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.