Public Comment Report - Agenda Item 9B — Torrance City Council, May 19, 2026

9. HEARINGS
9B.

Planning Commission and Community Development – Conduct a Public Hearing and Adopt

RESOLUTIONS
to
Deny the Appeal and for the Approval of a Series of Entitlements to Allow the Construction of a New MixedUse Development Comprised of 20 Senior Residential Apartments and 1,608 Square Feet of Commercial Space on Property Located on the East Side of Hawthorne Boulevard, Approximately 200 Feet North of Rolling Hills Road (APNs: 7547004010 through 7547004046) and Determine a Categorical Exemption from the California Environmental Quality Act (CEQA). Expenditure: None.

Name
Jeffrey Lewis
Comment 05/14/2026 10:20 PM : (Against)
Attached please find my letter in opposition to the Walteria Garden Terrace Project scheduled for your May 19, 2026 City Council Meeting.
1 PUBLIC COMMENT REPORT -
AGENDA ITEM 9B

May 14, 2026

VIA E-MAIL ([email protected]; [email protected]) Hon. George K. Chen, Mayor
City of Torrance
Community Development Department
3031 Torrance Boulevard
Torrance, CA 90503
RE: In re Walteria Garden Terrace (20-unit Senior Residential / 1,608 sq. ft. Commercial), east side of Hawthorne Boulevard, approximately 200 feet north of Rolling Hills Road, Torrance; Case Nos. CUP21-00018, DVP21-00001, PRE21-00009, DIV21-00009; APNs 7547-004-010 through 7547-004-046; appeal hearing of May 19, 2026.

Dear Mayor Chen and Members of the Council:

This office is litigation counsel for David Brent and a coalition of neighboring property owners in the Walteria community of Torrance who appear before the Council as appellants opposing the above-referenced project (the “Project”). The Project consists of a 20-unit senior residential and 1,608 square-foot commercial mixed-use development on a hillside parcel within the Hawthorne Boulevard Corridor Specific Plan (HBCSP-WT) and within the City’s Hillside and Local Coastal Overlay District (R-H). The appellants reside directly adjacent to, above, or immediately downslope of the Project site.

The appellants and their consulting experts have, over many months, submitted detailed written comments to City staff, the Planning Commission, and this Council documenting fundamental flaws in the application materials, the technical studies on which staff’s recommendation depends, and the public hearing process itself. Each of those comments has been previously transmitted by e-mail to the Council and to staff and is incorporated here by reference.

We write separately, as litigation counsel, to focus the Council on three discrete legal issues that, in our respectful view, require denial of the appeal’s underlying application — or at a minimum, a continuance — regardless of the merits of the appellants’ design-based and policy-based objections:

First, the proposed reliance on a categorical exemption under the California Environmental Quality Act (“CEQA”, Pub. Resources Code, § 21000 et seq.) is unsupported by substantial evidence. The technical studies underlying the exemption — noise, hydrology, public-sewer capacity, soils, and traffic — contain demonstrable methodological and factual errors. A fair argument that the Project may have significant environmental effects already exists on this record, and the “unusual circumstances” exception (CEQA Guidelines, § 15300.2(c)) further bars the exemption.

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May 14, 2026

Second, the public hearing record before the Council is so incomplete, and the public’s notice of the Project so deficient, that approval on this record would violate procedural due process. The story- pole silhouette posted on the site does not accurately represent the Project’s massing; critical project components (transformer siting, trash and loading, driveway accessibility study, sewer-easement rights) remain unresolved and are deferred to as-yet-unwritten conditions of approval; and the City’s submission portal does not permit appellants to file written comments until after the agenda is publicly posted, which truncates meaningful public participation.

Third, although the Project is properly classified as a Housing Accountability Act (“HAA”, Gov.

Code, § 65589.5) project, the HAA expressly preserves the Council’s authority to deny or condition the Project on the basis of (a) a specific, adverse impact on public health or safety identified in objective, written standards (§ 65589.5(j)(1)(A)) and (b) compliance with CEQA (§ 65589.5(e)). The record here amply supports denial on both grounds.

Our goal in writing is straightforward: to help the City avoid the time, expense, legal fees and reputational cost of a writ proceeding that, on the present record, the City would be at meaningful risk of losing.

Project Background and Procedural Posture
The Project is described on the agenda as a series of entitlements to allow the construction of a new mixed-use development comprised of 20 senior residential apartments and 1,608 square feet of commercial space. The requested entitlements include (i) a Conditional Use Permit (CUP21-00018) in conjunction with a density bonus, (ii) a Development Permit (DVP21-00001), (iii) a Precise Plan of Development (PRE21-00009), and (iv) a Division of Lot (DIV21-00009), on property located within the Hillside and Local Coastal Overlay District (R-H) in the Hawthorne Boulevard Corridor Specific Plan (HBCSP-WT Zone), on the east side of Hawthorne Boulevard, approximately 200 feet north of Rolling Hills Road (APNs 7547-004-010 through 7547-004-046). The agenda also asks the Council to determine that the Project is categorically exempt from CEQA.

The Planning Commission previously considered the application. The appellants — who include adjacent and downslope property owners on Eleda Drive and surrounding streets — timely appealed that decision. The matter now comes before this Council on de novo review.

Throughout the application process, the appellants have repeatedly raised — in writing and at the Planning Commission — the same issues described below. Staff’s recommendation to the Council is that the Council overrule the appeal and adopt the resolutions of approval, treating the Project as categorically exempt from CEQA and deferring a number of unresolved Project components to post-approval conditions. For the reasons set out below, that recommendation cannot lawfully be adopted on this record.
3

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May 14, 2026

The Housing Accountability Act Does Not Foreclose Denial We acknowledge that the Project is a housing development project to which the HAA (Gov. Code, § 65589.5) applies. The appellants are not asking the Council to ignore the HAA. They are asking the Council to deny the Project on grounds that the HAA expressly preserves.

Section 65589.5(j)(1) permits a local agency to disapprove a compliant housing development project where the agency makes written findings, supported by a preponderance of the evidence on the record, that (A) the project would have a “specific, adverse impact upon the public health or safety” and (B) there is no feasible method to satisfactorily mitigate or avoid the adverse impact. A “specific, adverse impact” is defined as a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete. (§ 65589.5(j)(1)(A).) Section 65589.5(e), in turn, makes clear that “[n]othing in this section” relieves the local agency from complying with CEQA — an obligation that exists independently of HAA approval standards.

As set out in Sections 3 and 4 below, the present record warrants denial of the Project approvals.

The Project presents specific, adverse, and quantifiable impacts on public health and safety — driveway/guardrail life-safety, sewer over-capacity that threatens downslope homes with sewage discharge, , and emergency-access constraints — each of which is anchored to objective written standards (Caltrans/AASHTO guardrail warrants, the City’s adopted sewer-capacity criteria, the City’s hillside-grading standards, and Fire Code access criteria). The Council should make the findings necessary to invoke § 65589.5(j)(1)(A); alternatively, the Council should require CEQA review under § 65589.5(e).

CEQA: The Proposed Categorical Exemption Cannot Be Sustained on This Record Staff proposes that the Council determine the Project to be categorically exempt from CEQA. That determination is legally insupportable for two independent reasons. First, the technical studies on which the exemption depends are demonstrably erroneous, which negates the substantial evidence support for a finding that the Project falls within any exemption class. Second, even if the Project facially fit within an exemption class, the “unusual circumstances” exception under CEQA Guidelines § 15300.2(c) applies, because there is a fair argument that the Project may have a significant effect on the environment due to the unusual size, location, soils, hydrology, and access conditions of the site.

The applicable standard is the “fair argument” test: if there is substantial evidence in the record supporting a fair argument that the Project may have a significant environmental effect, the agency must prepare an initial study and, if warranted, an EIR. (No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75; Banker’s Hill, Hillcrest, Park West Community Preservation Group v. City of San Diego (2006) 139 Cal.App.4th 249, 261.) Under Berkeley Hillside Preservation v. City of Berkeley (2015) 60 Cal.4th 1086, an agency may not apply a categorical exemption without considering evidence in its files of potentially significant effects, and the agency loses the benefit of the exemption where unusual 4

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May 14, 2026

circumstances exist and a fair argument of a significant effect is shown. (Id. at pp. 1103—1105.) Where the technical studies an agency relies on to support an exemption are themselves flawed, the studies cannot supply the substantial evidence the exemption requires. (See Cadiz Land Co. v. Rail Cycle, L.P. (2000) 83 Cal.App.4th 74, 117—120.)
The following defects in the studies and the record require, at a minimum, an initial study under CEQA Guidelines § 15063 before the Council determines the level of CEQA review required.

The hydrology report analyzes a different site plan.

The hydrology report in the file was prepared for a prior iteration of the site plan and does not match the current Project footprint, grading volumes, impervious-surface coverage, drainage swales, or catch-basin locations. Storm drainage from a hillside project on a 50% interior slope is not a peripheral CEQA concern; it is precisely the type of “specific, adverse impact upon the public health or safety” contemplated by § 65589.5(j)(1)(A), because failure of the drainage analysis sends water and debris into the homes immediately downslope. A hydrology report tied to a superseded design cannot support either an exemption finding under CEQA or a finding that the Project will not have adverse public-safety impacts under the HAA.

