has 3 story buildings which were removed from the Riverwalk project as 3 stories were incompatible with the neighborhood.

Thank you for your consideration.

Ann Cantrell
1 Scott Kinsey
From: Carlos Ovalle
Sent: Thursday, September 01, 2022 11:56 AM
To: Christopher Koontz
Cc: Amy Harbin; ; PlanningCommissioners; Scott Kinsey; ; Heather Flores
Subject: Re: Planning Commission 9/1/22 Agenda
Attachments: Screen Shot 2022-09-01 at 11.53.10 AM.png
‐EXTERNAL‐
Mr. Koontz,
You're incorrect. The Planning Commission page specifically states, "If you plan to attend virtually and wish to speak on an item, please fill out the virtual speaker card." It does not state that it is voluntary as required by law. Furthermore the link to the Virtual Speaker Card Form results in the attached form that clearly requires those items specifically prohibited by California law such as name, address, and whether one is for or against the agenda item. It is impossible to submit the form without any of the required information completed.

My requests stand.

Sincerely,
Carlos Ovalle
On Thu, Sep 1, 2022 at 11:45 AM Christopher Koontz <[email protected]> wrote:

Mr. Ovalle,

The city requests but does not require that information. Please submit what you are comfortable submitting, only your name and item # are required.

Thank you,

Christopher Koontz, AICP
Acting Director
2 Development Services
411 W. Ocean Blvd., 3rd Floor | Long Beach, CA 90802
Office: 562.570.6288 | Fax: 562.570.6068

Once your permit application has been processed/approved, you may schedule a building inspection by using the link below. For applications requiring plan check, project status may be viewed online using the appropriate link below. Please visit our website to view current processing times.

From: Carlos Ovalle
Sent: Thursday, September 1, 2022 11:39 AM
To: Amy Harbin <[email protected]>
Cc: PlanningCommissioners <[email protected]>; Scott Kinsey <[email protected]>; Christopher Koontz <[email protected]>; Heather Flores <[email protected]>
Subject: Re: Planning Commission 9/1/22 Agenda

3 ‐EXTERNAL‐

Good morning Amy, Planning Commissioners, et al

I am interested in attending via zoom and speaking on the Baker Street project. The Planning Commission page asks me to submit a speaker card in order to speak on the item. The speaker card requires me to include identifying information such as name, address, and whether I am in favor or in opposition to the item.

Because this is a public meeting by a public entity it is subject to the Brown Act, the Planning Commission is in violation of the Brown Act. I am hereby exercising my right to not provide the information requested. I request that the Planning Commission cease and desist the practice of requiring identifying information as a prerequisite to virtual or in‐person attendance. Furthermore I request that the Planning Commission delete all requests to speak that are in violation of the Brown Act or amend the requests and forms to be in compliance with California law.

Sincerely,

Carlos Ovalle

If you plan to attend virtually and wish to speak on an item, please fill out the virtual speaker card. 4 Virtual Speaker Card Form
The

On Thu, Sep 1, 2022 at 10:14 AM Amy Harbin <[email protected]> wrote:

Good morning,
Below it’s mentioned that you agree with the comments made by your attorneys Chatten-Brown, Carstens & Mineer. We have looked and do not have these comments. Can you please forward over?
Thank you,
Amy
Amy L. Harbin, AICP
Planner
Long Beach Development Services | Planning
411 W. Ocean Blvd., 3rd Fl. | Long Beach, CA 90802
Office: 562.570.6872

From:

Sent: Thursday, September 01, 2022 9:48 AM
To: PlanningCommissioners <[email protected]>; Scott Kinsey <[email protected]>; Amy Harbin <[email protected]>; Christopher Koontz <[email protected]> 5 Cc:

Subject: Planning Commission 9/1/22 Agenda

‐EXTERNAL‐

To: Planning Commissioners and Development Services
Re: Item 2 Sept. 1, 2022 Agenda 712 Baker St. FEIR
Dear Decision Makers:

As a board member of Riverpark Coalition, I agree with the comments made by our attorneys, Chatten-Brown, Carstens & Mineer. I would like to elaborate on some of the reasons I believe you should not approve this FEIR, Zoning Change, Site Plan Review, Tract Map, Development Agreement, and Street Vacations of Baker St. and Wardlow Rd. right of way.

1. The City did not address the Parks, Recreation and Marine Strategic Plan for 2022-2032, the Racial Equity and Reconciliation Initiative of June 2020, nor the recently adopted Climate Action Plan when considering this EIR and Zoning change.

On January 18, 2022, the following was part of the Parks & Rec Strategic Plan adopted by council:
"The City of Long Beach released the Racial Equity and Reconciliation Initiative [RERI], an evolving report that was unanimously adopted by Long Beach City Council on June 23, 2020. The Racial Equity and Reconciliation Initiative identifies Equity Goals and Strategies that address issues of systemic racial inequality based on community feedback , national best practices, existing City data, and City Council priorities. The four key goals for the City are: GOAL 1 End systemic racism in Long Beach, in all local government and partner agencies, through internal transformation. GOAL 2 Design and invest in community safety and violence prevention. GOAL 3 Redesign police approach to community safety. GOAL 4 Improve health and wellness in the City by eliminating social and economic disparities in the communities most impacted by racism.

PARK EQUITY Numbers of acres per thousand people
6 Up to 1.5 Light blue 1.6-2.52.6-5.0 Medium blue 5.1-16.3 (max) Dark blue
Death at Age 79.7-82.7 Lightest 76.4-77.9 74.2-76.4 Medium 74.2 or younger Darkest
7 Parks, beaches, and open space are a vital part of any thriving community, and the City of Long Beach has made a commitment to work towards achieving health equity across all zip codes. Although our parks are static pillars in the neighborhoods they are in, the PRM Department has the ability to be nimble and adapt to changing demographics and community needs. We are actively looking for opportunities to partner with other civic institutions, affordable housing developers, nonprofit organizations, or other groups that will expand our ability to serve Long Beach residents,
We can all agree that our neighborhood should not determine our life expectancy —everyone deserves a safe, clean place to live.

We are actively looking for opportunities to partner with other civic institutions, affordable housing developers, nonprofit organizations, or other groups that will expand our ability to serve Long Beach residents. "

2. This project should also reflect the goals of the recent Climate Action Plan and include requirements for solar energy, electric heating and appliances, irrigating with recycled water, planting more trees, no artificial turf, reducing density, thereby reducing vehicle trips, energy consumption, water usage and greenhouse gases.

3. There was no effort by the City to find grant funds with which to purchase this site as park/open space, even though it was included as parkland in many plans for the LA River. (Please see letters from Congressman Lowenthal, Senator Rendon and Assemblymember O'Donnell in the staff report.)

4. In addition to the many inadequacies of the EIR, I urge you to deny the Zoning Change from Commercial/ Storage to R-15, allowing 15 dwelling units per acre. (In 2015, the Riverwalk/dale project received a new zoning designation of RP-13, specifying a maximum density of 13 DU/ac. Prior to this, there was a limit of 8 dwelling units per acre in most of residential Long Beach.)
In addition, this project has 3 story buildings which were removed from the Riverwalk project as 3 stories were incompatible with the neighborhood.

Thank you for your consideration.

Ann Cantrell
8 1
Scott Kinsey
From: Carlos Ovalle
Sent: Thursday, September 01, 2022 2:41 PM
To: Amy Harbin
Cc: ; PlanningCommissioners; Scott Kinsey; Christopher Koontz; Heather Flores;
; Dawn McIntosh; Alexis Oropeza
Subject: Re: Planning Commission 9/1/22 Agenda
‐EXTERNAL‐
Amy,
Thank you, yet the illegal requirement has been there for a month, and there was no public notification that it was removed, and it was only transmitted to a few of us a couple of hours before the hearing.

Please postpone the hearing.

Carlos Ovalle
On Thu, Sep 1, 2022 at 2:36 PM Amy Harbin <[email protected]> wrote:

Good afternoon,
The requirement for a virtual speaker card has been removed from the Planning Commission website.

Please see the link to the webpage https://www.longbeach.gov/lbds/planning/commission/ I have also included a screen shot below:
2 3
Thank you,
Amy
Amy L. Harbin, AICP
Planner
Long Beach Development Services | Planning
411 W. Ocean Blvd., 3rd Fl. | Long Beach, CA 90802
Office: 562.570.6872

From: Carlos Ovalle >
Sent: Thursday, September 01, 2022 11:39 AM
To: Amy Harbin <[email protected]>
Cc: PlanningCommissioners <[email protected]>; Scott Kinsey <[email protected]>; Christopher Koontz <[email protected]>; Heather Flores <[email protected]>
Subject: Re: Planning Commission 9/1/22 Agenda

‐EXTERNAL‐

Good morning Amy, Planning Commissioners, et al

4 I am interested in attending via zoom and speaking on the Baker Street project. The Planning Commission page asks me to submit a speaker card in order to speak on the item. The speaker card requires me to include identifying information such as name, address, and whether I am in favor or in opposition to the item.

