SMCLC Objects to Incomplete, Inaccurate Draft EIR
on Village Trailer Park


December 2, 2011

To: Jing Yeo (by email)
Special Projects Manager
Planning and Community Development
City of Santa Monica
From: The Santa Monica Coalition for a Livable City ("SMCLC")

RE: Comments on the Draft EIR for Village Trailer Park

Dear Ms. Yeo,

The Village Trailer Park ("VTP") is an irreplaceable neighborhood with historic roots that enables affordable homes for low-income residents. 
Our City can never replicate this neighborhood so it is important that any EIR accurately and completely analyze the significant impacts on this neighborhood and its residents and the loss to the City as a whole if the VTP is demolished.

The Santa Monica Coalition for a Livable City ("SMCLC") notes the following deficiencies in the DEIR for the VTP that should be rectified in the final EIR:

• In addition to the "No Project Alternative," the final EIR should include identification of vacant land owned by the City that could be subject of a land swap with the developer for this project (and all other options that do not require the loss of this neighborhood and displacement of its residents).

• The finding of "no historical impact" is premature given that the City's Landmarks Commission is currently reviewing the post World War II history of the property to determine its historical significance. The FEIR should also conduct a full and proper review of the property's historical significance, not conclude, without a basis that there is none.

• Residents who own the trailers at the VTP have been incorrectly described as tenants in the DEIR apparently on the basis that they rent the spaces for their homes. For example, under the No Project Alternative, the DEIR states: "Existing uses on-site would remain. The existing mobile homes and their tenants would not be displaced." But the majority of the residents of the VTP are not tenants who occupy fungible rental housing; they are mobile homeowners who lease their spaces. Moreover, these residents may not be able to relocate their homes because of the age of their trailers or other requirements so they would no longer be homeowners if the project were to be approved.

• The FEIR should discuss whether the proposed project of primarily loft and one-bedroom units as well as the studio and affordable housing units meet the housing needs of the city or the family neighborhood needs of the area in which the property is located under LUCE.

• The FEIR should discuss whether the elimination of the VTP in its entirety is at odds with the LUCE goal to "preserve and enhance neighborhoods" and whether there is a reasonable alternative short of "no project" that would enable the neighborhood to remain intact.

• The DEIR does not include the cumulative traffic and other environmental impacts all of the known projects in the surrounding area as required by CEQA. Section 4.10-18 "Cumulative Impacts," includes only 2834 Colorado Avenue (192,000 sq. ft. -- Colorado Creative Studio Project/Lionsgate) and 2848-2912 Colorado Avenue (300,000 sq. ft. -- Roberts Business Center). This section does not include, as it must, the potential cumulative impacts from the following projects proposed or pending:

• Agensys (153,000 sq. ft. at 1800 Stewart);
• Bergamot Transit Village (770,000 sq. ft. on Olympic between 26th and Stewart);
• New Roads School (117,000 sq. ft. expansion at 3131 Olympic);
• Paseo Nebraska (356,000 sq. ft. at 3025 Olympic, 1820 Berkeley, and 3020-3060 Nebraska); and
• SMC Academy of Entertainment & Technology (48,750 sq. ft. expansion at 1660 Stewart).

Including Village Trailer Park's 399,581 sq. ft., this adds up to over 2,000,000 sq. ft. of development in immediate vicinity. Therefore, all of the circulation impacts currently projected in the DEIR must be revised to reflect these other projects, including but not limited to the following intersections:
20th and Wilshire,
20th and Santa Monica Blvd.,
20th and Olympic,
23rd and Ocean Park Blvd.,
Cloverfield and Santa Monica Blvd.,
Cloverfield and Colorado,
Cloverfield and Olympic,
Cloverfield and the I-10 westbound off-ramp,
Cloverfield and the I-10 eastbound on-ramp,
Cloverfield and Ocean Park Blvd.,
26th and Wilshire,
26th and Colorado Avenue,
26th and Olympic,
Yale and Broadway,
Stewart and Olympic,
Stanford and Colorado,
Centinela and Santa Monica Blvd.,
Centinela and Broadway,
Centinela and Colorado,
Centinela and Pennsylvania,
Centinela and the I-10 westbound ramps,
Bundy and Olympic,
Bundy and Pico,
Bundy and the I-10 eastbound on-ramp,
Bundy and Ocean Park Blvd.,
Barrington and Olympic.

• The Land-use discussion in the DEIR fails to address the significance of the lack of an Area Plan for the development of the entire 140 acres of which this project is but one part. Although the City has accepted a grant of over $600,000 from the federal government to prepare the Bergamot Area Master Plan, no such plan currently exists.

• The conclusion in the DEIR that there is no net loss of rent controlled housing as the result of the project is simply wrong. The DEIR is confusing the rental of spaces with the ownership of homes. The VTP residents own their homes, they rent the spaces on which their homes reside. That doesn't make them "tenants" for purposes of replacement housing. So both Section 4.10-17, which states that, "The proposed project would provide 52 affordable housing units" and Section 4.13-9, which states (as to the VTP residents) "These rent-controlled housing units would be no net loss of rent controlled housing occurs" is incorrect. There would be a loss of 109 homes assuming full trailer home occupancy followed by the construction of only 52 affordable housing rental units.


Diana Gordon

Co-Chair, SMCLC