The private sewer lateral lacks easement rights.

The Project’s design routes a private sewer lateral across the adjacent Nakano property by means of a recorded easement that, on its face, is dedicated to the City of Torrance for public sewer purposes. A private property owner does not acquire rights to use a sewer easement granted to the City of Torrance simply because the City permits a development. Unless and until the Nakano family executes a separate grant of private- lateral rights — which they have not done and have indicated they will not do — the Project as designed cannot lawfully discharge its sewage. Approval of a Project whose threshold sanitation infrastructure has no lawful route to the public system is, by definition, arbitrary.

The public sewer cannot handle the increased demands from this Project.

The sewer-capacity study assumes a public sewer pipe of one size; the in-ground pipe is in fact a different and smaller size, and cannot support the the Project’s incremental load.

A finding that sewer service is “adequate” is not supported by substantial evidence where the City’s own pipe does not have the capacity for the additional flows from the Project.

The soils report is not followed by the Project design, and the interior slope approaches 50%.

Appellant Scott’s retained soils engineer has reviewed the applicant’s soils report and concluded that the report’s own recommendations are not implemented in the Project’s grading plan. The interior side of the site contains a slope approaching 50%. The City’s Hillside Overlay District standards exist precisely to limit grading, retaining-wall heights, 5

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May 14, 2026

and slope failure risk in conditions like these. A categorical exemption — whichever class is invoked — cannot be sustained where the Project departs from its own soils engineer’s recommendations on a hillside that is presumptively susceptible to landslide and surcharge failure.

Driveway geometry and emergency access.

The driveway as proposed presents a combination of steepness, angle of attack from Hawthorne Boulevard, and sight-distance constraints that the appellants’ engineering review has identified as inconsistent with established standards. The site is on a curve of a high-speed arterial. The applicant has not produced, and staff has not required, a completed driveway-accessibility study. Instead, that study is deferred to a post-approval condition. Conditions of approval cannot be used to defer the threshold question whether the Project is even safe to access — that question must be answered before the Council determines significance under CEQA and before it makes the findings required to overrule the appellants under § 65589.5(j)(1)(A).

Removal of an existing, warranted guardrail without a warrant analysis.

The Hawthorne Boulevard frontage of the Project site is protected by an existing metal guardrail. The City installed that guardrail because traffic-engineering warrants — under California Department of Transportation guidance and AASHTO’s Roadside Design Guide — supported its installation. Vehicle speeds and average daily traffic on Hawthorne have only increased since installation.

The Project as designed removes a portion of the guardrail and sets back the remaining segments by approximately six feet. The City has not produced a contrary engineering warrant analysis supporting removal. Under longstanding traffic-engineering practice, a public safety device installed should not be removed except upon a documented engineering analysis demonstrating that the warrant no longer obtains. The Project file contains no such analysis. The downslope homes — whose rooflines sit at or below the roadway elevation — will be left in a clear line of sight to any vehicle that loses control on the curve. This is the paradigm case of a “specific, adverse impact upon the public health or safety” under § 65589.5(j)(1)(A), grounded in the City’s own prior, objective traffic-engineering determination that a guardrail was warranted at this very location.

The acoustical/noise study was conducted at the wrong location.

The Project’s acoustical study purports to establish that interior noise levels for senior residents can be maintained at 45 dBA — a level itself problematic given that the State’s recommended interior noise standard for senior housing is 35 dBA — yet the noise meter was not deployed in front of, or even in proximity to, the Project frontage on Hawthorne Boulevard. On information and belief, the acoustical measurements underlying the report were taken in a commercial parking lot far from the site. An acoustical study not conducted at the Project site cannot constitute substantial evidence 6

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May 14, 2026

that Project noise impacts will be less than significant. To the contrary, it constitutes a fair argument that noise impacts have not been adequately analyzed. The Council should not adopt findings premised on this report.

The Project presents “unusual circumstances” precluding any categorical exemption.

Even if the technical studies were not defective, the site and Project together present “unusual circumstances” under CEQA Guidelines § 15300.2(c) and Berkeley Hillside Preservation, supra, 60 Cal.4th at pp. 1103—1105. These include: a hillside site within the Hillside and Local Coastal Overlay (R-H), a 50% driveway slope, access only off a high- speed arterial on a curve, location within a designated Hillside Overlay District adopted in part because of slope-stability and runoff risks, downslope adjacency to existing single-family homes whose rooflines are at or below the road grade, an existing public guardrail whose removal is implicit in the Project, sewer infrastructure that cannot lawfully serve the site without a private easement that does not exist, and acoustical impacts on a senior-housing population that the State has identified as more vulnerable to environmental noise. Each of these is, on its own, atypical for the categorical- exemption classes; in combination, they are the textbook “unusual circumstances” case.

Taken together, the foregoing items are not stray comments to be answered in a staff response memo. They are a fair argument that the Project may have significant environmental effects, and they are an independent basis to find that the categorical exemption does not apply. Either showing, standing alone, requires CEQA review before the Council acts.

Due Process: The Hearing Record Is Materially Incomplete and Misleading A quasi-judicial land-use decision — and the Council’s adjudication of this appeal is quasi-judicial — is governed by procedural due process. (See Horn v. County of Ventura (1979) 24 Cal.3d 605, 612— 614.) Due process requires meaningful notice and a meaningful opportunity to be heard, on an accurate record, before a decision is made. The present hearing record falls short on each of those requirements in three respects.

The story-pole silhouette materially misrepresents the Project.

Story poles serve a quasi-constitutional function: they exist so that neighbors, the public, and the decision-makers can see what is actually being approved before approval is granted. The silhouette currently posted at the site is materially deficient. By the appellants’ on-site observations: (i) at least one of the poles representing the building’s front face is in the wrong location relative to the existing tree line; (ii) one or more of the connecting flag lines was previously down and has been replaced with newer materials that do not accurately reproduce the prior building outline; (iii) the silhouette omits significant project elements, including the large vents on the east-facing elevation and the front-leading edge of the parking garage, which is the portion of the Project closest to 7

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May 14, 2026

the existing single-family homes; and (iv) the pedestrian walkway and fencing along the front are not silhouetted at all.

An adjudicative body cannot lawfully approve a Project on the basis of public notice that does not show the public what is being approved. The defective silhouette is, on its own, a basis to continue the hearing until accurate story poles are installed and a renewed public-comment window is afforded.

Conditions of approval cannot lawfully defer threshold project components.

Staff’s recommendation defers a series of unresolved Project elements to as-yet- unwritten conditions of approval, including: the transformer-siting location; the trash and loading area; the driveway accessibility study; and the resolution of the Nakano sewer easement question. These are not micro-conditions of the kind that conditions of approval are designed to address (construction-hour limitations, landscaping specifications, exterior-paint palettes). They are threshold project components. The Council cannot find that the Project complies with applicable standards, or that it is exempt from CEQA, or that no specific adverse impacts to public health and safety exist, without knowing what those project elements are. Deferring threshold components to conditions deprives the public of the opportunity to comment on the actual Project the Council ends up approving.

The City’s deadline for submission forecloses meaningful written comment.

The City’s public-comment portal for this matter does not permit appellants and members of the public to upload written materials and exhibits until after the agenda for the hearing is publicly posted. That timing means that decision-makers do not have appellants’ final written submissions available far enough in advance of the hearing to consider them in any meaningful sense. While the appellants have e-mailed prior submissions directly to councilmembers (and incorporate those by reference here), the portal-only window is structurally inadequate. In a quasi-judicial proceeding, that procedural posture is constitutionally suspect.

The appellants are not asking the Council to throw out the schedule for this Project.

They are asking the Council to continue the hearing on its own motion until (i) accurate story poles are installed, (ii) all deferred Project components, including conditions, are reduced to writing and noticed for public comment, and (iii) the City’s submission window is opened sufficiently in advance of any hearing on the merits.

Approval on This Record Would Be Arbitrary and Capricious Council action on a land-use entitlement must be supported by findings, and the findings must be supported by substantial evidence in the record. (Topanga Assn. for a Scenic Community v. County of Los Angeles (1974) 11 Cal.3d 506, 514—515.) Findings cannot be lawfully made where the record on which they would rest is internally inconsistent, demonstrably wrong, or silent on threshold issues. 8

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The combination of defects identified above — an acoustical study taken off-site, a hydrology report keyed to a superseded design, a sewer-capacity analysis based on the wrong pipe, a sewer-lateral routing that lacks easement rights, a soils report whose recommendations are not implemented, a driveway-accessibility study deferred to a condition, and the removal of a warranted guardrail without a contrary warrant analysis — is not a record on which the required findings can be supported.

We respectfully submit that any resolution adopting these findings on the present record would be vulnerable to reversal under Code of Civil Procedure section 1094.5 and under the CEQA writ procedures of Public Resources Code section 21167. We raise this not as a threat — the appellants’ preferred outcome is denial on the merits on this Council’s own motion — but as candid notice of the litigation exposure the City should expect on approval.