Because this is a public meeting by a public entity it is subject to the Brown Act, the Planning Commission is in violation of the Brown Act. I am hereby exercising my right to not provide the information requested. I request that the Planning Commission cease and desist the practice of requiring identifying information as a prerequisite to virtual or in‐person attendance. Furthermore I request that the Planning Commission delete all requests to speak that are in violation of the Brown Act or amend the requests and forms to be in compliance with California law.

Sincerely,

Carlos Ovalle

If you plan to attend virtually and wish to speak on an item, please fill out the virtual speaker card.

Virtual Speaker Card Form
The

On Thu, Sep 1, 2022 at 10:14 AM Amy Harbin <[email protected]> wrote:
5 Good morning,
Below it’s mentioned that you agree with the comments made by your attorneys Chatten-Brown, Carstens & Mineer. We have looked and do not have these comments. Can you please forward over?
Thank you,
Amy
Amy L. Harbin, AICP
Planner
Long Beach Development Services | Planning
411 W. Ocean Blvd., 3rd Fl. | Long Beach, CA 90802
Office: 562.570.6872

From: >
Sent: Thursday, September 01, 2022 9:48 AM
To: PlanningCommissioners <[email protected]>; Scott Kinsey <[email protected]>; Amy Harbin <[email protected]>; Christopher Koontz <[email protected]> Cc:

Subject: Planning Commission 9/1/22 Agenda

‐EXTERNAL‐
6 To: Planning Commissioners and Development Services
Re: Item 2 Sept. 1, 2022 Agenda 712 Baker St. FEIR
Dear Decision Makers:

As a board member of Riverpark Coalition, I agree with the comments made by our attorneys, Chatten-Brown, Carstens & Mineer. I would like to elaborate on some of the reasons I believe you should not approve this FEIR, Zoning Change, Site Plan Review, Tract Map, Development Agreement, and Street Vacations of Baker St. and Wardlow Rd. right of way.

1. The City did not address the Parks, Recreation and Marine Strategic Plan for 2022-2032, the Racial Equity and Reconciliation Initiative of June 2020, nor the recently adopted Climate Action Plan when considering this EIR and Zoning change.

On January 18, 2022, the following was part of the Parks & Rec Strategic Plan adopted by council:
"The City of Long Beach released the Racial Equity and Reconciliation Initiative [RERI], an evolving report that was unanimously adopted by Long Beach City Council on June 23, 2020. The Racial Equity and Reconciliation Initiative identifies Equity Goals and Strategies that address issues of systemic racial inequality based on community feedback , national best practices, existing City data, and City Council priorities. The four key goals for the City are: GOAL 1 End systemic racism in Long Beach, in all local government and partner agencies, through internal transformation. GOAL 2 Design and invest in community safety and violence prevention. GOAL 3 Redesign police approach to community safety. GOAL 4 Improve health and wellness in the City by eliminating social and economic disparities in the communities most impacted by racism.

PARK EQUITY Numbers of acres per thousand people
7 Up to 1.5 Light blue 1.6-2.52.6-5.0 Medium blue 5.1-16.3 (max) Dark blue
Death at Age 79.7-82.7 Lightest 76.4-77.9 74.2-76.4 Medium 74.2 or younger Darkest
8 Parks, beaches, and open space are a vital part of any thriving community, and the City of Long Beach has made a commitment to work towards achieving health equity across all zip codes. Although our parks are static pillars in the neighborhoods they are in, the PRM Department has the ability to be nimble and adapt to changing demographics and community needs. We are actively looking for opportunities to partner with other civic institutions, affordable housing developers, nonprofit organizations, or other groups that will expand our ability to serve Long Beach residents,
We can all agree that our neighborhood should not determine our life expectancy —everyone deserves a safe, clean place to live.

We are actively looking for opportunities to partner with other civic institutions, affordable housing developers, nonprofit organizations, or other groups that will expand our ability to serve Long Beach residents. "

2. This project should also reflect the goals of the recent Climate Action Plan and include requirements for solar energy, electric heating and appliances, irrigating with recycled water, planting more trees, no artificial turf, reducing density, thereby reducing vehicle trips, energy consumption, water usage and greenhouse gases.

3. There was no effort by the City to find grant funds with which to purchase this site as park/open space, even though it was included as parkland in many plans for the LA River. (Please see letters from Congressman Lowenthal, Senator Rendon and Assemblymember O'Donnell in the staff report.)

4. In addition to the many inadequacies of the EIR, I urge you to deny the Zoning Change from Commercial/ Storage to R-15, allowing 15 dwelling units per acre. (In 2015, the Riverwalk/dale project received a new zoning designation of RP-13, specifying a maximum density of 13 DU/ac. Prior to this, there was a limit of 8 dwelling units per acre in most of residential Long Beach.)
In addition, this project has 3 story buildings which were removed from the Riverwalk project as 3 stories were incompatible with the neighborhood.

Thank you for your consideration.

Ann Cantrell
9 1
Scott Kinsey
From: Carlos Ovalle
Sent: Thursday, September 01, 2022 1:53 PM
To: Ann Cantrell
Cc: Charles Parkin; CityAttorney; Christopher Koontz; Amy Harbin; Scott Kinsey; PlanningCommissioners; Subject: Re: Mayor violates law
Attachments: Screen Shot 2022-09-01 at 1.46.13 PM.png; Screen Shot 2022-09-01 at 1.36.27 PM.png ‐EXTERNAL‐
All,
Adding to what Ann Cantrell wrote, I would like to add that not only is the mayor's letter inappropriate, it is possibly illegal, as there is clearly a conflict of interest and a violation of the City's ethics guidelines.

Mayor Garcia, as well as some councilmembers, have received substantial campaign contributions from the developer, Integral Communities, LLC while their project is under consideration. Mayor Garcia's campaign donors include primarily real estate developers but also include other industries directly and indirectly linked to increased for‐profit market luxury housing developments, such as the gated community now under consideration, and therefore must retract his deceptive letter of support.

I further request a postponement of the hearing to allow further investigation into other conflicts of interest, including members of the Planning Commission, city staff, and councilmembers.

Sincerely,
Carlos Ovalle
On Thu, Sep 1, 2022 at 12:46 PM > wrote:

To Whom It May Concern:

In the staff report for today's Planning Commission hearing for 712 Baker St. Project, there is letter of support from Mayor Garcia. It is my understanding that neither the Council nor the Mayor can comment on issues before the Planning Commission, as these will be coming to them for a vote.

It would appear that today's hearing should be postponed until this matter is clarified, along with other possible violations, such as no Story Poles for the 3 story height increase and an illegal requirement for name and address in order to make public comment.

I would appreciate a prompt response to these violations.

Ann Cantrell

1 Heather Flores
From: juan ovalle
Sent: Thursday, September 1, 2022 3:08 PM
To: PlanningCommissioners; Christopher Koontz; Amy Harbin Cc:

Subject: Item 2 Sept. 1, 2022 Agenda 712 Baker St. FEIR Attachments: Wrigley Heights Grant Application CD.pdf; Letter of Support(1).pdf; Screen Shot 2022-09-01 at

1.46.13 PM.png; Screen Shot 2022-09-01 at 1.36.27 PM(1).png ‐EXTERNAL‐
September 1st, 2022
Planning Commission, City of Long Beach
Subject: Item 2 Sept. 1, 2022 Agenda 712 Baker St. FEIR As a resident Western Long Beach that grew up and have lived only about a mile away from the Proposed 712 Baker St. project for over 50 years, I ask that you reject this project. As children, the LA River was our playground, riding my bike near the last remaining parcels north and south of the San Diego Freeway was a dream of future park land for all of us to enjoy.

As a member of the Riverpark Coalition, I agree with the comments made by our attorneys, Chatten-Brown, Carstens & Mineer, and would only like to echo a few comments made by colleagues at RPC and add a couple of documents for your consideration as you make that final vote.

On January 18, 2022, the following was part of the Parks & Rec Strategic Plan adopted by council, which you must read and perhaps even memorize. Wrigley and West Long Beach are a mainly working class community with over 80% of the population being of Hispanic and Asian descent.
"The City of Long Beach released the Racial Equity and Reconciliation Initiative [RERI], an evolving report that was unanimously adopted by Long Beach City Council on June 23, 2020. The Racial Equity and Reconciliation Initiative identifies Equity Goals and Strategies that address issues of systemic racial inequality based on community feedback, national best practices, existing City data, and City Council priorities. The four key goals for the City are: GOAL 1 End systemic racism in Long Beach, in all local government and partner agencies, through internal transformation. GOAL 2 Design and invest in community safety and violence prevention. GOAL 3 Redesign police approach to community safety.

GOAL 4 Improve health and wellness in the City by eliminating social and economic disparities in the communities most impacted by racism.

