TO: [email protected], councilmember.[email protected]

CC: [email protected], [email protected], [email protected], charlie.rausch@lacity,org, [email protected], [email protected], [email protected]

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Dear Members of the Planning Commission and Councilmember de León:

I am [your name, a little about yourself ] and I am a member of the Onteora Hillside Alliance.  I am opposed to a land development project by Leap of Faith Partners, LLC (LOF), located at 4875 Onteora Way.   It is the LAST open space hillside in Eagle Rock.  My opposition extends to an application for a Zone Change (APCE:2020-6555 ZC HCA) from RE20 to RE11 – to place 14 prefabricated/modular units, mounted on triangular caissons on a narrow 4.3-acre hillside land base formation of Topanga and Duarte shales (where currently only 2-4 homes should be built).  It’s unthinkable to put such multi-story units on stilits in a designated landslide area (Zimas.org).   I am also opposed to (ENV 2020-3136 EAF) the unimaginable cutting down/removal of 29+ protected, 80+ year old Live Oak trees – some with 12’-30’ canopies on the property – so they can be replaced with 18”H tree replacements that will take years to grow.  (There are conflicting numbers between LOF’s two arborist’s reports and the TT Vesting Map 83148 on the number of trees to removed.)  

When reviewed by the Land Use Committee and Eagle Rock Neighborhood Council, the filed paperwork on this project was incomplete and inadequate, and failed to have the signature of the City Clerk.  The Eagle Rock Neighborhood Council Board voted to oppose this Onteora development and sent a Letter of Opposition to the City Planning Commission and Councilmember Kevin de León, CD#14.  This action was supported by several hundred emails, letters and calls from stakeholders from the Northeast Los Angeles community.  Over 1500 individuals have signed two different petitions between 2016-2021.  This project also involves a CEQA issue and should enlist the counsel of the Native American community. 

I am not opposed to the addition of much needed, affordable housing in Los Angeles, but this is NOT the project. It is NOT affordable housing, and it is not the BEST project for our Eagle Rock area.  It is woefully incomplete and inadequate and requires a FULL Environmental Impact Report, a city-initiated Full Traffic Study, A CEQA review, and a Fire Department Review, and geotechnical and hydrologic studies.  I have attached a list of “bullet” points at the end of my letter related to why each of these issues pose community dangers and appear incomplete and inadequate.

Onteora Way has been a “start/stop” project since 2016. It was terminated by the City in October 2018.  It is unclear why.  What is clear are companies shielded by an LLC designation can cut a project loose at any time and for many reasons, including financial ones, and never follow through.  There are two such “eyesores” in Eagle Rock (after ‘permitted’ 25+ years ago) – one at the eastern base of the Onteora hillside (Fair Park Ave.) the other on Colorado Blvd. known to locals as “Pillarhenge.” Both remain incomplete.

For me, the Onteora project presents the veiled, socio-economic illusion that it seeks to advance such initiatives as ‘sustainability’ and the ‘need for housing’, as well as less neighborhood disruption.  It does not.  It fails to embrace any of the new landscape ideologies for Los Angeles urban planning.  Moreover, as plans progressed, the developer failed to respond to neighborhood outreach (per the discussion in the ERNC Board meeting, 1/5/21); and failed to contact The Eagle Rock Association (TERA)- a community-based organization. (Communication, Merideth, President of TERA, 1/12/21).  He has been less than cooperative.

As this process moves forward, I question Leap of Faith Partners, LLC willingness to comply with Los Angeles’ municipal codes, ordinances, and building and safety regulations.  Since 2015 it has failed to clear the hillside grasses and underbrush from its two vacant parcels, ignoring City of Los Angeles Municipal Ordinance Section 57.322 in a Very High Fire Hazard Severity Zone.  A letter to the Los Angeles Fire Commission (Ltr. 6/17/16) and others 4/4/16; 7/14/16; 1/11/16 to LAFD Brush Clearance; and phone call to a member of the Onteora Hillside Alliance from fire battalion chief Ernie Bobadilla (6/28/16) noted the owner was finally forced to clear the land of this severe fire hazard.  Yet despite yearly fire citations, the problems of brush clearance persisted well after clearance notification dates. (Referral to Fire Marshall Lance Matthews who was assigned this area until 2020).  It would seem the developer has little regard for City code and ordinances.  All above references are available for your review.