Requested Action
My clients respectfully request that the Council:
(a)

Include this letter in the administrative record for the Project; (b)

Include this law firm as an interested party for future notices; (c)

Grant the appeal and deny the application on the basis of findings under Government Code § 65589.5(j)(1)(A) — specifically, the driveway/guardrail life-safety impacts, the sewer over-capacity impacts on downslope homes, the soils/slope-stability impacts, and the emergency-access constraints — each grounded in objective written standards in the City’s code and adopted engineering references; or
(d) In the alternative, direct staff to prepare an initial study under CEQA Guidelines § 15063 and, on the basis of that initial study, to prepare an EIR or mitigated negative declaration, as appropriate, before any further Council action; or (e)

At a minimum, continue the hearing to allow accurate story poles to be installed, the deferred project components to be reduced to writing and re-noticed, and the public- submission portal to be opened on a meaningful schedule.

We have written this letter in the spirit of helping the City avoid the time, expense, and reputational cost of a writ proceeding that, on the present record, would be foreseeable. The appellants and their experts remain available to meet with staff and councilmembers in advance of the hearing to walk through any of the above issues. If a site visit would be useful, the appellants will host one.

Thank you for your consideration of these issues.

Respectfully submitted,

Jeffrey Lewis

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May 14, 2026

cc: Client
Hon. Jon Kaji, Councilmember, District 1 ([email protected]) Hon. Bridgett Lewis, Councilmember, District 2 ([email protected]) Hon. Asam Sheikh, Councilmember, District 3 ([email protected]) Hon. Sharon Kalani, Councilmember, District 4 ([email protected]) Hon. Aurelio Mattucci, Councilmember, District 5 ([email protected]) Hon. Dr. Jeremy Gerson, Councilmember, District 6 ([email protected])

10 9.

HEARINGS
9B.

Planning Commission and Community Development – Conduct a Public Hearing and Adopt

Name
Allan Rigg
Comment 05/15/2026 07:11 AM : (Against)
Hi,
These letters are in opposition to the project – CUP2100018, DVP2100001, PRE2100009, DIV2100009: ZEINA AWAD (MAHMOUD H. AWAD TRUSTEE FOR THE MAHMOUD AND NAWAL AWAD TRUST). Please forward them to Council.
11 January 28, 2026

David and Elaine Brent
3614 Eleda Drive
Torrance, CA 90505

Torrance City Council
3031 Torrance Blvd.

Torrance, CA 90503

Re: Proposed Walteria Mixed

Use Project, Eastside Hawthorne Blvd, 200 Ft. North of
Rolling Hills Rd.

Dear Mayor and City Council

Members,

We are the owners of

a
home immediately

adjacent to the proposed mixed

use
development. The photo below shows the visual and physical impact of the proposed project

from our backyard

This project is unsafe and cannot with any modifications be made safe. We urge you to carefully consider the numerous objective reasons our neighbors and consultant have provided to you, so that you will unquestionably deny the project . There are technical issues with the design, many flaws in the technical reports, and multiple unresolved issues that make it appear very doubtful the project can comply with the Torrance City Municipal Code. It seems the

c
ity is ignoring all of these due to
concerns with the State’s directives.

12 There are many critical issues that need to be resolved before the project is approved

that
include:

1. The
project silhouette needs to be modified to include elevated east

facing semi
-
subterranean ‘garage roof extension’ which will be 25 ft above adjacent residential property surface. The east-

facing garage surface with ‘six’ large 7 ft x 18 ft ‘open’ vents will be located only 10 ft from

the
adjacent residential west property line at 3620 Eleda
Drive. However, the silhouette is erected 20 ft from this property line. Therefore, the current silhouette does not simulate the highly

elevated east
-

facing surface of the garage
containing the ‘six’ large open vents.

Poles/line heights and locations

also
need to be
verified and corrected. These are confirmed in the Torrance staff report.

In order to make
these corrections

to
the silhouette, existing scrub trees may need to be trimmed or removed.

2. Project
construction and development will interfere with high-speed downhill Hawthorne Blvd Highway traffic for many months during excavation and construction.

Also, there will be n

o available safe storage location on Hawthorne Blvd for building construction materials.

3. Unsafe
steep single-

driveway for ingress and egress

from semi-

subterranean garage
located on a curved section of

Hawthorne Blvd carrying high

speed downhill traffic
where
senior drivers will experience traffic visibility issues

Semi-subterranean driveway safe
dry-

design upper
-limits have been reached or exceeded.

The parallel-slope (20%) is at the
safe upper-limit however the cross-

slope is 10% which is double the safe
permitted slope
of 5%.

If the driveway is wet, then the driveway will be slippery and potentially very unsafe for ingress and egress

The problem is made

even
worse if

vehicle
tires are worn!
The steep driveway ingress and egress will challenge senior drivers. It will also be unsafe for senior residents to walk up or down the steep driveway

which accesses Hawthorne
Blvd.

4. There will be

i
nadequate parking in the semi

-
subterranean garage for friends, care

-
givers, business patrons, emergency vehicles, cabs/taxis, etc.

The project is also

ADA
non-

compliant and

there
are no designated spaces provided

for Torrance senior service
vehicles.

No surface parking

is available or will be provided

on or near the property for
emergency vehicles and large delivery/hauling trucks.

No safe
-parking location will be
available for

vehicles

on Hawthorne Blvd near the project!

5. The Project will not have a safe parking location on Hawthorne Blvd for

large
fire-
truck, emergency vehicles, and law-

enforcement vehicles
. These vehicles likely have

to
stand in

the narrow Project Deceleration-Lane on Hawthorne Blvd. The only access to

the
Project for large vehicles is from the northbound Hawthorne Blvd Highway

downhill
eastmost lane.
13 6.

There
will be limited sidewalks available for senior residents and

no sidewalk
downhill on

the eastside of

Hawthorne Blvd.

Senior residents will have to ‘walk’ on the
steep Hawthorne Blvd ‘traffic carrying roadway’ to access nearest stores & restaurants located north & downhill on Hawthorne Blvd near Newton Street.

7. Bothersome airborne & ground transmitted fluctuating

intense
vehicular noise
infiltration into the proposed senior living quarters from high-

speed traffic on
Hawthorne
Blvd Highway

which is
only about 25 ft west of the building

will seriously impact the
health of senior residents.

Interior noise level should be kept at 35 dBA or lower for maximum healthful comfort

for senior residents
which is 10 dBA lower than the 45 dBA
value shown in the Developer’s Acoustical Report. Due to the very close proximity of the building to intense fluctuating airborne

noise
& ground transmitted vibration due to heavy
high-

speed traffic
, this is a very poor location for senior housing since this

intense noise
will penetrate the residential unit’s walls, ceilings, windows, doors, and floors.

8. Required Project
SCE transformer location is uncertain and apparently
undetermined.

It must be
safely located and isolated from high

speed traffic on
Hawthorne Blvd.

Also, a
n impact assessment has not been done for the proposed re- location of the electrical support pole on eastside of Hawthorne Blvd for power-lines located on westside of Hawthorne Blvd

9. Project sewage pipe and rainwater drainage pipes should not be connected to Eleda Drive

residential
lines which have small diameter and are only slightly sloped for adequate drainage.

Rainwater collected on the semi

subterranean garage floor will
probably be pumped

-
out onto Hawthorne Blvd along with roof-water collected by

project
catch-basins leading to potential hydroplaning of vehicles going downhill on Hawthorne Boulevard during rainstorms.

10 .

Uncertain status of the onsite PV-

Landfill hazardous groundwater monitoring well
M63B. Potential dangers in plugging or replacing the well which could potentially impact hazardous groundwater table, its drainage under the property, and loss of capability to monitor onsite hazardous-groundwater. The existence of the hazardous groundwater well M63B near center of the property is not discussed in the Developers submitted documents.

This well is important for monitoring the hazardous groundwater status and movement

11. Hazardous inhalable 2.5 Micron dust
will likely be generated

during extensive
excavation which will impact

those residing and working in the area.

The SCAQMD and
residents will use Air Quality Sensors to monitor air-quality and hazardous dust continuously and will

mak
e real-time measurement data available online for the SCAQMD and other authorities to assess!

14 12.

Potential damage to neighboring RHBC and

neighboring
residential buildings due to

long-

term
‘

intense ground

transmitted excavation vibration
’. In addition, neighboring
residents and RHBC office workers will be subjected to ‘intense excavation and construction noise’ for many months due to the close- proximity of the project.

13. Construction Bond(s) are needed and should be

secured by Developer

cover both
RHBC/residential property damages due to intense excavation vibration, damage to existing residential walls/fences/homes due to physical impact, and health damage to business/residential neighbors caused by inhaling hazardous airborne particulates du

ring
excavation and construction.

There is no mention of Bonds in the Dev

el
oper’s documents
submitted to the City of Torrance.

14. Construction of the
equivalent of a 5

-
story tall wrap-

around building
very close to
and seriously impacting adjacent residential properties on Eleda Drive. The presence of numerous windows, patios, elevated walkways, and ‘six’ large 7 ft x 18 ft open-

garage
transmissive vent screens

in close proximity and facing our property that will create privacy and security problems

for residential neighbors

15. The proposed ‘six’ large 7 ft x 18 ft acoustically transmissive garage vents

and only
10 ft from neighboring residential properties on Eleda Drive will radiate very-

disturbing
airborne noise from visitors and automotive horns, tire squeal, engines, door slams, garage interior-

hard
-surface conducted traffic noise from Hawthorne Blvd, etc.