Oh, how the winds have changed from promised action towards meeting a goal, to political opportunists attempting to appease their donors. Using our City or their position as stepping stones for higher office as is the case with your current Commission President and of course our Mayor, who has received thousands of dollars from associates, employees and family of the Developer of the subject project is not acceptable! In 2003 our acting City Manager Gerald R. Miller attempted to follow through on a promise by applying for a grant to purchase these 20 acres of land, please refer to the attached grant application. Today, we have a Mayor that may have acted unethically and may have violated a long tradition of Council and Mayors staying away from stating their support for a specific project until approved by Planning. In the case of most members of the Planning Commission, they have all been appointed by the Mayor himself. Now a letter to solidify his obligation to the Developer that contributed thousands of dollars is simply an open admonition to his obligation to those that pave his way with campaign contributions. 2 Oh yes, how things have changed in our City! Some for the better, some for the unethical. Decision makers, please reject this project and do what is right for our western Long Beach communities and protect the last remaining parcels of open land for future generations to enjoy as the riparian wetlands, trails, and forested land to act as a buffer to all the unseen pollution that is reducing the lifespan of our neighbors our children and ourselves.

Vote NO!
Juan E. Ovalle
Riverpark Coalition
https://www.riverparkcoalition.org/
562.570.6801 | [email protected] | @LongBeachMayor
411 West Ocean Blvd, Long Beach, California 90802
August 30, 2022
Chair Joni Ricks-Oddie
Planning Commission, City of Long Beach
411 W. Ocean Blvd.

Long Beach, CA 90802
Dear Chair Ricks-Oddie and Planning Commissioners:

This week you will be considering an item on the Riverpark Residential Project. I am writing in strong support of this project. Its approval will support the housing and environmental goals in our city and have a positive impact on our community.

The Riverpark Residential Project will play an important role in the city’s plan to create more housing and to address the issue of housing insecurity. Not only will the project create 226 new housing units, but it will also provide 12 units of affordable housing. This will move our city closer to accomplishing not only our own housing goals, but the goal set out by the State – upholding our city’s record as a national leader and model.

In addition to providing housing, the project will improve and stimulate the surrounding community. It will do so by eliminating a contaminated site and replacing it with 5 acres of new park, dog park improvements, and upgrades to the city-owned park it will be located adjacent to.

The recreational opportunities that this development will provide will be enormously beneficial to the surrounding Wrigley Heights community and our entire city.

Thank you for your consideration and your hard work on behalf of our City.

Sincerely,
Mayor Robert Garcia
City of Long Beach

1 Heather Flores
From: Leslie Garretson
Sent: Thursday, September 1, 2022 4:16 PM
To: PlanningCommissioners; Christopher Koontz; Amy Harbin; Scott Kinsey; Heather Flores Cc: Renee Lawler; Ann Cantrell; Serena Steers; Corliss Lee; Elena Tucci; Ian Patton; Juan Fragoso; Carlos Ovalle; Martin Holman; Juan Ovalle; Doug Carstens; Sunjana Supekar; Michelle Black Subject: 712 Baker St. (APNs: 7203-002-001, 7203-002-005, 7203-002-007, 7203-002-008, 7203-002-009, 7203-002-010) Application numbers; 2003-24 (ZCHG20-002, SPR20-007, VTTM20-002, DA20-001, GPC21-003
‐EXTERNAL‐
Objection to River Park Residential Project, 712 Baker Street, State Clearinghouse No. 2021020492
I am an affected resident and Board member of Riverpark Coalition. I request the Commission reject this harmful Project in favor of the long-planned and much-needed Los Angeles River park that would be forever foreclosed if the City approves this Project. I am in support of our legal counsel Chatten-Brown, Carstens & Minteer LLP's correspondence and would like to add:

1. Including the Mayor’s letter of support to the Planning Commission is problematic, these are appointees made by the Mayor to the Planning Commission. Recusing himself is not sufficient, the damage is done, While Dawn McIntosh stated it was not illegal for him to support an item before the Planning Commission, it still gives an impression of bias if he were to participate in the discussion when the item comes to the City Council, so we have advised him that he will need to recuse himself.

2. Mayor Garcia, as well as some councilmembers, have received substantial campaign contributions from the developer, Integral Communities, LLC while their project is under consideration. Mayor Garcia's campaign donors include primarily real estate developers but also include other industries directly and indirectly linked to increased for-profit market luxury housing developments, such as the gated community now under consideration, and therefore must retract his deceptive letter of support.

3. At approximately 2:30 today the requirement for a virtual speaker card has been removed from the Planning Commission website. The illegal requirement was on the City website for more than a month, there has been no public notification it was removed (and if so, insufficient notice for a 5pm meeting) and only transmitted to Riverpark Coalition and our legal advisors.

At a minimum, I further request a postponement of the hearing to allow further investigation into other conflicts of interest, including members of the Planning Commission, city staff, and councilmembers.
2 Sincerely,
Leslie Ann Garretson
Riverpark Coalition Board Member
Los Cerritos Neighborhood Association
Los Cerritos/Bixby Knolls Clean Streets
Friends of Los Cerritos Committee
"When you cease to make a contribution you begin to die". Eleanor Roosevelt 1 Heather Flores
From: RAE GABELICH
Sent: Thursday, September 1, 2022 4:25 PM
To: PlanningCommissioners
Cc:

Subject: 712 Baker vote
‐EXTERNAL‐
Dear Commissioners,
Tonight, on agenda item #2 you are being asked to support a high density housing project that has been questioned by the area neighborhoods for many years.

We hear daily about the needs for housing across our state, but we do not hear our commissioners or elected bodies address the concerns of residents living within those areas today. Tonight, you have the opportunity to do just that.

Over the years this space has been considered for open space as well as residential development. The city states that they have never had access to purchase this private property, but chances are the efforts have never been there.

The Trust for Public Land claims that Long Beach does not/ has not approached them on several plots of land that could have been significant additions to our westside open spaces. This side of our city that is lacking appropriate recreational spaces has seen minimal effort to change that reality.

It is unfortunate that Mayor Garcia, the person responsible for your commission appointments, thought he should demonstrate his desire for this project to be approved. Neither the mayor nor the council members are suppose to attempt to influence your decisions. And certainly not when local political campaigns are on the table.

This same developer was awarded a zone change for the Will J. Reid Boy Scout Park several years back. That ten acres would have allowed much needed open space in the Uptown area of Long Beach. Instead, we have 131 homes on 10 acres. A high density privatized development in a challenged neighborhood that deserved improvements on recreational opportunities was approved and blessed and built with little discussion or demands.

I was a founding member of CARP (Citizen's About Responsible Planning) when this project was going through the city cycle of demands and approvals. We challenged that approved project and reached a settlement with the developers. They still went back to OC with millions in their pockets. Long Beach gained 131 high density homes and again lost the opportunity to improve quality of life for the residents who already live here.

Your constituents do not want to take legal action to make a point. We want this and every other decision making body to allow for the questions to be addressed in advance of approval. We want our visionaries to consider improving the quality of life for ALL of Long Beach. More is not always better! And finally, when housing projects are approved they should be required to meet all sustainable building practices from solar to water needs. From neighborhood assets (parking, traffic flow, recreation) for all, to more public safety provided as more residents are being added to the city.

Please open this discussion and consider this particular project to be at minimum downsized in number of units and heights of allowable homes. As one of the last large plots of land along the LA River your consideration could greatly influence the nature of our Long Beach.

Thank you,
Rae Gabelich
Former 8th District Council member
2 1
Heather Flores
From: R.M. Holman >
Sent: Thursday, September 1, 2022 4:26 PM
To: PlanningCommissioners; Christopher Koontz; Amy Harbin; Scott Kinsey; Heather Flores Subject: Objection to River Park Residential Project, 712 Baker Street, State Clearinghouse No. 2021020492 ‐EXTERNAL‐
Objection to River Park Residential Project, 712 Baker Street, State Clearinghouse No. 2021020492 I request the Commission reject this harmful Project in favor of the long‐planned and much‐ needed Los Angeles River park that would be forever foreclosed if the City approves this Project.   I am in support of our legal counsel Chatten‐Brown, Carstens & Minteer LLP's correspondence and would like to add:

1. Including the Mayor’s letter of support to the Planning Commission is problematic, these are appointees made by the Mayor to the Planning Commission.  Recusing himself is not sufficient, the damage is done, While Dawn McIntosh stated it was not illegal for him to support an item before the Planning Commission, it still gives an impression of bias if he were to participate in the discussion when the item comes to the City Council.

2. Mayor Garcia, as well as some councilmembers, have received substantial campaign contributions from the developer, Integral Communities, LLC while their project is under consideration. Mayor Garcia's campaign donors include primarily real estate developers but also include other industries directly and indirectly linked to increased for‐profit market luxury housing developments, such as the gated community now under consideration, and therefore must retract his deceptive letter of support.

3. At approximately 2:30 today the requirement for a virtual speaker card has been removed from the Planning Commission website.  The illegal requirement was on the City website for more than a month, there has been no public notification it was removed (and regardless, is certainly insufficient notice for a 5pm meeting) and only transmitted to Riverpark Coalition and our legal advisors.

At a minimum, I further request a postponement of the hearing to allow further investigation into other conflicts of interest, including members of the Planning Commission, city staff, and councilmembers.