I thank the City Planning Commission, City Planners and Councilman de León for your attention to this critical Eagle Rock Community Concern.  I and my neighbors look to your careful consideration of what is presented as a dangerous, inadequate, incomplete and opportunistic development project by Leap of Faith Partners, LLC (Noah Ornstein, principal at 4875 W Onteora Way.  The Eagle Rock Community voice is clear.  We DO NOT want this ill-advised development on this last open hillside space in our area; and we ask the city to NOT ‘greenlight’ APCE 2020-6555 ZC HCA.  

Sincerely,

[ your name ]

[ your address ]  

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CRITICAL BULLET POINTS

These points address in detail the Negative and Dangerous Impact the Leap of Faith Partners’ LLC development will have on my community and immediate neighborhood.

Environmental (Cultural [CEQA] and Physical) Issues: (ENV 2020-3136 EAF)

• There has been NO Complete Environmental study.  The 2007-2008 MND is woefully inadequate and incomplete:   A FULL EIR IS REQUIRED.

• There is NO city-initiated traffic study.  This subdivision project demands one due to anticipated increased hillside traffic congestion and increased dangers to existing neighbors in a Very High Fire Hazard Severity and earthquake zone – especially on Round Top Dr. used as an “over-the-hill” thoroughfare from Glendale to Eagle Rock. A FULL CITY-INITIATED TRAFFIC STUDY IS MANDATED. 

• There is NO Fire Department Review in this Very High Fire Hazard Severity Zone.  Brent Kneisler is the current Fire Marshall in our area.  A LAFD REVIEW IS IMPERATIVE.
• The units are dangerous additions in an Earthquake (Raymond Fault) and Very High Fire Hazard Severity Zone (Zimas.org). The weight of construction materials, attic or open spaces filled with lightweight trusses supporting a roof over floor joists that are attached to some type of board (maybe gypsum) by a highly flammable glue are factors.  Will they be covered with a flammable siding or as a fire chief calls them a “solidified gasoline wrap?”  (Gallagher, 2009. Fire Engineering, “The Dangers of Modular Construction”).
• There is danger to existing residents when 14 prefabricated, stacked modules, mounted on ”triangular” caissons, will be drilled into a sloping hillside formation of Topanga/Duarte shale in a city-designated landslide area (one of many in Eagle Rock, Glassell Park and Highland Park on the fault zone).  Such “stilts” are a great way to place units on unstable ground.  Since the unit is built up, off the ground, it’s up to these stilts themselves to give stability rather than the ground underneath. This allows houses to be built in otherwise unstable places and minimize a unit’s footprint, thus allowing the developer to place more homes on the hillside land base – and in a city-identified land slide area.
• Fire and earthquake evacuations on a hillside from a SINGLE ingress/egress in a subdivision onto a small cul-de-sac pose clear dangers to residents.
• There is no share of regional jobs within a commute through high-transit public transportation. Hillside living most often requires private vehicle use.  

• There is no evidence of a cultural resource(s) survey(s) on the Onteora site, despite the fact that a prehistoric ¾” grooved hand axe (AD 1200 – American Southwest; and on exhibit and the Natural History Museum of Los Angeles County) was found within 1000 feet of the site at 4564 Wawona St. It was identified as a trade item into the area.  It is unclear if the developer has consulted with local Kizh/Tongva and Tataviam tribes under AB52, and California Public Cultural Resources Code Sections 21000-21004 to discuss whether the area was developed as a possible trade, food gathering site.  It is well-documented there was Uto-Aztecan speaking Kizh (Gabrieleno/Tongva habitation sites in Northeast Los Angeles, identified as Hahamonga, Tobgna? Harasgna and Yangna (downtown) (King, 2014 Ethnographic Overview of The Los Angeles National Forest: Tataviam & San Gabriel Mountain Serrano.Ethnohistory).  This is clearly a CEQA issue.  A FULL CEQA REVIEW IS MANDATED.