16. Potentially
excessive spill-over night-time project illumination from the many windows and project lighting

will
lead to privacy-

loss and sleep

-
deprivation related issues
since our and our neighbor’s bedroom windows face the

project
property.

17. The proposed tall wrap

around building
placed adjacent to

our property and our
neighbor’s property will cause significant reduction of sunlight in the afternoon and year-round continuous significant airflow blockage. The blockage of air-

flow
will force
us to use excessive electrical power to

cool
our homes

in the summer. Solar panels will
not generate enough electrical power due to

reduced incident

s
unlight exposure by the
proposed project.

Thus, there will be many significant ‘

negative
’ impacts on neighboring residential
property values, security, and quality of life for those living on Eleda Drive. These impacts to our home and our neighbor’s homes will be very extensive and have been ignored by the developer and the city. Please

review
the following photo showing how the
project will look from our home.

We
, as residents of Torrance, are due a thorough and
legally appropriate review of this project which has not yet

been performed by City staff
and the Planning Commission.
15 We hope that the multitude of ‘serious negative environmental, health, and safety issues’ that the proposed project will create, encourages you to make the obvious objective finding to deny this project!

Thank you for the time you have spent reviewing our concerns,

David and Elaine Brent

Note: We are the owners of Reliant Environmental Acoustics, LLC located in Torrance and have performed

500+
industrial, commercial, multi

-
unit residential, and civic
environmental acoustical studies in Torrance, Redondo Beach, and neighboring cities.

We
have performed acoustical studies at the Torrance City Hall Permit Center, Torrance Cultural Arts

Center, Torrance High School Stadium,

American Honda Motor Company
Headquarters, Toyota North American Headquarters,

etc.

On April 14, 2015 we
each
received a Volunteer Noise Consultant Award from the Torrance City Council. As a tenured Assistant Professor of physics, Dave taught environmental acoustics and applied physics at the Lawrence Technological University.

16 January 24, 2026

Anni and Vivian Lee
3620 Eleda
Torrance, CA 90505

City of Torrance
Attention: City Council
3031 Torrance Blvd.

Torrance, CA 90503

Re: CUP21-00018, Proposed Walteria Mixed-Use Project, Eastside Hawthorne Blvd, 200 Ft.

North of Rolling Hills Rd.

Dear City Council Members,
Please find below our comments regarding the proposed Walteria Mixed-Use Project. Our residence is immediately adjacent to the northern boundary of the project site and is therefore uniquely affected by the project’s massing, grading, circulation, and operational characteristics.

The issues outlined below are based on the project’s submitted materials, staff reports, and supporting technical studies.

Please also see the simulations of the project from the rear of our home at the end of this letter.

We invite you to view the project from our yard and home from 12 pm-4 pm the Saturday and Sunday before your review of the project. If you are in the neighborhood another time, please knock on our door and/or email us in advance.

1. Project Massing
The project’s massing places a multi-story residential structure directly along the northern property line, with minimal horizontal or vertical separation from existing single-family development. Due to the parcel’s narrow and irregular geometry, the building envelope concentrates height and bulk at its closest point to adjacent residences. As a result, residential windows and decks are oriented directly toward neighboring private open space, creating clear line-of-sight conditions. These conditions arise from the project’s design and massing strategy and are an objective land-use compatibility issue rather than a matter of personal preference.

2. Incomplete Representation of Building Envelope and Silhouette The submitted silhouette and visual analysis does not fully depict the extent of the building mass, particularly where the garage level projects northward beyond the upper floors. As noted in the staff report, portions of the structure are obscured by existing vegetation. This limitation prevents a complete and accurate assessment of the project’s height, bulk, and scale relative to surrounding development, and constrains the City’s ability to objectively evaluate compliance with applicable development standards.

3. Traffic Safety & Driveway Access
17 The project proposes a driveway and subterranean parking access immediately adjacent to an existing residence along a steep downhill segment of Hawthorne Boulevard. Both resident observations and the civil engineering review indicate that the submitted traffic analysis evaluates only limited sight-distance conditions. It does not address driveway geometry, turning movements, construction-phase impacts, or cumulative safety effects associated with steep grades and high-speed downhill traffic. Without this information, potential vehicular and pedestrian safety impacts cannot be fully evaluated.

4. Shadow Study
According to the project’s shadow study, the proposed structure would cast prolonged shadows on the south and west façades of the adjacent residence during winter daylight hours. This represents a measurable reduction in solar access, with implications for interior daylighting, passive heating, energy consumption, and the feasibility of on-site renewable energy systems.

These impacts are directly attributable to the project’s height, orientation, and proximity.

5. Structural Risk Considerations due to Excavation & Grading The excavation and grading approach relies on assumptions that are not supported once the full scope of construction is considered. Both the project soils report and an independent engineering review indicate that excavation beyond specified depths requires additional analysis and protective measures. Proceeding without updated geotechnical studies, verified shoring systems, and construction monitoring plans raises avoidable risks to adjacent properties and infrastructure. --
The combined effects of building height, massing, proximity, and ongoing operational factors (including lighting, noise, and vehicle activity) raise substantive land-use compatibility concerns.

These factors are standard planning considerations used to assess whether a project is appropriately scaled and sited relative to its surroundings.

We recognize that, under the Housing Accountability Act, project decisions must be based on objective standards and substantial evidence rather than subjective preferences. As outlined above & in the analysis from Rigg Consulting, the project presents unresolved design conflicts, incomplete technical analyses, and quantifiable impacts related to massing, safety, solar access, and excavation. These issues warrant careful consideration and resolution prior to any approval.

We have included a simulation of the project as viewed from our rear yard for reference. We also remain available should decision-makers wish to view the site context directly.

Thank you,
Anni & Vivian
[email protected]

18 19

3620 Eleda Drive
20 January 27 , 2026

Rita and Kevin Nakano
3631 Eleda
Torrance, CA 90505

City of Torrance City Council
3031 Torrance Blvd.

Torrance, CA 90503

Re:

Proposed Walteria
Mixed-Use Project, Eastside Hawthorne Blvd, 200 Ft.

North of Rolling Hills Rd.

Dear Mayor and City Councilmembers

Thank you

very much

fo
r your review of the proposed

development adjacent to our
home. We appreciate your time

enhancing the quality of life in Torrance
.

At the Planning Commission meeting, the city attorney was very clear in that the project was only subject to objective standards and is exempt from the typical protections provided with the Hillside Overlay Zone.

The Commission was
directed to ignore the enormous impacts to us and our neighbors due to the project

’
s massive size and impacts to views and privacy.

It is u
nfortunate that the
State trumps our local laws, but so be it.

However, the concerns we raised at the meeting did not seem to be heard by the Planning Commission. In particular, there is a guardrail on Hawthorne placed long ago to keep vehicles from leaving the roadway and crashing onto the top of our home (please see attached exhibits). We would have expected the city to study why a guardrail was found to be warranted previously, but now it is not needed? The addition of the driveway and loading area in the area of the guardrail will make it even more likely a driver will drive down the loading area and onto our 21 home. Who is liable when a city guardrail is allowed to be removed and our property is damaged or our lives are lost?

We also expressed concerns about the noise created by the driveway towering over our home. The design is such that vehicles will be honking at one another trying to navigate it, and tires will squeal due to the steep design. There will be a significant impact and the city’s CEQA exemption should not be approved.

An additional concern is the proposed sewer line on our property. Long ago an easement to the City of Torrance was created for a public sewer. Now the developer is proposing to place their private sewer in the City’s easement. Our understanding is that an easement’s purpose and beneficiary cannot simply be changed without our permission and proper legal filings. We want to be on record that we oppose any use of the easement by the developer. There is significant risk to us with the failure of the sewer and sewage flowing onto our property and into our home.

In order to enumerate other objective reasons to deny the project, we have engaged Allan Rigg, at no small expense, to provide an expert analysis of the project and the required findings. He has found the design is incorrect, the technical studies are flawed, and that the staff has pushed off many items as conditions of approval, that may or may not be possible. Please deny this project as we have provided you many objective reasons.

Thank you very much for your time,

Rita and Kevin Nakano

22 23

24 Rigg Consulting, Inc.

January 27, 2026

Rigg Consulting, Inc.
6415 Via Canada
Rancho Palos Verdes, CA 90275

City of Torrance City Council
3031 Torrance Boulevard
Torrance, CA 90503

Re: Proposed Walteria Mixed-Use Project, Eastside Hawthorne Blvd, 200 Ft. North of Rolling Hills Rd.

Dear

Mayor Chen and City Councilmembers
,

Thank you for your review of the

proposed Walteria Terrace Garden Project. The project must be denied for a variety of reasons

that
I will provide in three groups – Design Flaws,

Technical
Study Flaws, and Incomplete Design.

As a matter of introduction, I am a dually licensed Planning and Engineering consultant with 38 years of experience in

producing and

reviewing entitlement applications, primarily in Palos
Verdes and the South Bay. For 14 of those years, I served as the Planning Director at the City of Palos Verdes Estates, and for 25

years I have served as the

C
ity

E
ngineer of several cities.

Over
the years I have reviewed many hundreds of proposed projects to determine if they comply with city codes, engineering design criteria, CEQA, and State laws.

