The City of Los Angeles is using the Final Environmental Impact Report (FEIR) for the city’s General Plan Framework Element as the draft environmental impact report for the fourth revision of the city’s Housing Element 2006-2014.

“The key issues concerning this draft EIR are twofold: does the Framework FEIR adequately address the impacts of this fourth revision of the Housing Element, and should additional alternatives or mitigation measures be considered to avoid or reduce significant effects of the project?” states Department of City Planning documentation.

On Thursday, June 12th, a public meeting regarding the proposed 2006-2014 Housing Element draft EIR was held in downtown Los Angeles before the city Planning Commission and the Affordable Housing Commission.

Some meeting attendees said they were told more changes will be coming to the document, and that there is a push to get it approved by July 1st, scant time to address issues such as the shortages of police, fire and healthcare needs, as well as pressures on utilities and increased traffic.

Gov. Arnold Schwarzenegger recently declared a drought in California, which is with existing infrastructures and doesn’t take into account the requirements of water and sewer services for proposed new construction, said one Westchester resident.

This update of the Housing Element restates the goals, objectives and policies from the current Housing Element 1998-2005. The Framework Element projected the city’s change in population and housing needs from 1990 through today and beyond, also established the city’s capacity to accommodate the projected growth to 4.3 million persons and 1.6 million households, states city planning documentation.

The City of Los Angeles is 469 square miles of land area, with a population of 3.7 million as of October 2005, according to city documentation.

The draft EIR states that “the only material change between the current Housing Element and the updated is the increase in the number of new housing units to be accommodated during this planning period.”

Denny Schneider, a Westchester resident who attended the meeting, said he and other local residents are concerned that the housing plan will cause even more traffic congestion and the potential loss of community-serving retail property.

“The document emphasizes construction of affordable housing for which there is no budget,” Schneider said. “The wholesale demolition of affordable buildings over the recent years to put up larger ones that include a few new, more expensive ‘affordable units’ has resulted in less affordable units than ever.

“The draft EIR is exactly what the city said it is, the same FEIR prepared many years ago. Subsequent development is causing increased air quality and environmental concerns along with even more traffic gridlock,” Schneider said.

“They couldn’t mitigate conditions before so the EIR says that worse conditions cannot be mitigated either. There is a silver lining. The city can generate new revenue from the gridlock by franchising car hops along all the transit corridors. We all need to eat and we’re going nowhere fast.”

Shashi Hanuman, senior staff attorney for the Public Counsel Law Center presented data and statistics formulated by Beth Steckler’s “Affordability Matters” report, found at

Hanuman’s presentation focused on how the draft Housing Element currently addresses preservation and how it can be revised to better address that preservation.

The report states that the city’s own analysis has shown preservation is more cost effective, but data shows huge past and projected losses, said Hanuman.

Hanuman said the report shows that a policy to discourage demolitions and conversions, a preservation barriers assessment and the city wide replacement policy were not implemented by the city until late in the planning period, when advocates advised the city.

In addition, a set goal of preserving the long-term affordability and preservation of 3,500 at-risk units fell short, with only 669 units being preserved.

The current draft Housing Element addresses preservation by focusing on rehabilitation and code enforcement, but the report states that the city “must have programs to both maintain affordability and to structurally rehabilitate,” but no monies are committed to preservation and no effective land use strategies are proposed to preserve.

The draft “fails to continue to include any programs regarding condo conversions, fails to include effective programs to regulate demolitions, fails to include effective policies to preserve at-risk housing, and the program on the Rent Stabilization Ordinance (RSO) simply maintains the RSO and has deleted the provision to prevent unreasonable evictions,” states the report.

The report recommends that tenant protections should be strictly enforced under the Rent Stabilization Ordinance, with heightened enforcement in gentrifying areas; increased commitment/resources to the Los Angeles Housing Department’s Preservation Unit and preserve at-risk housing; and commit resources to monitoring and enforcement of affordability restrictions.

