Monday, February 26, 2018

Rancho La Habra Draft EIR Comments

 After a few boring months, we finally have a development in La Habra worth commenting to the city on. As usual, the a draft EIR was developed which fails to see the huge amount of harm to the residents of California which housing restrictions have caused.

Here are the comments I submitted:

The draft environmental impact report for the Rancho La Habra Specific Plan largely fails to see the big picture of the environmental impact from development of this housing. The project is blamed for a great many problems which are either not environmental problems, or will not actually be impacted by this project. A more reasonable analysis of the impact of this project would find that the actual lowest environmental impact of this project could be obtained by dramatically increasing the density of housing development, perhaps to the level of other recent projects along Beach Boulevard.

The environmental impact report blames the project for increasing population and states that this is a significant unavoidable impact. The project will do no such thing. The people who will live in the development are already born and there is no reason to think that the project will lead to increased birth rates in the future. The project will not increase the population. It will only increase the number of those people who live in La Habra. The significant environmental question is, would the environmental impact of this population be reduced or increased if these people move to La Habra? The answer is a very clear reduction. If this project is not constructed these people will find housing elsewhere. This housing will almost certainly have a higher environmental impact than this development due to the mild climate, minimal disturbance of wildlife habitat and central location of this project which will reduce environmental impacts when compared to exurban developments in the inland empire. 

Elsewhere the EIR repeatedly mentions increases in traffic as an unavoidable environmental problem. This is quite simply not an environmental problem. The environmental problem is cars, not traffic. If there is an environmental impact relating to transit which should be considered it is from the fact that this development will never support decent public transportation. Were the density to be tripled or quadrupled, it would plausibly be a high enough density urban area to support reasonable public transit service. As it is, the development is simply too low density to ever support good public transit. Unlike increased traffic from this project, this is a serious environmental impact. Also, the design could reduce driving by providing easier walking access to neighboring businesses, making these distances as short as practical and removing gates which are likely to reduce the number of people who walk. 

Again greenhouse gas emissions are over-stated because of a failure to understand what would happen were this development is not constructed. These people will live somewhere. The average resident will certainly be closer to their worksite if this development is constructed, reducing miles driven. The average resident will certainly be using less heating and cooling if this development is constructed, again reducing energy use and greenhouse gas emissions.

None of the evaluated alternatives properly account of the reduced environmental impacts which could be realized by increasing density. The amount of preserved habitat, viability of public transit, walkability, total greenhouse gas emissions, and even total revenue to the developer could all be improved by reducing the amount of land developed while increasing the total number of housing units installed. This is a dramatically superior option to all six alternatives considered in the draft EIR.