This particular

property has a very long history with a variety of design concepts, none of which have been approved. We understand that the city has limited discretion due to the Housing Accountability Act and has no subjective discretion. As directed by the Deputy City Attorney at the Planning Commission’s November 19, 2025 meeting, “…specific findings of fact to suppo

rt
the denial will need to be made.” I agree 100%, and will provide you with the

objective

reasons
to deny this project.

Design Flaws

Driveway Design –

The slope of the driveway is extreme and beyond engineering and safety standards. Measured along the centerline, the slope is 20%, which is high, but often allowed with proper transitions to lower slopes. However, due to the curved nature of the driveway, the slope of the inside curve of the driveway is at least 50%. As cars 25 Rigg Consulting, Inc.
traverse this area they will be subject to sliding and bottoming out. Also, pedestrians cannot feasibly walk down the driveway. Please see below:

Sewer Design – The project is shown to connect to a public sewer in Eleda through an easement on the property at 3631 Eleda. However, the subject property has no right to use the easement as the easement only benefits the City of Torrance and not the subject property. The connection from the proposed building to the public sewer is a sewer lateral and is privately-owned, not a City of Torrance facility. Even if the City of Torrance wanted to allow a private sewer in their public easement, it is not legal. A portion of the tract map establishing the easement is shown below:

Loading and Trash Cannot Occupy the Same Space – The project is required to have one loading space a minimum of 10 feet wide by 25 feet long with a vertical clearance of 26 Rigg Consulting, Inc.
14 feet. Due to the low ceiling in the garage, it must be outside as shown on the plans.

However, the plans also indicate the trash is within the same area. They simply cannot be in the same location:

Driveway Design –

Angle

The City standard for a driveway in the public right of way mandates that it be perpendicular to the curb. However, in an apparent effort to allow for the driveway to curve 180 degrees into the parking garage, the proposed driveway is angled in the right

of
way as shown below. Drivers simply cannot make such a turn, and as such the driveway design does not work and is non-standard. The thick red line shows the alignment of a proper driveway:

27 Rigg Consulting, Inc.

Removal of Guardrail –

The project proposes to remove a portion of an existing guardrail in order to build the driveway. The guardrail was originally installed in response to accidents, or the fear of one due to the high speeds on and the curvature of the road. How can the applicant simply remove the guardrail without a study to determine it is now not needed, or provide alternative protection to drivers and to the residents below?

Technical Study Flaws (Provided to Support a CEQA Exemption)

Sewer Report – There is no capacity for the project’s sewage in the public sewer. The sewer report has erroneous information about the

public sewage

pipe being eight

inches
in diameter. The

County Sanitation Department owns the public line and reported it had been lined with an inside diameter of 7.5 inches. When the pipe capacity at Manhole #4 is calculated with the correct 7.5-inch diameter, the half-full capacity is 0.3622 cubic feet per second, less than the 0.364 flow from the combined flow from the project and the existing peak flows (0.01989 cubic feet per second

from project). When calculated
correctly, the proposed flows push the pipe over capacity.

As such
, the project would
have a significant impact on the environment and could cause sewer overflows. Also, the existing flows are based on measurements from nine years ago, before full occupancy of Sunrise. It also does not account for wet weather flows.

Here is the letter from the
Sanitation District

and then an excerpt from the Sewer Report
:

28 Rigg Consulting, Inc.

Traffic Access Study – The study is incomplete as it only includes a Stopping Sight Distance analysis, but does not analyze other potential concerns as noted in the attached memo from the traffic engineering firm Fehr & Peers:

•

A site intersection analysis per AASHTO should have been completed. •

In the analysis in the Traffic Access Study the driver’s eye position is incorrect. •

Vehicles temporarily parked at the curb would obstruct drivers’ views and methods to eliminate this situation should have been reviewed. •

The driveway design has a sharp curve and vehicles navigating the curve may cause additional view blockage.
•

A parking management plan for the construction period should been reviewed due to site constraints.

CEQA requires analysis of impacts caused by construction, especially if they create safety issues.

Hydrology Report – The hydrology report is based on the Walteria Townhome proposal in 2021. The report references two driveways, while this project only has one. Also, the proposed imperviousness is shown at 60% when the actual is 82

so the report is not
based on the proposed project. Also, it conveniently does not include a

site plan or a map
designating where storm flows will be routed.

This report is for a different project.

Incomplete Design

Loading Area

– The staff report references that a proper loading area is not located on the plans and indicates this will be solved with a condition of approval. Condition #16 for the Conditional Use Permit is shown below and indicates the

loading space needs to
be revised or relocated to provide for a 14-foot height clearance, and that the outdoor loading space needs to be relocated or redesigned not to provide a traffic collision conflict. This is very inappropriate to approve a plan that does not seem to be able to comply with the Code.

Trash Room – Similar to the Loading Area condition, condition #19 for the Conditional Use Permit is shown below and indicates the trash room needs to be proven to be developable within the building or moved outside. With the interior ceiling being very 29 Rigg Consulting, Inc.
low and that there is minimal open space on the lot to place a trash enclosure. In the staff report it is admitted that it is unclear whether trash trucks can access the interior trash room. Again, this is very inappropriate to approve a plan that does not seem to be able to comply with the Code.

Electrical Transformers – Similar to the Loading Area and Trash Room conditions, condition #28 for the Conditional Use Permit is shown below and requires that the transformers not be located in the front setback. The transformer is currently shown in the front setback. There is little room

outside the front setback for a transformer
, and
SCE has very specific access requirements for their transformers and a location may not be possible. Again, this is very inappropriate to approve a plan that does not seem to be able to comply with the Code.

Driveway Turning Template Study – Similar to the Loading Area, Trash Room, and Electrical Transformer conditions, condition #41 for the Conditional Use Permit is shown below and requires that a study be done to demonstrate that vehicles can turn into the garage.

This is similar to the comment provided by our traffic engineer. Again, this is very inappropriate to approve a plan that does not seem to be able to comply with the 30 Rigg Consulting, Inc.

Code or be functional. There would seem to be liability for the city to approve a project that has not been properly design and so many potential flaws have been demonstrated:

Parking – Sharing of Commercial and Guest Analysis Not Provided The staff report indicates that four parking stalls will be shared for guest parking and commercial parking per the CUP approval. However, per State Law AB 894 and Torrance

engineering standards, a study is required to show that the timing of the usage of the shared stalls is different. It is likely that the parking stalls will be desired to be used by both the commercial and residential guests at the same time and not comply with the shared-parking standard.

We have provided 13 objective reasons why this project cannot be approved. In summary:

•

Design flaws:
o

The driveway is too steep and contrary to standard design. o

The sewer lateral does not have legal authority to be

located
as designed.
o

The trash enclosure and loading area cannot occupy the same space. o

The driveway angle is inappropriate and contrary to standard design. o

The removal of the existing guardrail has not been justified.

•

Technical study flaws:
o

The public sewer size in the capacity calculations is wrong, and there is no capacity for the project’s sewage.
o

The traffic access study uses wrong criteria and does not fully evaluate the project’s impacts.
o

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 designed to comply with critical requirements of the city:

Loading area.
o

Trash room/enclosure.
o

Electrical transformers
o

Driveway accessibility
o

Sharing of parking stalls
31 Rigg Consulting, Inc.

The Housing Accountability Act allows you to use objective criteria

such as these

to deny a
project. Additionally, CEQA does not allow you to use an Exemption when there are possible or know significant impacts from a project. You are allowed, and required, to deny this project.

Sincerely,

Allan Rigg, PE AICP

Attachment

–

Fehr & Peers Report

32 25500 HAWTHORNE BOULEVARD, SUITE 2250

TORRANCE, CALIFORNIA 90505

T: 310-698- 5310

January 2

8 , 2026

City of Torrance City Council
3031 Torrance Blvd.

Torrance, CA 90503

RE: Public Comment
CUP21

-
00018, DVP21

00001,
PRE21

00009,
DIV21

00009

East Side

of Hawthorne

Blvd, Approximately 200

Ft.

North of Rolling Hills
Rd.

Dear Mr. Mayor and Councilmembers:

I previously wrote to the Planning Commission regarding significant technical and safety concerns with the proposed project’s development. The Planning Commission did not discuss my concerns and seemed intimidated by the characterization of the project as a housing development project under the Housing Accountability Act (HAA).

The project should not get a rubber stamp due to the HHA, but should be reviewed based on the objective findings as mandated by law.

Since the Planning Commission meeting, a group of concerned property owners has hired a local land use consultant to review the project. He has found an extensive number of design flaws, errors in technical reports, and unresolved issues in the design. Rather than reiterate all of these, I urge you to review each one of the issues in detail in his letter.

tely
150 feet long, and is also ten feet closer to the neighbor’s property than the constructed silhouette. The developer represents the garage as being subterranean, but this isn’t the case with the down slope portion that will be exposed to the neighbors.

The silhouette as depicted only reflects the construction of the residential living units (not the garage). It is not representative of the total structure that will be built.

My previous letter focused on the significant unresolved geotechnical and construction

safety risks

that directly affect the adjacent commercial property to the south. These risks are clearly documented within the applicant’s own geotechnical report and project section drawings, and they have not been adequately addressed

in
the

development submittal. Below is a summary of the

most critical deficiencies, all
sourced from the project’s own documentation.