Sincerely,
Roger Martin Holman
1 Heather Flores
From: R.M. Holman
Sent: Thursday, September 1, 2022 4:26 PM
To: PlanningCommissioners; Christopher Koontz; Amy Harbin; Scott Kinsey; Heather Flores Subject: Objection to River Park Residential Project, 712 Baker Street, State Clearinghouse No. 2021020492 ‐EXTERNAL‐
Objection to River Park Residential Project, 712 Baker Street, State Clearinghouse No. 2021020492 I request the Commission reject this harmful Project in favor of the long‐planned and much‐ needed Los Angeles River park that would be forever foreclosed if the City approves this Project.   I am in support of our legal counsel Chatten‐Brown, Carstens & Minteer LLP's correspondence and would like to add:

1. Including the Mayor’s letter of support to the Planning Commission is problematic, these are appointees made by the Mayor to the Planning Commission.  Recusing himself is not sufficient, the damage is done, While Dawn McIntosh stated it was not illegal for him to support an item before the Planning Commission, it still gives an impression of bias if he were to participate in the discussion when the item comes to the City Council.

2. Mayor Garcia, as well as some councilmembers, have received substantial campaign contributions from the developer, Integral Communities, LLC while their project is under consideration. Mayor Garcia's campaign donors include primarily real estate developers but also include other industries directly and indirectly linked to increased for‐profit market luxury housing developments, such as the gated community now under consideration, and therefore must retract his deceptive letter of support.

3. At approximately 2:30 today the requirement for a virtual speaker card has been removed from the Planning Commission website.  The illegal requirement was on the City website for more than a month, there has been no public notification it was removed (and regardless, is certainly insufficient notice for a 5pm meeting) and only transmitted to Riverpark Coalition and our legal advisors.

At a minimum, I further request a postponement of the hearing to allow further investigation into other conflicts of interest, including members of the Planning Commission, city staff, and councilmembers.

Sincerely,
Roger Martin Holman
1 Heather Flores
From: Mary Parsell
Sent: Thursday, September 1, 2022 4:59 PM
To: PlanningCommissioners
Cc: Council District 1; Council District 2; Council District 3; Daryl Supernaw; Council District 5; Council District 6; Council District 7; Council District 8; Council District 9 Subject: REJECT River Park 712 Baker Street
‐EXTERNAL‐
September 1, 2022
Dear Chair and Commissioners:

REJECT Final EIR
Note the comments made by California Fish and Game Commission (page 80) that the EIR does not address the colony of endangered Western Burrowing Owls that will be destroyed by the project.

There is no biological survey done by the consulting firm. How can you possibly make policy without knowing the numbers through a biological survey?  This is a violation of CEQA and an affront to preserving the endangered Western Burrowing Owl.  Vote "No" on ratifying the FEIR.

Sincerely,
Mary Parsell
El Dorado Audubon Society
(local chapter of National Audubon Society)
Contact for this subject:
cc: Long Beach City Council members, district 1 through 9 Long Beach Mayor Robert Garcia
1 Heather Flores
From: Leslie Garretson
Sent: Thursday, September 1, 2022 4:16 PM
To: PlanningCommissioners; Christopher Koontz; Amy Harbin; Scott Kinsey; Heather Flores Cc: Renee Lawler; Ann Cantrell; Serena Steers; Corliss Lee; Elena Tucci; Ian Patton; Juan Fragoso; Carlos Ovalle; Martin Holman; Juan Ovalle; Doug Carstens; Sunjana Supekar; Michelle Black Subject: 712 Baker St. (APNs: 7203-002-001, 7203-002-005, 7203-002-007, 7203-002-008, 7203-002-009, 7203-002-010) Application numbers; 2003-24 (ZCHG20-002, SPR20-007, VTTM20-002, DA20-001, GPC21-003
‐EXTERNAL‐
Objection to River Park Residential Project, 712 Baker Street, State Clearinghouse No. 2021020492
I am an affected resident and Board member of Riverpark Coalition. I request the Commission reject this harmful Project in favor of the long-planned and much-needed Los Angeles River park that would be forever foreclosed if the City approves this Project. I am in support of our legal counsel Chatten-Brown, Carstens & Minteer LLP's correspondence and would like to add:

1. Including the Mayor’s letter of support to the Planning Commission is problematic, these are appointees made by the Mayor to the Planning Commission. Recusing himself is not sufficient, the damage is done, While Dawn McIntosh stated it was not illegal for him to support an item before the Planning Commission, it still gives an impression of bias if he were to participate in the discussion when the item comes to the City Council, so we have advised him that he will need to recuse himself.

2. Mayor Garcia, as well as some councilmembers, have received substantial campaign contributions from the developer, Integral Communities, LLC while their project is under consideration. Mayor Garcia's campaign donors include primarily real estate developers but also include other industries directly and indirectly linked to increased for-profit market luxury housing developments, such as the gated community now under consideration, and therefore must retract his deceptive letter of support.

3. At approximately 2:30 today the requirement for a virtual speaker card has been removed from the Planning Commission website. The illegal requirement was on the City website for more than a month, there has been no public notification it was removed (and if so, insufficient notice for a 5pm meeting) and only transmitted to Riverpark Coalition and our legal advisors.

At a minimum, I further request a postponement of the hearing to allow further investigation into other conflicts of interest, including members of the Planning Commission, city staff, and councilmembers.
2 Sincerely,
Leslie Ann Garretson
Riverpark Coalition Board Member
Los Cerritos Neighborhood Association
Los Cerritos/Bixby Knolls Clean Streets
Friends of Los Cerritos Committee
"When you cease to make a contribution you begin to die". Eleanor Roosevelt 1 Nicole Amescua
From: Mary Parsell
Sent: Thursday, September 1, 2022 4:59 PM
To: PlanningCommissioners
Cc: Council District 1; Council District 2; Council District 3; Daryl Supernaw; Council District 5; Council District 6; Council District 7; Council District 8; Council District 9 Subject: REJECT River Park 712 Baker Street
‐EXTERNAL‐
September 1, 2022
Dear Chair and Commissioners:

REJECT Final EIR
Note the comments made by California Fish and Game Commission (page 80) that the EIR does not address the colony of endangered Western Burrowing Owls that will be destroyed by the project.

There is no biological survey done by the consulting firm. How can you possibly make policy without knowing the numbers through a biological survey?  This is a violation of CEQA and an affront to preserving the endangered Western Burrowing Owl.  Vote "No" on ratifying the FEIR.

Sincerely,
Mary Parsell
El Dorado Audubon Society
(local chapter of National Audubon Society)
Contact for this subject:
cc: Long Beach City Council members, district 1 through 9 Long Beach Mayor Robert Garcia

2 And finally, when housing projects are approved they should be required to meet all sustainable building practices from solar to water needs. From neighborhood assets (parking, traffic flow, recreation) for all, to more public safety provided as more residents are being added to the city.

Please open this discussion and consider this particular project to be at minimum downsized in number of units and heights of allowable homes. As one of the last large plots of land along the LA River your consideration could greatly influence the nature of our Long Beach.

Thank you,
Rae Gabelich
Former 8th District Council member
1 Nicole Amescua
From: Elena Tucci
Sent: Thursday, September 1, 2022 6:04 PM
To: PlanningCommissioners
Subject: Sept. 1 2022 Item 2 712BakerSt-FEIR Comments
Attachments: PC_Item2_9-1-22-Agenda_712BakerSt-FEIR.pdf; 040522-R-20sratt.pdf ‐EXTERNAL‐
To whom it may concern,
Attached, you will find my comment in the PDF: PC_Item2_9‐1‐22‐Agenda_712BakerSt‐FEIR as well as a PDF of a recommendation item mentioned in my comments. I am also enclosing my comments in the body of this email, just in case.

Microsoft Word ‐ Document1
September 1, 2022
Planning Commission, City of Long Beach
Subject: Item 2 Sept. 1, 2022 Agenda 712 Baker Street FEIR As a member of the Riverpark Coalition (RPC), I agree with the comments made by the law firm of Chatten-Brown, Carstens & Mineer, and would like to echo some of the comments made by them, as well as a few of my RPC colleagues.

As a resident Western Long Beach, I ask that you reject the proposed 712 Baker Street project.

The City’s intention to support environmental and social justice goals is being tested with your decision.

Communities largely populated by people of color living in an area that has some of the worst air quality in the nation, which is the leading cause of and contributor to respiratory diseases detrimental to their health. The decision to move this project forward will not improve this reality; it will only exacerbate it.

The years of promises to transform this area into open space is at risk as you make this decision. The LA River Masterplan, The Lower LA River Plan (LLARP), and Riverlink Plan all envisioned this location as open space. As currently as 2022, there was a reference to the Riverlink Plan on the Long Beach Department of Parks, Recreation and Marine (LB Parks & Rec) website, leading the community to believe this was the plan. Trees are the bestknown antidote to carbon emissions.