• Any additional archaeological cultural resources would be further destroyed during site grading.
• During consideration of the project, tribal and other commenters should be consulted as to whether it is a tribal cultural resource and assert whether the mitigation measures for cultural resources are adequate to avoid the impact. The mitigation should call for tribal monitors during construction, notification of likely descendants in case of the discovery of human remains, and data recovery.  For legal review see: Save the Agoura Cornell Knowll vs, City of Agoura Hills (March 17, 2020).
• Climate Change and Global Warming demand increased greenspace and tree canopies to mitigate increasing temperatures, retain rainwater in watersheds and lessen runoff, trap carbon emissions, especially from the nearby 134 and 2 Freeways.  The developer wants to cut down at least 29+ protected trees. 
• Live Oaks maintain biodiversity and control erosion; the latter being critical in the Onteora landslide area. Live Oak Trees are a KEYSTONE SPECIES – a species on which many other organisms in an ecosystem depend.  If lost the ecosystem would change drastically. 
• Live Oaks continue to be useful to individuals and wildlife even after they die.
• The Onteora open space is a necessity that plays an important functional role in the filtration of water and protecting wildlife habitats. 
• The Onteora development would cause Eagle Rock to lose a critical ecosystem that supports array of wildlife (coyotes, raptors, many species of birds, burrowing owls, squirrels, snakes, skunks, opossum, racoons, et al) and especially coyotes and raptor birds who hunt daily on the property.
• Extreme addition of noise decibels and dust to existing neighbors. No wall barriers between proposed subdivision street and existing homes on Kerwin Place and Round Top Drive.  
• It does not sustain environmental and social equity in our area.  Eagle Rock has been and remains a diverse population of people and cultures.
• There will be a strain on capacity for social and emergency services.  NELAPD division reported (2017) there are only 7 police response units available in a 39 square mile area of NELA.  
• There is NOT ONE iota of this development’s benefit to the overall Eagle Rock community.