33 January 20, 2026

Page 2 of 6 ends

1. Temporary Excavation Hazards Are Not Properly Addressed or Mitigated

Excavation depth exceeds what the soils report identifies as safe. The soils report states in Section 13.15

–
Temporary Excavations, that:
• Excavations more than 16 feet are not anticipated.
• The same section includes a chart indicating that any cut greater than 20 feet requires special engineering review and reevaluation.

However, the developer’s Building Section A drawing shows the parking level floor elevation at 207.5 feet, which does not include:
• slab thickness
• footings / grade beams
• required remedial excavation depth per Section 13.1 – Remedial Grading Recommendations

Using the site’s highest adjacent grade and the report’s own remedial grading requirements, the actual excavation height is 23 feet (see attached Exhibit A

–
applicant’s
survey)

, well above

both the 16

foot assumption and the 20

foot reevaluation threshold.

This
requires a completely new engineering analysis—

none has been provided.

b) Excavation is located directly on the property line, violating surcharge limits.

Section 13.15

also states:
• No surcharging is allowed within 5 feet of the temporary excavation.

Yet the adjacent commercial property uses this 5

foot zone for:

• daily vehicle parking
• delivery truck operations
• a large Southern California Edison transformer

All of these impose significant surcharge loads directly on the edge of the proposed vertical excavation. This creates a known and unacceptable risk of soil movement, wall failure, or structural damage

to the adjacent property.

c) The soils report itself warns of dangerous soil movement. Section

13.19 states:
• Major yielding of the adjacent soils may occur during construction. Care should be taken that any movements associated with the yielding are not excessive to harm any underground utilities or adjacent structures.

Given that the project proposes a vertical cut on the property line, in highly expansive soils, near active parking and utility infrastructure, the conditions for “major yielding” directly contradict the required safety margin. The project does not provide any design, shoring plan, vibration mitigation, or monitoring program capable of addressing this risk.

34 January 20, 2026

Page 3 of 6 ends

2. The Project’s Excavation Height Conflicts With Its Own Required Remedial Grading

Section 13.3

–
Site Preparation

identifies required remedial over -

excavation and
recompaction for support of the building’s foundation systems. The submitted drawings fail to incorporate:
• remedial cut depth / over excavation
• slab thickness
• footing depth
• grade beam depth (see attached Exhibit B)

When these are included

— as required

— the true excavation height becomes 23
feet, which materially exceeds the assumptions used in the soils report’s temporary excavation safety calculations. This is not a small discrepancy. It is a fundamental engineering mismatch that invalidates the temporary shoring safety analysis and exposes neighboring properties to subsidence, cracking, and structural risk.

3. Lack of Protective Measures for Adjacent Commercial Operations

The soils report explicitly prohibits loads within 5 feet of the cut and warns of major yielding. Despite this, the submittal offers no:
• engineering reevaluation for deeper cuts
• protections for the existing transformer
• monitoring plan for soil movement
• indemnification or mitigation for damage to adjacent structures

Given that the adjacent property is fully developed, occupied daily by commercial tenants, and houses critical electrical infrastructure, the absence of these protections is unacceptable.

Conclusion – Project Should Not Be Approved as Submitted

The deficiencies described above originate from the developer’s own soils report and drawings. They demonstrate that:
• Required remedial excavation depths and safety requirements were not incorporated in the recommendations
• The proposed vertical cut exceeds all stated safe limits. • The adjacent property’s active use violates the soils report’s 5 - foot surcharge exclusion zone.
• The soils report acknowledges the real possibility of “major yielding” that could damage neighboring structures.

Until these geotechnical inconsistencies are fully resolved

— with revised excavation
depths, updated shoring

recommendations
, and protections for adjacent property — the
project presents unacceptable safety and liability risks . For these reasons, I respectfully request that the

City Council

deny approval of the project in its current form.
35 January 20, 2026

Page 4 of 6 ends

Thank you for your consideration.

Sincerely,

Rolling Hills Business Centre, LLC

Scott Douglas, Manager

36 January 20, 2026

Page 5 of 6 ends

Exhibit A

37 January 20, 2026

Page 6 of 6 ends

Exhibit B

38 9.

HEARINGS
9B.

Planning Commission and Community Development – Conduct a Public Hearing and Adopt

Name
Allan Rigg
Comment 05/15/2026 07:13 AM : (Against)
Hi,
Please find the attached documents in opposition to CUP2100018, DVP2100001, PRE2100009, DIV2100009: ZEINA AWAD (MAHMOUD H. AWAD TRUSTEE FOR THE MAHMOUD AND NAWAL AWAD TRUST).
39 Walteria Terrace Garden Project
1) Project Silhouette & Groundwater Monitoring Well
2) Project Driveway Safety Concerns
3) Project Environmental & Security Impacts
4) Project will Seriously Impact Senior Residents
and Neighboring Residential Properties
40 Current Silhouette
Missing Line
Existing Line
Hazardous
Groundwater/Vapor
Monitoring Well
41 Steep Entrance Driveway with Tight Hairpin U-Turn Into the Semi-Subterranean Garage The Tight Entrance Hairpin U-Turn inner radius is approx. 15 ft., the outer radius is approx. 30 ft., and midpoint radius is approx. 22.5 ft, whereas the Safe Turn Radius for Emergency Vehicles is 40 ft.

The Entrance Turn Lane Boundaries are shown by the Red Lines. The Driveway is also highly sloped and angled.

Some Senior Drivers, automobiles, and SUVs will require larger turn radii to safely enter and exit the garage.

Vehicles with Large Turning-Radius might have to back-out the Entrance Driveway onto Hawthorne Blvd. 42 NOTE: The Large Garage Vents, Pedestrian Deck, and Residential Patios will be a ‘Source of Noise and Reduced Security’, in addition the Large Number of Windows and Glass Doors will be a ‘Source of Troublesome Spill-Over Night-time Illumination’ onto Neighboring R1 Residential Properties in the ‘Torrance Hillside Overlay District’. Furthermore, there will also be a ‘Significant Reduction in Air-Flow Ventilation and Circulation’ and ‘Reduced Solar-Illumination’ for these Residential Properties. The proposed Wrap-Around Building will be 10 ft from Residential Properties, and will tower over them similar to a five story (50 ft) high building. 43 Significant Project Issues
# The Project Hair-Pin U-Turn Entrance Driveway is Unsafe since it Very Steep and Tight, preventing Senior Drivers, larger automobiles, trucks, and emergency vehicles from safely entering the garage. # Removal of Critical Traffic Guardrail on Hawthorne Blvd used to Protect Residents on Eleda Drive. # Significant Collected Rainwater could be dumped onto Hawthorne Blvd leading to Vehicular Hydroplaning. # There will be Traffic Blockage for Months due to trucks accessing & departing the steeply-sloped property on Busy Hawthorne Blvd carrying High-Speed Traffic.
# Likely Failure of the 8ft high Concrete Wall on the RHBC parking lot Due to Close, Deep-Excavation. # The Project will have No Significant Sidewalks for Senior Residents along Hawthorne Blvd. # The Project Interior Average Noise Level is planned for 45 dBA, but should be 35 dBA for Senior Residents. # The Project will Block Sunlight during the winter months and Reduce Air-Flow year-round on Neighboring Residential Properties on Eleda Drive.
# The Project will generate Bothersome Night-Time Illumination Spill-Over from the many glass windows and doors causing Sleep Issues for Neighboring Residents.
# The Seven Large Garage Ventilation Vents and the Elevated Pedestrian Deck and Patios facing residential properties will be a Source of Troublesome Vehicular and Human Noise. # The Project will Reduce Security & Privacy on Eleda Drive, Madison Street, and Candlewood Road due to the Elevated Pedestrian Deck and Patios facing residential properties on these roadways. # The Project will be Highly-Invasive and will Wrap-Around the neighboring residential properties on Eleda Drive located in the Torrance Hillside Overlay District.
# The Important Well M63B for Monitoring Hazardous PV Landfill Vapors/Liquids will be plugged and abandoned. 44 Walteria Terrace Garden
Project
May 19, 2026
45 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
46 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.
47 The current proposal destroys
the adjacent neighborhood and
is not the type of project that
the Council has expressed their
opposition to

.
48 You have many objective
reasons to deny the project
that support your
commitment to the
community.
49 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.
50 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
51 Design Flaw #1: Driveway Geometry and Safety
Issues
• Centerline driveway slope is
about 20%
• Inside curve is a t 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
52 Design Flaw #1: Driveway Geometry and Safety
53 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
• B oth 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
54 Design Flaw #2 - No Legal Authority to Use Easement
55 Design Flaw #3 - Loading and Trash Same Location
56 Design Flaw #4 - Non-Standard and Unsafe Driveway Apron 57 Design Flaw #5 – Guardrail Removed – Exposes Homes Below 58 Design Flaw #6 – Soils Report Recommendations not
Incorporated into Design
59 Technical Study Flaw #1: Sewer Capacity
• S ewer 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.
60 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
61 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
62 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.
63 Incomplete Design #4 : Driveway Accessibility
64 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.
65 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
66 Conclusion
• We have presented 1 4 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 d eny the project based on these reasons, which support the Council’s commitment to protect single family residential neighborhoods.
67 9.

HEARINGS
9B.