Hanuman said the draft can better address preservation by adding the following land use strategies/programs:

n place annual allowances on demolitions and conversions by planning area;

n strengthen the existing vacancy rate provision in the Los Angeles Municipal Code (LAMC), which allows the city to deny an application for condominium conversion in certain cases; and

n extend demolitions to the LAMC as directed in April 2007.

The California Environmental Quality Act (CEQA) initial study and checklist included with the draft EIR states that “the changes in the environmental setting from the time the Framework Element and Framework Element FEIR were prepared to the end of the planning period for the Housing Element Update were identified and their impacts were analyzed in the Framework Element FEIR.”

The checklist, signed off on by cit planning associates, stated: “Determination: I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or negative declaration pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or negative declaration, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.”

Five categories on the checklist are listed as “potentially significant impacts,” which include air quality, biological resources, public services, transportation/circulation and mandatory findings of significance.

Under the “potentially significant unless mitigation incorporated,” there are also five categories ñ geology and soils, hydrology and water quality, population and housing, public services, recreation and utilities.

One of the impacts considered “less than significant” is the impact on public health facilities. In the draft EIR, it states that “the amount of growth contained in the update could result in a significant increase in demand for public health facilities, such as hospital beds, with one of the most significant deficiencies occurring in Palms-Mar Vista-Del Rey.”

Regarding noise level standards, one statement in the draft EIR is, “While the increased numbers of housing units included in the update to the Housing Element may result in an increase in traffic, this does not mean that noise levels will automatically increase in areas adjacent to freeways, arterials and collector streets.

“An important factor in traffic noise is the actual speed of the traffic. As future traffic volumes increase, the capacity of the roads to carry traffic will be greatly diminished and the result will be a decrease in overall traffic speed.”

One of the programs calls for increasing the production of affordable housing: “Explore the development of a citywide mixed-income ordinance that requires new housing construction to include units that are made affordable to very low and low-income households for at least 30 years.”

This type of program is known as inclusionary zoning, requiring developers to make a percentage of housing units in new residential developments available to low- and moderate ñincome households.

In return, developers receive incentives such as density bonuses, zoning variances and/or expedited permits reducing construction costs.

Comparison of Update (2006-2014) to Current Housing Element (1998-2005):

In a comparison between the current housing element and the update, an identification of change and impact shows original goals, present goals and the impact (all of which state “no change in impact”), there are wording changes to indicate stronger actions by the city to put these changes into place, as well as splitting the one objective into two objectives and one or two policies.

As an example, Objective 1.1 in the current housing element states “encourage production and preservation of an adequate supply of rental and ownership housing to meet the identified needs of persons of all income levels and special needs.”

In the update, that objective has been split into two objectives and one policy — objective 1.1: “plan the capacity and develop incentives for the production of an adequate supply of rental and ownership housing for households of all income levels and special needs; and objective 1.2: develop incentives for the preservation of quality rental and ownership housing for households of all income levels and special needs.

The objective 1.2 Policy 6: “provide incentives that extend affordability to existing market rate housing units.”

Objective 1.1.1 of the current element states “promote neighborhood preservation and rehabilitation to ensure that existing housing is maintained in a decent, safe and sanitary condition.

In the update, that objective was separated into two policies: Policy 1: “facilitate the maintenance of existing housing in decent, safe, healthy and sanitary conditions; and Policy 3: promote preservation of neighborhood character in balance with facilitating new development.”

Public comments in writing with reference to the DEIR case number (ENV-2007-5270-EAF) may be submitted by Monday, July 7th to: Naomi Guth, Department of City Planning, City of Los Angeles, 200 N. Spring St., Room 721, Los Angeles, CA 90012.

The draft EIR can be viewed at the Palms-Rancho Park Branch Library, 2920 Overland Ave., Los Angeles, 90064, and online by clicking on “Draft Housing Element Update” under “What’s New” at