Walteria Terrace Garden
Project
May 19, 2026
Allan Rigg, PE AICP
• Certified Planner for 25 Years and Registered Engineer for 34 Years
• Planning Director for 14 Years at City of PVE
• Public Works Director for 26 Years at PVE, Stanton,
and Gardena
• Consultant for 12 Years in the South Bay
• Expert Witness in a Variety of Engineering and
Planning Litigation
We appreciate the fact that
Mayor Chen and Council
Members understand the
need to preserve our
neighborhoods and quality of
life, while building housing in
the right places with minimal
disruptions to city residents.
The current proposal destroys
the adjacent neighborhood and
is not the type of project that
the Council has expressed their
opposition to.
You have many objective
reasons to deny the project
that support your
commitment to the
community.
Incomplete design
Direction from Staff to Planning Commission
“Deputy City Attorney Guerrero stated to the Commission that this is a HAA (Housing Accountability Act) project and therefore the commission must look at the factors of this project objectively. Vice Chair’s comments regarding the quality of life, that is a subjective standard, the commission must look at the objective standards. If the commission denies the project, specific findings of fact to support the denial will need to be made.” “Planning Manager Garcia stated in response to the motion to deny, which is a pending motion, the commission will need to provide factual information as to why the commission is denying the project; this means to state adverse impacts, significant impacts, and unavoidable impacts based on objective, identified public health and welfare, most of what the commission has stated as concerns related to safety is mostly related to traffic and this is not part of the project.”
Message – Factual and Objective Information is Needed
to Deny the Project.
Design flaws
• Driveway is too
steep
• Sewer connection
lacks legal authority
as designed
• Loading and trash
are shown in the
same space
• The driveway angle
is contrary to
standard design
• Guardrail removal is
not justified
• Soils report
recommendations
not incorporated in
design - unsafe
Technical study
flaws
• Sewer capacity
analysis uses wrong
pipe diameter
resulting in no
capacity
• Traffic access study
is incomplete
• Hydrology report
appears based on a
different project
Incomplete
design
• Loading area
unresolved
• Trash
room/enclosure
unresolved
• Transformer location
unresolved
• Vehicle turning and
shared parking
unresolved
• Sharing of parking
stalls not justified
14 Factual and Objective Reasons to Deny
Design Flaw #1: Driveway Geometry and Safety
Issues
• Centerline driveway slope is
about 20%
• Inside curve is at 50% slope
• Vehicles may slide or bottom
out
• Pedestrian use of driveway is
infeasible
Implication
• Driveway fails engineering
and safety standards
• Curved, steep geometry may
make the garage access
nonfunctional
• This is as an objective basis
for denial
Design Flaw #1: Driveway Geometry and Safety
Design Flaws #2–#5
Sewer design
• Proposed sewer route uses an
easement that benefits only the
City, not the property
• Private sewer lateral in that
easement is not legally
permissible
Loading vs. trash
• Required outdoor loading
space and trash area are
shown in the same location
• Both functions cannot legally
and practically occupy the
same space
Driveway angle
• City standard requires a
driveway perpendicular to the
curb
• Proposed angled approach will
make turning into the garage
unworkable
Guardrail removal
• Existing guardrail would be
removed for a driveway
without a study showing it is
no longer needed
• No alternative protection is
identified
Design Flaw #2 - No Legal Authority to Use Easement
Design Flaw #3 - Loading and Trash Same Location
Design Flaw #4 - Non-Standard and Unsafe Driveway Apron
Design Flaw #5 – Guardrail Removed – Exposes Homes Below
Design Flaw #6 – Soils Report Recommendations not
Incorporated into Design
Technical Study Flaw #1: Sewer Capacity
• Sewer report assumed an 8-inch public sewer, but the sanitation district reported a lined inside diameter of 7.5 inches.
• Using 7.5 inches, the half-full capacity at Manhole #4 is calculated in the letter at 0.3622 cfs.
• The combined peak flow would be 0.364 cfs, which would exceed capacity.
• Additional criticisms: old flow data, no wet-weather accounting, and risk of sewer overflows.
Technical Study Flaws #2–#3
Traffic access study
• Only stopping sight distance
analysis was provided
• AASHTO site intersection
analysis was not completed
• Driver eye position is incorrect
• Curbside parking, curve
navigation, and construction-
period parking impacts were
not fully analyzed
Hydrology report
• Report is said to be based
on the 2021 Walteria
Townhome proposal
• References two driveways
while current project has one
• Imperviousness allegedly
shown as 60% versus actual
82%
• No clear routing plan for
storm flows is identified –
possibly diverts flows onto
SFR properties
Incomplete Design #1 - #3 : Key Unresolved Conditions
Loading area
• Condition says
loading must be
revised or
relocated to
achieve 14-foot
clearance
• Outdoor loading
also must avoid
traffic conflict
Trash room
• Condition
requires proof the
trash room is
developable or
moved outside
• Truck access and
buildability
remain unclear
Transformers /
vehicle access
• Transformer
cannot remain in
front setback
• No other feasible
location
Incomplete Design #4 : Driveway Accessibility
• Staff report has a condition of approval “That a turning template study for the proposed driveway is required to demonstrate that vehicles are able to turn into the subterranean garage”.
• It is easy to see the turning movement into the garage, not even including the 50% slope, will be difficult or even impossible. This should have been resolved for a project to be deemed complete.
Incomplete Design #4 : Driveway Accessibility
Incomplete Design #5 : Parking and Shared-Use Concern
• Staff report indicates four stalls would be shared between guest and commercial parking.
• A formal shared-parking analysis is required under AB 894 and Torrance standards.
• The concern is that residential guests and commercial users will demand the same spaces at the same time.
• Without the study, the project’s parking supply and operations remain unproven.
Objective Reasons to Deny the Project Help Support the City Council’s Commitment to Develop Housing in Right Locations Design flaws:
• The driveway is too steep and contrary to standard design. • The sewer lateral does not have legal authority to be located as designed. • The trash enclosure and loading area cannot occupy the same space. • The driveway angle is inappropriate and contrary to standard design. • The removal of the existing guardrail has not been justified. • Soils report recommendations not incorporated in design - unsafe Technical study flaws:
• The public sewer size in the capacity calculations is wrong, and there is no capacity for the project’s sewage.
• The traffic access study uses wrong criteria and does not fully evaluate the project’s impacts. • The hydrology report is based on a different site plan from a previous proposed project.
Incomplete design, the project may not be able to be built to comply with critical requirements of the city:
• Loading area.
• Trash room/enclosure.
• Electrical transformers
• Driveway accessibility
• Sharing of parking stalls
Conclusion
• We have presented 14 objective reasons for denial across three categories: design flaws, technical study flaws, and incomplete design.
• The project is not presently eligible for CEQA exemption. • Please deny the project based on these reasons, which support the Council’s commitment to protect single family residential neighborhoods.