Planning Commission and Community Development – Conduct a Public Hearing and Adopt

Name
Zeina Awad
Comment 05/18/2026 09:31 AM : (For)
Attached please find the acoustical engineer's Response to Comments #2 for the Walteria Senior Residential Noise Impact Study. We respectfully request approval of the project and denial of the appeal.
68 AZ Office CA Office
4960 S. Gilbert Road, Ste 1-461
1197 Los Angeles Avenue, Ste C-256
Chandler, AZ 85249Simi Valley, CA 93065
p. (602) 774-1950 p. (805) 426-4477
www.mdacoustics.com

1 May 15, 2026

Ms. Danika Sinohin
ZS Development Corp.
11646 Prairie Ave.

Hawthorne, CA 99250

Subject: Walteria Senior Residential – Noise Impact Study – Torrance, CA Response to Comments #2

Dear Ms. Sinohin,

MD Acoustics, LLC (MD) has received comments from the concerned residents David and Elane Brent for the proposed Walteria Senior Residential project dated January 28, 2026. MD has provided these responses to the comments as outlined below:

Comment 1 : Bothersome airborne & ground transmitted fluctuating intense vehicular noise infiltration into the proposed senior living quarters from high-speed traffic on Hawthorne Blvd Highway which is only about 25 ft west of the building will seriously impact the health of senior residents. Interior noise level should be kept at 35 dBA or lower for maximum healthful comfort for senior residents which is 10 dBA lower than the 45 dBA value shown in the Developer’s Acoustical Report. Due to the very close proximity of the building to intense fluctuating airborne noise & ground transmitted vibration due to heavy high-speed traffic, this is a very poor location for senior housing since this intense noise will penetrate the residential unit’s walls, ceilings, windows, doors, and floors.

MD Response: Per Chapter 12, Section 1206.4 “Allowable Interior Noise Levels” from the 2025 California Building Code, the interior noise threshold for any habitable room is 45 dBA Ldn or CNEL. The project meets this requirement.

Comment 2 : Potential damage to neighboring RHBC and neighboring residential buildings due to long-term ‘intense ground-transmitted excavation vibration’. In addition, neighboring residents and RHBC office workers will be subjected to ‘intense excavation and construction noise’ for many months due to the close-proximity of the project.

MD Response: The construction of the proposed project would not require the use of equipment such as pile drivers, which are known to generate substantial construction vibration levels. At the nearest off-site residence, the projected vibration due to project construction activities is below the applicable threshold for newer residential structures from the Caltrans Transportation and Construction Induced Vibration Guidance Manual. See Section 8 of the noise study prepared by MD. 69 Walteria Senior Residential
Noise Impact Study
City of Torrance, CA – Response to Comments#1
2 Comment 3. The proposed ‘six’ large 7 ft x 18 ft acoustically transmissive garage vents and only 10 ft from neighboring residential properties on Eleda Drive will radiate very-disturbing airborne noise from visitors and automotive horns, tire squeal, engines, door slams, garage interior-hard-surface conducted traffic noise from Hawthorne Blvd, etc.

MD Response: The attached updated SoundPLAN model shows the combined impact of project HVAC and parking noise. The garage vents were modeled as entirely acoustically transparent, as illustrated in the 3D model. The model assumes that the parking lot will have 10 movements per hour. This number of movements was chosen based on the peak hour trips from the Trip Generation prepared for the project by K2 Traffic Engineering, Inc. The updated SoundPLAN model shows even quieter levels than the model in the noise study and is more accurate to the actual peak hour traffic conditions. Thus, parking noise from the acoustically transmissive garage will not exceed the City’s noise requirements.

This response to comments addresses the direct noise complaints received from residents. All other noise complaints addressed issues already discussed in the comments above. The on-site interior noise, construction vibration, and parking noise transmitted through the garage vents were addressed. Please do not hesitate to call our CA office at 805-426-4477 with any questions or comments.

Sincerely,
MD Acoustics, LLC

Naomi Jensen
Acoustical Consultant, INCE-USA
70 14592501_25480 Hawthorne Blvd Torrance Noise
Noise Level Contours
Signs and symbols
57 5058 5159 52 Level table, dBA
Buildings
Auto Parking
Parapet Walls
HVAC
Point Receivers
Levels in dB(A)
< 45
45 - 50
50 - 55
55 - 60
60 - 65
>= 65
Length scale 1:40
0 25 50 100 150
feet
1 42
2 41
3 40
4 37
5 36
71 14592501_25480 Hawthorne Blvd Torrance Noise
Noise Level Contours
Signs and symbols
57 5058 5159 52 Level table, dBA
Buildings
Auto Parking
Parapet Wall
HVAC
Point Receiver
Levels in dB(A)
< 45
45 - 50
50 - 55
55 - 60
60 - 65
>= 65
Length scale 1:230
0 150 300 600 900
72 9.

HEARINGS
9B.

Planning Commission and Community Development – Conduct a Public Hearing and Adopt

Name
Zeina Awad
Comment 05/18/2026 10:04 AM : (For)
Attached please find the Response to Comments addressing Air Quality and Greenhouse Gas Emissions for the Walteria Senior Residential project. We respectfully request approval of the project and denial of the appeal. 73 From: Seth Myers [email protected]
Sub ect: RE: Plannin Commission Pro ect Hearin - Walteria

Air Quality/Greenhouse Gas Emissions-related comment responses

David and Elaine Brent Letter

Comment: “Hazardous inhalable 2.5 Micron dust will likely be generated during extensive excavation which will impact those residing and working in the area. The SCAQMD and residents will use Air Quality Sensors to monitor air-quality and hazardous dust continuously and will make real-time measurement data available online for the SCAQMD and other authorities to assess!”

Response: The comment expresses concern regarding the generation of PM2.5 (ﬁne particulate matter) and fugitive dust during project excavation and construction activities. As discussed in Section 2.3.3, “Impact Analysis,” of the Air Quality and Greenhouse Gas Assessment, the Project’s construction-related air pollutant emissions, including PM2.5 and fugitive dust (PM10), were quantitatively evaluated using the California Emissions Estimator Model (CalEEMod) in accordance with South Coast Air Quality Management District (SCAQMD) guidance and methodologies.

The analysis evaluated both regional and localized construction emissions and compared the results to the SCAQMD’s adopted signiﬁcance thresholds. As shown in Tables 2-6 and 2-7 of the Assessment, construction-generated PM2.5 and PM10 emissions would remain below applicable SCAQMD regional and localized signiﬁcance thresholds, including thresholds speciﬁcally intended to protect nearby sensitive receptors from substantial pollutant concentrations.

The Assessment also notes that construction activities would be required to comply with SCAQMD Rule 403 (Fugitive Dust), which requires implementation of dust- control measures such as watering exposed surfaces, limiting vehicle speeds on unpaved areas, sweeping adjacent roadways, and covering haul trucks to minimize particulate matter emissions during construction.

Based on the analysis contained in Section 2.3.3, Project construction emissions, including PM2.5 emissions associated with excavation and grading activities, would not exceed SCAQMD signiﬁcance thresholds and would therefore result in a less- than-signiﬁcant air quality impact under CEQA. The commenter’s statement regarding the potential use of air quality sensors by SCAQMD or nearby residents to monitor local air quality does not alter the conclusions of the analysis.

Seth Myers  Air Quality/Noise Task Manager  ECORP Consulting, Inc.

California Small Business for Public Works (SB-PW, #12138) [email protected]  Ph: (530) 717-7600
Rocklin  Redlands  Irvine  San Diego  Chico  Santa Fe  Fresno 74 9.

HEARINGS
9B.

Planning Commission and Community Development – Conduct a Public Hearing and Adopt

Name
Zeina Awad
Comment 05/18/2026 10:48 AM : (For)
Attached please find the Response to Comments from C.L. Geosolutions, Inc., the project's geotechnical engineer of record, addressing the geotechnical and constructionsafety concerns raised regarding the Walteria Senior Residential project.

We respectfully request approval of the project and denial of the appeal. 75 76

77 78

79 80

January 28, 2026
City of Torrance City Council
3031 Torrance Blvd.

Torrance, CA 90503
RE: Public Comment
CUP21-00018, DVP21-00001, PRE21-00009, DIV21-00009
East Side of Hawthorne Blvd, Approximately 200 Ft. North of Rolling Hills Rd.

Dear Mr. Mayor and Councilmembers:

The project should not get a rubber stamp due to the HHA, but should be reviewed based on the objective findings as mandated by law.

I would also like to comment on the errors in the silhouette, beyond those identified by staff in the staff report. The silhouette omitted the northeast wall of the garage structure, which is approximately 25 feet tall above neighbor’s grade, is approximately 150 feet long, and is also ten feet closer to the neighbor’s property than the constructed silhouette. The developer represents the garage as being subterranean, but this isn’t the case with the down slope portion that will be exposed to the neighbors.

The silhouette as depicted only reflects the construction of the residential living units (not the garage). It is not representative of the total structure that will be built.