In 2003, acting City Manager Gerald R. Miller attempted to follow through on a promise by applying for a grant to purchase these 20 acres of land. On January 18, 2022, LB Parks & Rec released a Strategic Plan to address some of the city’s social inequities, which was adopted unanimously by city council on June 23, 2020. On April 5, 2022, LB Parks & Rec submitted a Recommendation to:

Adopt a Resolution in support of the formation of the Lower Los Angeles River Recreation and Park District; direct the City Clerk to file the Resolution with the Local Agency Formation Commission; and, authorize the City Manager to approve the final District Boundary Map on behalf of the City. (Citywide) Today, we have a Mayor that has acted unethically and violated a long tradition of Council and Mayors staying away from stating their positions on specific projects until approved by Planning.

September 1, 2022
Planning Commission, City of Long Beach
Subject: Item 2 Sept. 1, 2022 Agenda 712 Baker Street FEIR As a resident Western Long Beach, I ask that you reject the proposed 712 Baker Street project. As a member of the Riverpark Coalition (RPC), I agree with the comments made by the law firm of Chatten-Brown, Carstens & Mineer, and would like to echo some of the comments made by them, as well as a few of my RPC colleagues.

The City’s intention to support environmental and social justice goals is being tested with your decision. Communities largely populated by people of color living in an area that has some of the worst air quality in the nation, which is the leading cause of and contributor to respiratory diseases detrimental to their health. The decision to move this project forward will not improve this reality; it will only exacerbate it.

The years of promises to transform this area into open space is at risk as you make this decision. The LA River Masterplan, The Lower LA River Plan (LLARP), and Riverlink Plan all envisioned this location as open space. As currently as 2022, there was a reference to the Riverlink Plan on the Long Beach Department of Parks, Recreation and Marine (LB Parks & Rec) website, leading the community to believe this was the plan. Trees are the best-known antidote to carbon emissions.

In 2003, acting City Manager Gerald R. Miller attempted to follow through on a promise by applying for a grant to purchase these 20 acres of land. On January 18, 2022, LB Parks & Rec released a Strategic Plan to address some of the city’s social inequities, which was adopted unanimously by city council on June 23, 2020. On April 5, 2022, LB Parks & Rec submitted a Recommendation to:

Adopt a Resolution in support of the formation of the Lower Los Angeles River Recreation and Park District; direct the City Clerk to file the Resolution with the Local Agency Formation Commission; and, authorize the City Manager to approve the final District Boundary Map on behalf of the City. (Citywide)
Today, we have a Mayor that has acted unethically and violated a long tradition of Council and Mayors staying away from stating their positions on specific projects until approved by Planning.

The Mayor’s letter of support for the Baker Street project solidifies his obligation to a developer that has contributed thousands of dollars to his political ambitions and in my opinion, is an open admonition of his obligation to those that have and continue to pave his way with campaign contributions. It essentially sends the message to developers that the remaining open space parcels in western Long Beach that have been identified in numerous Los Angeles River revitalization plans are for sale to whomever is willing to contribute to a private citizen’s political ambitions (which is not limited to the Office of the Mayor). But it also sends the message to the citizens of Long Beach: all of the hard work to construct those LA River Master Plans is being capitalized upon by double-dealing politicians, simultaneously lending their support to the same plans they continue to undermine by failing to protect the parcels of open space identified in those plans. Soliciting good will from the citizenry of Long Beach through their support of increased park space in a severely park poor area rife with air pollution, all the while receiving thousands of dollars from associates, employees and family of the private developers (who have their sites set on open green and brown spaces).

Leveraging the last remaining parcels of open space in western Long Beach as a stepping-stone to further political ambitions of higher office all at the expense of this city’s residents and taxpayers is unacceptable.

Unscrupulous developers and politicians are using the housing crisis to enrich themselves only to exacerbate poor planning policy. We don’t need more market rate housing. We do need more affordable and low-income housing but this proposed project makes only a meager contribution. The Baker Street project does not solve the housing crisis and it comes at the expense of desperately needed opportunities for open space, recreational opportunities and environmental remediation. (Western Long Beach only has one acre of parks per 1,000 residents.)
While I do believe in the autonomy of the Planning Commission, the Mayor himself has appointed many members. I am concerned with how any feelings of obligation may affect or outweigh a commissioner’s ability to assert that independence in their decision-making process. A decision to deny the zoning changes would be heroic in allowing the original intention of adding open space in the last possible location for a park along the LA River to be pursued. Please consider this decision carefully. The fate of Westside Long Beach is at stake and just as we are dealing with the poor planning decisions made in the past, we will continue to experience the repercussions of this moment—you have a choice to right the wrongs of the past and support a decision that favors revitalization, resilience and quality of life. The “greening” of the Westside will go a long way to ensure environmental justice, desperately needed stormwater runoff collection and local water security, as well as see an increase in existing property values and future in-fill development.

Reject the Baker Street project and do what is right by the western Long Beach neighborhoods. Protect the last remaining parcels of open space for future generations to enjoy as riparian wetlands, trails, and forested land to act as a buffer to all the pollution that is worsening the health, safety and well being of this community.

Thank you for your time and consideration of my views regarding this important matter.

Elena Tucci
Riverpark Coalition
https://www.riverparkcoalition.org/

1 AL:vr A22-00550 (3.10.22)
01360888.DOCX
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OFFICE OF THE CITY ATTORNEY
CHARLES PARKIN, City Attorney
411 W. Ocean Boulevard, 9th Floor
Long Beach, CA 90802
RESOLUTION NO.

A RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF LONG BEACH IN SUPPORT OF THE FORMATION

OF AND INCLUSION IN THE LOWER LOS ANGELES RIVER

RECREATION AND PARKS DISTRICT
WHEREAS, in September of 2016, California Senate Bill 1374, sponsored by Senator Ricardo Lara, was signed into law authorizing the formation of the Lower Los Angeles River Recreation and Parks District (District); and WHEREAS, the Lower Los Angeles River flows through many disadvantaged communities, where residents are disproportionally impacted by poor air quality from local heavy industry and congested transportation corridors, and suffer from a severe lack of access to recreational opportunities and outdoor park space; and WHEREAS, parks have many beneficial impacts on communities, encouraging physical activity, improving health and fitness, reducing urban heating effects and air pollution, reducing greenhouse gas emissions through trees and greenery, and providing important economic benefits; and
WHEREAS, many communities along the Lower Los Angeles River represent low income communities which are some of the most park-poor areas in Los Angeles County, lacking the resources to fund, develop, maintain and operate the parks and recreational opportunities that their residents need; and WHEREAS, with numerous recent developments, including the creation of a Lower Los Angeles River Working Group to develop a revitalization plan, the City’s Los Angeles River Revitalization Master Plan, and multiple conversations about a new vision for the river, there is a growing local interest in transformation of the river; and WHEREAS, development and maintenance of a safe, attractive and vibrant recreation zone along the Lower Los Angeles River will require coordination of activities, 2 AL:vr A22-00550 (3.10.22)
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OFFICE OF THE CITY ATTORNEY
CHARLES PARKIN, City Attorney
411 W. Ocean Boulevard, 9th Floor
Long Beach, CA 90802
maintenance, public safety and planning across multiple jurisdictions and is beyond the capabilities of any one city; and
WHEREAS, the City of Long Beach has significant interest in the continued development of recreational opportunities for all residents, including facilities and activities which utilize and enhance this important resource and which improves access to the Lower Los Angeles River for everyone; and
WHEREAS, the proposed annexation is categorically exempt from the California Environmental Quality Act (CEQA) pursuant to State CEQA Guidelines Section 20, as a change in the organization of local agencies, and the Categorical Exemption was adopted by the City of South Gate, as lead agency, on March 26, 2019.

NOW, THEREFORE, the City Council of the City of Long Beach resolves as follows:

Section 1. This resolution shall take effect immediately upon its adoption by the City Council, and the City Clerk shall certify the vote adopting this resolution.

Section 2. This resolution is hereby adopted and approved by the City of Long Beach in support the City of South Gate’s application for formation of the Lower Los Angeles River Recreation and Parks District as authorized and in the manner provided by the Cortese-Know-Hertzberg Local Government Reorganization Act of 2000.

Section 3. The City of Long Beach will cooperate with the formation of the District and is requesting to be included within the District as outlined in Senate Bill 1374 and as indicated on the finalized District Boundary Map Section 4. The City Clerk of the City of Long Beach is hereby authorized and directed to file a certified copy of this Resolution with the Executive Officer of the Local Agency Formation Commission for the County of Los Angeles. ///
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3 AL:vr A22-00550 (3.10.22)
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OFFICE OF THE CITY ATTORNEY
CHARLES PARKIN, City Attorney
411 W. Ocean Boulevard, 9th Floor
Long Beach, CA 90802
I hereby certify that the foregoing resolution was adopted by the City Council of the City of Long Beach at its meeting of , 2022, by the following vote:

Ayes: Councilmembers:

Noes: Councilmembers:

Absent: Councilmembers:

Recusal(s): Councilmembers:

City Clerk

1 SB1374 Lower Los Angeles River Recreation and Park District FAQ
1) What is the purpose of SB1374 Lower Los Angeles River Recreation and Park District? The purpose of this bill is to create a special district to help facilitate the construction, improvement, and maintenance of parks and recreational facilities along the Lower Los Angeles River. This bill establishes in statute the structure of the district, but will still require formation through the local LAFCO, thereby preserving local control. 2) What is the biggest barrier to new parks development? The single biggest barrier to development of new parks is a lack of funding. California voters approved a state “water bond” (Proposition 1) in 2014 and a state “park bond” (Proposition 68) in 2018 to provide funding opportunities for the revitalization of the Lower Los Angeles River watershed, including $87.5m in grant in direct allocations and $19m in FY 18/19 State Budget funds to the San Gabriel and Lower Los Angeles Rivers and Mountains Conservancy (RMC) through both bonds for urban creek restoration and park and open space development.

