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November 23, 2011
Ms. Claire Bowin City Planner, Los Angeles Department of City Planning 200 N. Spring Street, Room 410 Los Angeles, CA 90012 Via E-mail: Claire.bowin@lacity.org RE: Cornfield Arroyo Seco Specific Plan and Redevelopment Plan Draft Environmental Impact Report, ENV-2009-599-EIR, State Clearinghouse #2009031002 Dear Ms. Bowin: On behalf of the Green LA Coalition Transportation Work Group, I would like to express our concerns about the Cornfields Arroyo Seco Specific Plan (CASP) and the Draft Environmental Impact Report (DEIR) for the CASP Project area. We believe CASP could have a negative, irreversible impact for the local community. While we support and laud many of CASP’s goals, we believe that there are several shortcoming of CASP as related to its stated goals of increasing livability, social equity, and environmental protections. Below is a summary of our concerns: CASP in its current form is likely to accelerate the displacement of low-income communities of color CASP is insufficient in providing incentives for affordable housing Given the toxicity of the area, CASP must do more to address environmental justice CASP should support local jobs for local residents
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In addition, we are concerned that the DEIR analysis is flawed, and the CASP will subject current and future residents to considerable environmental harm. As such, we believe that the DEIR fails to comply with CEQA because it does not properly or sufficiently analyze the significant impacts of the CASP. The DEIR does not provide adequate analysis of alternatives or of mitigation opportunities.
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We further encourage the City to analyze the proposed Community Oriented Development Overlay Zone (COD) alternative developed by SEACA and Public Counsel with key stakeholders in the CASP area (attached below) and to re-circulate the DEIR with analysis of the COD alternative for public comment. We believe the COD alternative would increase affordable housing and mitigate various significant and unmitigated impacts identified in the Draft EIR.
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