My previous letter focused on the significant unresolved geotechnical and construction-safety risks that directly affect the adjacent commercial property to the south. These risks are clearly documented within the applicant’s own geotechnical report and project section drawings, and they have not been adequately addressed in the development submittal. Below is a summary of the most critical deficiencies, all sourced from the project’s own documentation.
25500 H AWTHORNE B OULEVARD , S UITE 2250
T ORRANCE , C ALIFORNIA 90505
T : 310-698-5310
81 January 20, 2026

Page 2 of 6 ends

1. Temporary Excavation Hazards Are Not Properly Addressed or Mitigated a) Excavation depth exceeds what the soils report identifies as safe. The soils report states in Section 13.15 – Temporary Excavations, that:
•
•
Excavations more than 16 feet are not anticipated.

The same section includes a chart indicating that any cut greater than 20 feet requires special engineering review and reevaluation.

However, the developer’s Building Section A drawing shows the parking level floor elevation at 207.5 feet, which does not include:
•
•
•
slab thickness
footings / grade beams
required remedial excavation depth per Section 13.1 – Remedial Grading Recommendations
Using the site’s highest adjacent grade and the report’s own remedial grading requirements, the actual excavation height is 23 feet (see attached Exhibit A – applicant’s survey), well above both the 16-foot assumption and the 20-foot reevaluation threshold. This requires a completely new engineering analysis—none has been provided. b) Excavation is located directly on the property line, violating surcharge limits.

Section 13.15 also states:
• No surcharging is allowed within 5 feet of the temporary excavation.

Yet the adjacent commercial property uses this 5-foot zone for:
daily vehicle parking
delivery truck operations
•
•
• a large Southern California Edison transformer
All of these impose significant surcharge loads directly on the edge of the proposed vertical excavation. This creates a known and unacceptable risk of soil movement, wall failure, or structural damage to the adjacent property. c) The soils report itself warns of dangerous soil movement. Section

Page 3 of 6 ends

2. The Project’s Excavation Height Conflicts With Its Own Required Remedial Grading
Section 13.3 – Site Preparation identifies required remedial over-excavation and recompaction for support of the building’s foundation systems. The submitted drawings fail to incorporate:
•
•
•
•
remedial cut depth / over excavation
slab thickness
footing depth
grade beam depth (see attached Exhibit B)
When these are included — as required — the true excavation height becomes 23 feet, which materially exceeds the assumptions used in the soils report’s temporary excavation safety calculations. This is not a small discrepancy. It is a fundamental engineering mismatch that invalidates the temporary shoring safety analysis and exposes neighboring properties to subsidence, cracking, and structural risk.

3. Lack of Protective Measures for Adjacent Commercial Operations The soils report explicitly prohibits loads within 5 feet of the cut and warns of major yielding. Despite this, the submittal offers no:
•
•
•
•
engineering reevaluation for deeper cuts
protections for the existing transformer
monitoring plan for soil movement
indemnification or mitigation for damage to adjacent structures Given that the adjacent property is fully developed, occupied daily by commercial tenants, and houses critical electrical infrastructure, the absence of these protections is unacceptable.

Conclusion – Project Should Not Be Approved as Submitted The deficiencies described above originate from the developer’s own soils report and drawings. They demonstrate that:
• Required remedial excavation depths and safety requirements were not incorporated in the recommendations
•
•
The proposed vertical cut exceeds all stated safe limits.

The adjacent property’s active use violates the soils report’s 5-foot surcharge exclusion zone.
• The soils report acknowledges the real possibility of “major yielding” that could damage neighboring structures.

Until these geotechnical inconsistencies are fully resolved — with revised excavation depths, updated shoring recommendations, and protections for adjacent property — the project presents unacceptable safety and liability risks. For these reasons, I respectfully request that the City Council deny approval of the project in its current form. 83 January 20, 2026

Page 4 of 6 ends

Thank you for your consideration.

Sincerely,
Rolling Hills Business Centre, LLC
Scott Douglas, Manager
84 January 20, 2026

Page 5 of 6 ends

Exhibit A
85 January 20, 2026

Page 6 of 6 ends

Exhibit B
86 9.

HEARINGS
9B.

Planning Commission and Community Development – Conduct a Public Hearing and Adopt

Name
Zeina Awad
Comment 05/18/2026 10:53 AM : (For)
The engineer who prepared the project's Sewer Area Study, Conway Cooke, has reviewed the sewer capacity concerns raised in the public comment and provided the following response:
"The letter states that the sewer pipe size is 7.5 inches per the Sanitation District report.

However, there is typically no standard VCP 7.5inch sewer pipe size. Standard sewer pipe diameters are generally 4", 6", 8", 10", 12", etc., making 7.5 inches an unusual size. Even if the 7.5inch pipe size is correct, the difference between the proposed flow and the sewer pipe operating at half full is only 0.002 cfs. Based on this, the proposed flow should be able to be accommodated within the existing sewer pipe capacity." We respectfully request the Council deny the appeal and approve the project as recommended.
87 9.

HEARINGS
9B.

Planning Commission and Community Development – Conduct a Public Hearing and Adopt

Name
Mike Griffiths
Comment 05/18/2026 05:36 PM : (No Vote)
Dear Mayor and Council
Please read my attached letter containing comments regarding item 9B on tomorrow's council agenda. And please provide a copy for the record to be included in the supplemental for this item.

Thank you,
Mike
88 May 18, 2026
Torrance Mayor and City Councilmembers:

Let me start off by saying that I am writing regarding item 9B on the May 19, 2026 agenda, and I’m speaking as a resident who lives very near the subject property. I am very familiar with this location both from the Hawthorne Blvd side, as well as the downslope Walteria neighborhood below the subject property.

If there ever was a property that should never be built on, this is one such property. It is such a narrow property, on a very steep slope, overhanging a residential neighborhood below it. It is on the downhill side of Hawthorne Blvd, on which the traffic flows very fast downhill, and there are many accidents resulting from the downhill speeds, not to mention that this is not only on the steep downhill slope of Hawthorne Blvd., but it also is curving to the left as you pass this property going northbound, which is the only side of Hawthorne that will have access to the ONLY driveway to the proposed project. Cars that miss this curve going too fast could easily crash into whatever might be built at this property, and that is a reason that part of this property is protected by a EXISTING strong guardrail, that I understand would be partially removed as proposed. I strongly hope that all members of City Council personally visit both the Hawthorne side of the project, as well as the neighborhood below on Madison Street and Eleda Street, to see how this project is so detrimental to this location firsthand.

It is also very important to note that the map included in the agenda item (page 31) is missing an important element. That being that Madison Street is COMPLETELY CLOSED OFF at the North end of its intersection with Eleda Street from the North, and at Madison Street and Candlewood when approaching from the South. This PREVENTS ANY vehicular traffic, including construction and emergency vehicles which may need to access this property in case of a fire or landslide or other emergency, forcing them to navigate into a primarily R1 zoned neighborhood for access to the site from the East.

I am not a lawyer, or a safety expert, or a geologist, but common sense tells me that the proposed project consisting of 20 SENIOR residential apartments would suggest to most people that Senior Citizens living or visiting here would very likely have a challenging time safely entering and exiting this property via the only proposed driveway onto the CURVING portion of DOWNHILL Northbound Hawthorne Blvd, let alone delivery vehicles, vans, or trucks needing to access the property, with traffic barreling downhill usually faster than the speed limit in this section of Hawthorne Blvd. (Stand there and watch for yourself! And drive it a few times!).

Additionally, the steep slope on potentially unstable ground with residential properties immediately below would be concerns for landslide slippage, water/sewer drainage overflows, etc., considering that this land was or is part of the Butcher Hill geology, including diatomaceous earth mined from this property many decades ago. We all hear about the unstable geology of the hills in Palos Verdes, and the damage it has caused to properties that were developed there, initially thinking that the ground was stable. That land, now dealing with ground slippage, should never have been developed, as I believe is the case with this property.
89 I think just the above mentioned concerns about safety alone are enough reasons to deny this project.

The liability to the City of approving this project with these concerns to me does not justify the small benefit that this project adds to the community.

But if that isn’t enough of a reason to OBJECTIVELY deny the project, then the more subjective elements that the HOO was designed to protect should come into play – protection of views, light, air, massing and privacy, all of which will be severely impeded by this project on the properties to the South and East of this project.

It is so unbelievable for the developer of this project to invoke State housing laws, specifically, density bonus, for which they aren’t really even taking full advantage of, except to try to hide behind protection for this project by the Housing Accountability Act, that this would be the only way that this project could get approved. Without those protections, it would be likely that this project would be denied in a heartbeat. It is shameful for any developer to take advantage of these State Mandates, without providing any significant benefit to the City, except to provide the financial benefit to the developer/property owner, who will take the money, and leave the consequences and liability to the City and its residents.

This project screams for the City to take a stand to protect the community from this kind of poor development. I have read the letter provided by the appellant’s attorney, Jeff Lewis Law dated May 14, 2026, and I believe that there are enough reasons both within that letter, and mine and other’s observations, that this project should be denied, and the City, if need be, should be willing to take a stand against State laws being used to allow projects significantly detrimental to the safety and well being of our community to be stopped once and for all. Torrance has done a great job so far following the State mandates and progress towards RHNA allocations, and this project adds little towards meeting those goals, yet creates significant, and PERMANENT damage to our community, and to the safety and well being of the residents affected by it and even those who live in it, if it is allowed to be built. Please vote NO on this project.

Thank you,
Respectfully,
Mike Griffiths – Walteria Resident of over 40 years
90

Torrance City CouncilMay 19, 2026

Torrance City Council
May 19, 2026