But those funds are limited to acquisition and development of facilities with some allocations for planning, technical assistance, and community access programming, and cannot be used for operation or maintenance of park facilities. A lack of local resources often means that parks cannot be developed, or if they are, they cannot be properly maintained. 3) What is the benefit of creating the Lower Los Angeles River Recreation and Park District?
The Lower LA River flows through many disadvantaged communities, where residents are disproportionally impacted by poor air quality from local heavy industry and congested transportation corridors, and suffer from a severe lack of access to recreational opportunities and outdoor park space.

This District will help to promote the development of open space and parks for the benefit of communities along the Lower LA River. While the Lower LA River serves an important purpose as a flood protection and control channel, it also presents a unique opportunity for open space, urban greening, and as a recreational resource for the region. With numerous

ATTACHMENT B
2 recent developments, including the development of the Lower Los Angeles River Revitalization Plan, the City’s Los Angeles River Revitalization Master Plan, the County’s Los Angeles River Master Plan update, and multiple conversations about a new vision for the river, there is a growing local interest and opportunity to transform the river.

Furthermore, The River Ranger Program (AB1158) can be implemented within the District, to better foster connections between communities, agencies, and resources to promote safe, equitable usage and stewardship of the Los Angeles River and its tributaries. And it can serve as a model for the formation of the Lower San Gabriel River Recreation and Park District (SB693).
4) How will the newly formed District be able to identify funding to fulfill the District's mission?
One of the unique powers a special district has is the ability to leverage funding by fee assessment to fund new parks, conduct a property tax transfer upon approval of the members, the ability to acquire and improve property, and the ability to operate and maintain parks.

Funding for these purposes is currently from limited sources such as bonds (i.e. Proposition 1), and often includes limitations – funds cannot be spent to improve or maintain existing resources. Public Private partnerships and other resources can be explored for additional funds to operate and maintain parks.

5) How does the county calculate the property tax transfer percentage to the district? And will it be taken from the existing pool?
No funding will come from the LA County’s open space district fund. The property tax transfer percentage will be determined if and when the cities enters negotiation to contribute some of their property tax revenues to the district.
6) What is RMC’s role in the formation of the Lower LA River Recreation and Park District?
According to SB1372, if the Park District is formed, then it must coordinate with the Lower Los Angeles River Working Group and the San Gabriel and Lower Los Angeles Rivers and Mountains Conservancy to fulfill the duties established by this bill.

RMC will commit to funding a staff position and provide administrative support for 3 years.

The staff member will report directly to RMC. The named cities in SB 1374 are encouraged to commit additional funding, or in-kind contributions, to support the duties and goals of the Lower LA River Recreation and Park District.
3 7) Who determines the boundaries for the District's jurisdiction? SB 1374 (Lara) establishes the Board of Directors of the district, made up of three public members, appointed by the Los Angeles County board of Supervisors, one representative appointed by each of the following cities: City of Vernon, City of Maywood, City of Bell, City of Bell Gardens, City of Cudahy, City of South Gate, City of Lynwood, City of Compton, City of Paramount, City of Long Beach. Previously, one representative would jointly be appointed by the cities of Commerce, Downey, Montebello, and Pico Rivera. The SB268 (Archuleta) amendment would allow one representative to be appointed by each of the following cities:

City of Commerce, City of Downey, City of Montebello, and City of Pico Rivera.

The bill allows the board, made up of representatives from the Los Angeles County and each of the cities to determine the districts mission.
8) Will cities along the Lower LA River have local control over their respective project? Yes, the cities will continue to have local control over their projects in the Lower LA River.

This also includes projects voted by the Board of Directors of the District. The final decision will be made by the local authority.
9) The size and proportion of the LA River in each city vary, so how will funding be allocated?
The board of directors will make the decisions once the board is formed. 10) How will private land be impacted by the Lower LA River Recreation and Park District?
The Park District do not have additional rights over private land. The private sector partner \ will have to be a willing partner, including for the acquisition of land. 11) What will the Board of Director function?
Once the District is formed, the Board of Director shall consist of no more than 17 members as follow:

The city council of each of the following cities may appoint one representative:
(1) The City of Vernon.
(2) The City of Maywood.
4 (3) The City of Bell.
(4) The City of Bell Gardens.
(5) The City of Cudahy.
(6) The City of South Gate.
(7) The City of Lynwood.
(8) The City of Compton.
(9) The City of Paramount.
(10) The City of Long Beach.
(11) The City of Commerce.
(12) The City of Downey.
(13) The City of Montebello.
(14) The City of Pico Rivera.
(b) The Los Angeles County Board of Supervisors may appoint three public members. One of those members shall be a representative of a nonprofit organization serving the Lower Los Angeles River region.
(c) Except as provided in subdivision (d), a person appointed to the board of directors shall serve at the pleasure of the city council or county board of supervisors that made the appointment.

The representative appointed pursuant to this subdivision shall serve for a two-year term.

Once the Board of Directors are established, they can determine the function of the Park District by developing by-laws.
1 Heather Flores
From: juan ovalle
Sent: Thursday, September 1, 2022 7:06 PM
To: PlanningCommissioners; Christopher Koontz; Amy Harbin Cc: Ben Harris; Sunjana Supekar
Subject: EDITED: Item 2 Sept. 1, 2022 Agenda 712 Baker St. FEIR Attachments: Screen Shot 2022-09-01 at 1.36.27 PM(1).png; Screen Shot 2022-09-01 at 1.46.13 PM.png; Letter of Support(1).pdf; Wrigley Heights Grant Application CD.pdf ‐EXTERNAL‐
September 1st, 2022
Planning Commission, City of Long Beach
Subject: Item 2 Sept. 1, 2022 Agenda 712 Baker St. FEIR As a resident Western Long Beach that grew up and has lived only about a mile away from the Proposed 712 Baker St. project for over 50 years, I ask that you reject this project. As children, the LA River was our playground, riding my bike near the last remaining parcels north and south of the San Diego Freeway was a dream of future park land for all of us to enjoy.

As a member of the Riverpark Coalition, I agree with the comments made by our attorneys, Chatten-Brown, Carstens & Mineer, and would only like to echo a few comments made by colleagues at RPC and add a couple of documents for your consideration as you make that final vote.

On January 18, 2022, the following was part of the Parks & Rec Strategic Plan adopted by council, which you must read and perhaps even memorize. Wrigley and West Long Beach are a mainly working class community with over 80% of the population being of Hispanic and Asian descent.
"The City of Long Beach released the Racial Equity and Reconciliation Initiative [RERI], an evolving report that was unanimously adopted by Long Beach City Council on June 23, 2020. The Racial Equity and Reconciliation Initiative identifies Equity Goals and Strategies that address issues of systemic racial inequality based on community feedback, national best practices, existing City data, and City Council priorities. The four key goals for the City are: GOAL 1 End systemic racism in Long Beach, in all local government and partner agencies, through internal transformation. GOAL 2 Design and invest in community safety and violence prevention. GOAL 3 Redesign police approach to community safety.

GOAL 4 Improve health and wellness in the City by eliminating social and economic disparities in the communities most impacted by racism.

Oh, how the winds have changed from promised action and attempts towards meeting a goal, to political opportunists attempting to appease their donors. Using our City or their position as stepping stones for higher office as is the case with your current Commission President and of course our Mayor, who has received thousands of dollars from associates, employees and family of the Developer of the subject project is not acceptable! In 2003 our acting City Manager Gerald R. Miller attempted to follow through on a promise by applying for a grant to purchase these 20 acres of land, please refer to the attached grant application. Today, we have a Mayor that may have acted unethically and may have violated a long tradition of Council and Mayors staying away from stating their support for a specific project until approved by Planning (attached). In this case all members of the Planning Commission have been 2 appointed by the Mayor himself. Now, a letter to solidify his obligation to the Developer that contributed thousands of dollars is simply an open admonition to his obligation to those that pave his way with campaign contributions (see attached).

Oh yes, how things have changed in our City! Some for the better, some for the unethical. Decision makers, please reject this project and do what is right for our western Long Beach communities and protect the last remaining parcels of open land for future generations to enjoy as the riparian wetlands, trails, and forested land to act as a buffer to all the unseen pollution that is reducing the lifespan of our neighbors our children and ourselves.

