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RE: Land Use Element (LUE) Environmental Impact Report (EIR) and Placetypes when combined
with tenets of Senate Bill 35(SB35)
Two aspects of the LUE are unacceptable as 1) the Program EIR that describes future traffic impacts
with no mitigation plan and 2) the placetypes that when coupled with SB35, make the placetype maps
irrelevant. These two risk areas make proceeding with the LUE in its current format a dangerous
proposition for our City.
EIR
The traffic study in the LUE EIR (section 4.8-34 ) concludes that a total of 44 intersections in the City
will degrade to a LOS (level of service) E or F. Development Services did not include any mitigation
plans associated with this risk element. This violates State environmental law. By their own
admission in the EIR, anything below a level D is a failure in terms of managing traffic. That seems to
have been tragically overlooked as each intensive round of density was added to the plan over recent
months, making failure of even more intersections probable.
PLACETYPES
While the recent release of the placetype maps does show that some of the planned density has been
reduced, the plan remains unacceptable with respect to the input given by the residents at the outreach
sessions. The main objections to this plan include:
increased traffic
reduced parking
pressure on inadequate infrastructure (police, fire, water, gas, electrical, sewage etc.)
Because of the impact of SB35 and related housing bills recently passed by the State Legislature, the
placetype concept, while providing granularity that supports managing the plan, it also results in a
negative impact when coupled with the streamlined process. No matter the height (# of stories) shown
on the placetype maps, a developer is required to build to the maximum height allowed by the
placetype to obtain approval for the streamlined process.
SB35 65913.4 (3) (a) 5(A) A development shall be deemed consistent with the objective zoning standards related to
housing density, as applicable, if the density proposed is compliant with the maximum density allowed within that land
use designation, notwithstanding any specified maximum unit allocation that may result in fewer units of housing being
permitted.
Additionally, incentives (refer to Density Bonus Law in Section65915) for building low income
housing allow the developer to apply for greater density (additional stories) and less parking.
SUMMARY: The heights shown on the placetype maps are irrelevant and give a false description of
future building heights and density. There is no way for the City to control building and development
using this methodology. We need a go-forward strategy of compliance that retains maximum control at
the City level and our goal should be to comply with the lowest density acceptable within the law.
In light of the flaws in our current LUE methodology, when coupled with SB35 and additionally the
degradation of traffic with the current plans, it would be prudent to consider replacing this LUE with a
methodology that supports maximum control of development by our City. The Mobility Plan that
suggests the residents of Long Beach will replace their cars with buses, bicycles and walking is
preposterous. It is time to acknowledge that our current General Plan is a failed attempt. The good
news is there is no deadline. We can abandon the course we are on and replace it with a more
optimistic version thereby giving greater protective assurances to Long Beach residents.
Respectfully,
Corliss Lee