Zoning and Construction Concerns: (APCE 2020-6555 ZC HCA) TT MAP 83148 HCA

• There are inadequate and incomplete geotechnical and hydrologic studies.  And, neighbors report a natural Spring exists on the eastern slope of the hillside behind homes on College View – NOT reported on the 2007-2008 MND.   THE PLAN REQUIRES ADDITIONAL GEOTECHNICAL AND HYDROLOGIC STUDIES.
• Earth Fault Zone, Raymond Fault 6.5 RM
• In land use planning there is Zoning ‘piece-mealing’ at the north end to 4900 Onteora NW to Lockhaven and NE to Fair Park Ave. and Yosemite Dr.  Parcel 5683028026 is currently RE20; Parcel 5683027010 is currently R1.  Spot zoning on this property should not be allowed. 
• Harm to the homes and people who reside on Lockhaven St and Yosemite Dr/College View/Loy Lane and Onteora Dr. directly below the development.  Drilling and the weight of 14 multi-story units on caissons on the western slope, weaken the eastern slope and the entire hillside land base and pose a danger to all homes in the immediate vicinity.
• There will be considerable hillside grading and land infill. There could be 14000-20000 cubic yards of dirt moved throughout the hillside.  There is a need for a certified grading plan with information regarding cut and fill, how much bulk is cut and hauled vs. that which is cut and placed on site.  We oppose the “slicing and dicing” of our hillside.
• Storm and drainage on steep ridgelines are a major concern.  Lower NW-erly slopes are above Lockhaven Runoff Diversion. Kerwin Pl. – Lockhaven St. is a steept Woodland and Ridgeline.   What were the reasons in 1960s for building a V-ditch along the Lockhaven easterly slope property lines from the top of the Onteora property?  There are different elevations on the property: NW side 700 Ft.-640’ to NW downhill.   On the SW end 810’-790-770’ NE end. S/SE side: 810’-790-775’ at hillside crest and run into backyards of Kerwin and Round Top residences. (2021, CT Williams, geologist/zoologist PhD).  There is no indication storm waters, water main breaks will be diverted away from neighboring homes.  Moreover, concerns that in certain storm periods (experienced in 2016, 2017 and 2020) especially with the altering/grading of the hillside land base for this subdivision, water runoff could exceed the capacity of existing or planned storm water drainage systems with polluted water runoff. 
• Storm drains connecting to non-conforming drains on Lockhaven Ave and everything may have to be redone. There is added expense for Lockhaven and Kerwin Place homeowners.
• There is danger in one-way “Y” turnarounds.  Large fire trucks and emergency vehicles will have difficulty in a Very High Fire Hazard Severity and The Raymond Fault earthquake Zones.
• The subdivision is planned with a dangerous SINGLE ingress/egress that empties into a small cul-de-sac (Kerwin Pl) whose only access is Round Top Dr. At this conjunction there is a very steep 13 % downgrade. 
• There is no minimization of dirt truck haul routes, nor minimization of the extensive hauling of modular units through narrow hillside (and other) Eagle Rock streets to create multi-story structures with the use of large cranes on the property.  This poses considerable disruption to the community. Homeowners will be unhappy with the possibility of 140 days (6d/wk+23 weeks, up to 6 months).  
• There is no safe plan for staging areas (cranes, modules, worker parking, porta-pottys, et al and the anticipated overspill onto Kerwin (cul de sac).  Disruptive to neighborhood.  
• Concerns for glare/sun reflection from the modular units. 
• Concerns for extensive street parking along, and placement of lighting on the new subdivision street that abuts the backyards of homes on Kerwin Place and Round Top.  No retaining wall for protection from carbon emissions and noise.  
• Added noise due to elevated sources and reflective hillside slopes.
• It does NOT shorten construction schedule and there WILL BE considerable impacts on the existing neighborhood.
• There are major concerns with the danger and disruption of connecting to an older, existing 1960’s infrastructure of gas, above ground electrical telephone and cable lines.  Will our taxes and general costs increase?
• The pumping and emptying of sewage lines into an old infrastructure on our hillside are concerns.
• It does NOT optimize resources to be less destructive; and increases the DANGER to existing homes, particularly with the use of cranes on this narrow hillside strip of property. 
• The 14 units are not part of LA’s desired affordable housing; and they are expected to be offered at high-end market prices. 

Developer and the Development Plan Ignores The Northeast Los Angeles Community and City General Plans

• It promotes “destruction and deterioration of community resources, including neighborhood scenic viewsheds, open space corridor…. “ (Northeast Los Angeles Community Plan; pp.1-9) on the last green space hillside in Eagle Rock.
• It violates guidelines that disallow “The encroachment of incompatible uses and inappropriately-scaled [prefabricated, modular, in this case] development into single-family and low density neighborhoods” (NELA Community Plan; pp. 1-9)  
• It gives the developer an opportunity to strategically target “low density hillside development” (NELA Community Plan; pp 1-10)” solely for profit. 
• The developer is leveraging prefabricated modular in Los Angeles as hillside infill that will only increase developer profits.  
• It promotes the disruption of and danger to the hillside’s “generally outdated infrastructure….” (NELA Community Plan, pp.1-9)
• It violates guidelines that oppose “Incompatibilities of land uses and scale of development that detract from established neighborhood or community character “(The NELA Community Plan; pp.1-8).
• It Increases density with no allowances for open spaces; and the resulting gentrification violates Eagle Rock’s “strong architectural heritage” of C. 1920-1960 homes. (NELA Community Plan; pp.1-3)

PLEASE SAY NO.