Vote NO!
Juan E. Ovalle
On Thu, Sep 1, 2022 at 3:07 PM juan ovalle wrote:

September 1st, 2022
Planning Commission, City of Long Beach
Subject: Item 2 Sept. 1, 2022 Agenda 712 Baker St. FEIR As a resident Western Long Beach that grew up and have lived only about a mile away from the Proposed 712 Baker St. project for over 50 years, I ask that you reject this project. As children, the LA River was our playground, riding my bike near the last remaining parcels north and south of the San Diego Freeway was a dream of future park land for all of us to enjoy.

As a member of the Riverpark Coalition, I agree with the comments made by our attorneys, Chatten-Brown, Carstens & Mineer, and would only like to echo a few comments made by colleagues at RPC and add a couple of documents for your consideration as you make that final vote.

On January 18, 2022, the following was part of the Parks & Rec Strategic Plan adopted by council, which you must read and perhaps even memorize. Wrigley and West Long Beach are a mainly working class community with over 80% of the population being of Hispanic and Asian descent.
"The City of Long Beach released the Racial Equity and Reconciliation Initiative [RERI], an evolving report that was unanimously adopted by Long Beach City Council on June 23, 2020. The Racial Equity and Reconciliation Initiative identifies Equity Goals and Strategies that address issues of systemic racial inequality based on community feedback, national best practices, existing City data, and City Council priorities. The four key goals for the City are: GOAL 1 End systemic racism in Long Beach, in all local government and partner agencies, through internal transformation. GOAL 2 Design and invest in community safety and violence prevention. GOAL 3 Redesign police approach to community safety.

GOAL 4 Improve health and wellness in the City by eliminating social and economic disparities in the communities most impacted by racism.

Oh, how the winds have changed from promised action towards meeting a goal, to political opportunists attempting to appease their donors. Using our City or their position as stepping stones for higher office as is the case with your current Commission President and of course our Mayor, who has received thousands of dollars from associates, employees and family of the Developer of the subject project is not acceptable! In 2003 our acting City Manager Gerald R. Miller attempted to follow through on a promise by applying for a grant to purchase these 20 acres of land, please refer to the attached grant application. Today, we have a Mayor that may have acted unethically and may have violated a long tradition of Council and Mayors staying away from stating their support for a specific project until approved by Planning. In the case of most members of the Planning Commission, they have all been appointed by the Mayor himself. Now a letter to solidify his obligation to the Developer that contributed thousands of dollars is simply an open admonition to his obligation to those that pave his way with campaign contributions. 3 Oh yes, how things have changed in our City! Some for the better, some for the unethical. Decision makers, please reject this project and do what is right for our western Long Beach communities and protect the last remaining parcels of open land for future generations to enjoy as the riparian wetlands, trails, and forested land to act as a buffer to all the unseen pollution that is reducing the lifespan of our neighbors our children and ourselves.

Vote NO!
Juan E. Ovalle
Riverpark Coalition
https://www.riverparkcoalition.org/
562.570.6801 | [email protected] | @LongBeachMayor
411 West Ocean Blvd, Long Beach, California 90802
August 30, 2022
Chair Joni Ricks-Oddie
Planning Commission, City of Long Beach
411 W. Ocean Blvd.

Long Beach, CA 90802
Dear Chair Ricks-Oddie and Planning Commissioners:

This week you will be considering an item on the Riverpark Residential Project. I am writing in strong support of this project. Its approval will support the housing and environmental goals in our city and have a positive impact on our community.

The Riverpark Residential Project will play an important role in the city’s plan to create more housing and to address the issue of housing insecurity. Not only will the project create 226 new housing units, but it will also provide 12 units of affordable housing. This will move our city closer to accomplishing not only our own housing goals, but the goal set out by the State – upholding our city’s record as a national leader and model.

In addition to providing housing, the project will improve and stimulate the surrounding community. It will do so by eliminating a contaminated site and replacing it with 5 acres of new park, dog park improvements, and upgrades to the city-owned park it will be located adjacent to.

The recreational opportunities that this development will provide will be enormously beneficial to the surrounding Wrigley Heights community and our entire city.

Thank you for your consideration and your hard work on behalf of our City.

Sincerely,
Mayor Robert Garcia
City of Long Beach
State of California – The Resources Agency

RIVERS AND MOUNTAINS CONSERVANCY

CALIFORNIA CLEAN WATER, CLEAN AIR, SAFE NEIGHBORHOOD PARKS, AND COASTAL PROTECTION ACT OF 2002

GRANTPROJECT APPLICATION
This Form and Required Attachments Must Be Submitted for Each Project Site

PROJECT NAME AMOUNT OF GRANT REQUESTED
$5 million
WRIGLEY HEIGHTS ACQUISITION Estimated TOTAL PROJECT COST (State Grant and other funds) $6.8 million
Grant Applicant (Agency/Organization and Address) COUNTY Los Angeles

NEAREST CITY
Long Beach
City of Long Beach
Department of Parks, Recreation & Marine

PROJECT ADDRESS
701 Baker Street, Long Beach
2760 N. Studebaker Road
Long Beach, CA 90815-1697

NEAREST CROSS STREET
Wardlow Road & Magnolia
FAX (562) 570-3224
SENATE DISTRICT NO.
25th

ASSEMBLY
DISTRICT NO.
54th
Grant Applicant’s Representative Authorized in Resolution Gerald R. Miller Acting City Manager (562) 570-6916
Name Title Phone
Person with day-to-day responsibility for Project (if different from authorized representative) Dennis Eschen
Manager of Planning &
Development (562) 570-3132
Name Title Phone
Brief description of Project
The Wrigley Heights Acquisition project will provide for the acquisition of 20 acres of Los Angeles River front property for the future restoration of historical wetlands, passive recreation, and publicly accessible open space.

For Development Projects
Land Tenure – Project is: ___________ acres:

For Acquisition Projects
Project land will be __20____ acres
_________Acres owned in fee simple by Applicant ___X_____Acres acquired in fee simple by Applicant _________Acres available under a _________ year lease _________Acres in other than fee simple (explain) _________Acres other interest (explain) _____________
________________________________________________
_____________________________________________
______________________________________________
I certify that the information contained in this Project Application form and Application requirements is accurate.

Signed ____________(Gerald R. Miller)_____________________________________ 2/28/03 Grant Applicant’s Authorized Representative as shown in Resolution Date

Planning Commission – Thursday, September 1, 2022 – Zoom Chat From JE to Everyone 05:00 PM
How do we line up as
From Michelle to Everyone 05:01 PM
I would like to know as well.

From Riverpark Coalition to Everyone 05:01 PM
Me too!
Err.. Me three!
From Me to All Panelists 05:07 PM
Hello all,
We will begin with in-person public comment, then we will open it up to those joining virtually/telephonically. For those of you joining virtually you will use the raise-hand function located at the bottom center portion of your screen when public comment is open for the agenda item you would like to speak on. I will make the verbal announcement too. Hope this information clarifies.

Thank you.

From JE to All Panelists 05:12 PM
Do we raise hand to line up to speak?
From Me to Everyone 05:13 PM
Hello all,
We will begin with in-person public comment, then we will open it up to those joining virtually/telephonically. For those of you joining virtually you will use the raise-hand function located at the bottom center portion of your screen when public comment is open for the agenda item you would like to speak on. I will make the verbal announcement too. Hope this information clarifies.

Thank you.

From JE to Everyone 05:13 PM
Thanks!
From Me to Everyone 05:14 PM
For those joining telephonically you would want to press *9. Thank you! Me to JE, All Panelists 05:14 PM
You're welcome!
From Serena Steers to Everyone 05:22 PM
How can we get a copy of this Powerpoint presentation?
From Michelle to Everyone 05:24 PM
Planning Commission – Thursday, September 1, 2022 – Zoom Chat I would also like a copy!
From Me to Everyone 05:26 PM
The Staff Presentation can be found here:
http://longbeach.legistar.com/View.ashx?M=F&ID=11198615&GUID=76B0BF6D-7567-44C7-A8AF009B1A2A7FBA The full agenda for this evening with link can be found here:
https://longbeach.legistar.com/View.ashx?M=A&ID=995660&GUID=F965670C-AA02-4951-99B6- B7E56C067094
From JE to Everyone 05:52 PM
What is the name of the developers presenter?
From Serena Steers to Everyone 05:53 PM
Didn't this same Developer also build on the old Boy Scouts land? From Riverpark Coalition to Everyone 05:55 PM
Sure is!
From raegabelich to All Panelists 05:55 PM
Yes, the same developer group
From Riverpark Coalition to Everyone 05:56 PM
did you read the email I forwarded from Rae?
From LaVonne Miller to Everyone 05:57 PM
I didn't get the email from Rae.

From Serena Steers to Everyone 06:01 PM
I think he needs to read it. He's clearly not been updated on the facts of the surrounding community and the lack of equitable open/green space (i.e. Tree's) to help mitigate the horrific air we have to breath.

This is not Orange County where the Developer is located, in Newport Beach. We have an average loss of our life expectancy of 5-7 years due to the toxic air we have to breathe. Why isn't that taken into consideration of rejecting this ANOTHER atrocity.

From Riverpark Coalition to Everyone 06:03 PM
just like the Boy Scout project!
From Serena Steers to Everyone 06:04 PM
Please review the statistics from the American Lung Association https://www.lung.org/research/sota/city-rankings/msas/los-angeles-long-beach-ca From Riverpark Coalition to Everyone 06:09 PM
Planning Commission – Thursday, September 1, 2022 – Zoom Chat if on the zoom call, how do we unmute? thank you
Me to Riverpark Coalition, All Panelists 06:09 PM
There should be a pop-up on your end.

From LaVonne Miller to Everyone 06:11 PM
"Press and hold the Space key to temporarily unmute yourself.

From raegabelich to All Panelists 06:14 PM
Is that the same method to unmute on IMac
Me to raegabelich, All Panelists 06:15 PM
There should be a pop-up on your end.

From Riverpark Coalition to Everyone 06:49 PM
There are funds! Grants! It requires a commitment from the city! If the Planning Commissions does not approve, it still goes to the city council? How could it possibly get done?
From Serena Steers to Everyone 06:50 PM
but that is only in regards to ground water. What about soil and air quality? From Roger Martin Holman to Everyone 06:50 PM
Because the Planning Commission isn't a binding decision maker.

From JE to Everyone 06:51 PM
What happens at City Council if planning votes no? Can City Council override Planning Vote? From Riverpark Coalition to Everyone 06:52 PM
I heard there is still work being done, how can it be in front of the Planning Commission? I am confused how things work in the city leadership.

Will potential residents sign off they know what the risks are with having their windows open? From Michelle to Everyone 06:53 PM
I'm also confused about this. I live right across the street and I can confirm that work is being done, like grading and flagging on the ground. How are they allowed to do this before the EIR was finalized? We've heard nothing about having over windows open.

From Riverpark Coalition to Everyone 06:53 PM
What about the LUE?
From Michelle to Everyone 06:54 PM
Planning Commission – Thursday, September 1, 2022 – Zoom Chat What is the LUE?
From Serena Steers to All Panelists 06:55 PM
Same thing happened on the north property. The city made a mistake about approving permitting for that property. They put the cart before the horse. Please be areful being outdoors during that time. I live across the street from the north property. \
From Riverpark Coalition to Everyone 06:55 PM
Land Use Element
From Serena Steers to All Panelists 06:55 PM
The dirt that is being “moved" is extremely toxic
From Roger Martin Holman to Everyone 06:56 PM
Hi Michelle! Can you email [email protected] ? We are very active on this and hopefully we can work together on this?
From Riverpark Coalition to Everyone 06:56 PM
YES!!!!!!!!
From Serena Steers to All Panelists 06:56 PM
Your and all others health will unfortunatly suffer due to this. It is the developers responsibility to control dust because of the lead, arsenic, benzine, etc. in it via watering it down before, etc.

From Roger Martin Holman to Everyone 06:57 PM
WRONG!
Work is happening there!
From Serena Steers to All Panelists 06:57 PM
So if you EVER see dust. Call AQMD at 1-800-CUT-SMOG
From Michelle to Everyone 06:57 PM
We're already signed up for the newsletter.

From Riverpark Coalition to Everyone 06:58 PM
They are there doing things, there is a fence that was put up that we can't see what they are doing!! We see dust and know things are going on! Those of us that live clos by are affected! clos = close (sorry)
From Serena Steers to All Panelists 06:58 PM
If 3 or more community members call, they have to send out an Inspector Planning Commission – Thursday, September 1, 2022 – Zoom Chat From Roger Martin Holman to Everyone 06:58 PM
okay, great, thanks Michelle!
From Michelle to Everyone 06:58 PM
I also added CO on Facebook.

From Riverpark Coalition to Everyone 07:04 PM
This is the park I mentioned. https://la.urbanize.city/tags/wishing-tree-park Can we copy the chat window? there are some links that I would like to save. Thank you! From Michelle to Everyone 07:08 PM
Roger, I sent an email.

How do we make those complaints?
What is the phone number?
From Riverpark Coalition to Everyone 07:08 PM
to AQMD?
From Serena Steers to Everyone 07:08 PM
1-800-CUT SMOG
From Michelle to Everyone 07:08 PM
Thank you!
From JE to Everyone 07:09 PM
PLEASE VOTE NO!
From Riverpark Coalition to Everyone 07:10 PM
Use our on-line complaint system to report excessive odors, smoke, dust, or other air contaminants (except smoking vehicles), or call 1-800-CUT SMOG®️ (1-800-288-7664). Smoking vehicles can be reported by calling 1-800-CUT-SMOG.

NO! Please listen to the residents!!
Website: http://www.aqmd.gov/home/air-quality/complaints From JE to Everyone 07:11 PM
Tanaka Park
From Riverpark Coalition to Everyone 07:14 PM
PLEASE SAY NO !!!
Planning Commission – Thursday, September 1, 2022 – Zoom Chat Let me ask - which of you live by this?
From JE to Everyone 07:14 PM
Shame on you, commissioners!
Pathetic!
From Riverpark Coalition to Everyone 07:15 PM
Developers get another piece of our city, the residents get nothing yet again. Very disappointing! From Tilly Hinton, PhD to Everyone 07:15 PM
A horrifying outcome, unsurprising but shameful nevertheless.

From Roger Martin Holman to Everyone 07:15 PM
indeed...

From Riverpark Coalition to Everyone 07:15 PM
Can't say I am surprised. This City has FAILED its residents, From Billy OBrien to All Panelists 07:23 PM
Honestly commissioners. This is upsetting. Did you not hear a word of the public comments? 1 Scott Kinsey
From: Patria Caballero
Sent: Wednesday, September 07, 2022 9:29 AM
To: Scott Kinsey
Cc: Bernard C; junn gabrillo; Andy Luk
Subject: Very Poor Air Quality in Wrigley Heights 90806 -EXTERNALHi Scott,
The air quality in my neighborhood in Wrigley Heights 90806 which is across the vacant lot of Oil Operators (712 Baker St) has gone worst! My house is directly across the vacant lot where there’s some sort of construction going on. In the past few months, whenever I step outside the house, I smell something strange in the air but recently, the sickening odor of petroleum or something like a burnt toxic smell has become more obvious that even when inside the house, I can still smell it ⣚⣛⣜⣝ My AC is on 24/7 and windows are always closed but still the odor is getting inside the house ϋόύώϏϐ My daughter has been suffering from recurring sinus headaches and several of my other neighbors also shared this complaint of poor air quality and pollution. θικλ I reported this to the South Coast Air Quality and their inspector came over and witnessed the odor/pollution first hand! Whatever is going on in that vacant lot is not safe and healthy for the residents here in Wrigley Heights! Please help and advise us before our health and wellbeing gets worse! Few of my neighbors already died from cancer and I’m very worried about the long term effects that this air pollution will cause my family and neighbors. What can you do to help us please? Respectfully,
Patty
P.S. I have cc’d a few if my neighbors in this email.

Sent from my iPhone
SECTION 1
City’s Written Responses
to Public Comments Received
Prior to Planning Commission Hearing
September 1, 2022
Attachment M
Memorandum
Date: September 1, 2022
To: Planning Commissioners and Chair
From: Scott Kinsey, Planner V
Subject: 712 Baker Street (River Park Residential Development Project) Responses to Public Comments
Planning staff has received multiple written comments from the public on this project.

Most of these comments raise the same or substantially similar issues and concerns.

Staff provides this summary of the comments and concerns, along with a response to each, for the Commission’s convenience and incorporation into the record of proceedings.

1. Comment/concern #1: The project consists of affordable housing; what percentage of the project is affordable; how will the affordable housing and residents affect the rest of the project and surrounding neighborhoods? • Response: Of the 226 units in the project, the applicant is electing to provide 5% of the units (12 units) as Very Low Area Median Income (AMI)- level affordable units, under the State’s density bonus law (California Gov’t Code Section 65915). The applicant is not requesting a density bonus but rather a development standards waiver under §65915, to allow the proposed carriage townhomes to be three stories instead of the two-story limit imposed by the General Plan Land Use Element Map. The portion of the project related to affordability and concessions and waivers is a ministerial approval, allowing for no personal judgement or discretion by the City. However, the inclusion of the 12 affordable housing units is not realistically expected to have any negative effects upon the project or surrounding neighborhood, and the affordable units will be indistinguishable from the market-rate units.

2. Comment/concern #2: The entire project site should be developed as a public park; development of this project represents a lost opportunity for the City to develop a park at the project site.
• Response: The project is privately-owned land, and is not now, nor was previously, designated for open space use in the General Plan Land Use Element. The City lacks the structural and one-time funding needed to purchase the site, carry out the required environmental remediation, and develop and operate a public park. The project site was dismissed from consideration for acquisition as City parkland in the City’s April 2021 Open Space Acquisition Study.

3. Comment/concern #3: The project will obstruct or remove access to the Los Angeles River trail; the project will negatively impact equestrian activities or access Response to Public Comments for 712 Baker Street (River Park Residential Development Project)
September 1, 2022