Ann Larson
Community Development Department
City of Laguna Beach
505 Forest Avenue
Laguna Beach, CA 92651

Dear Mrs. Larson,

Village Laguna representatives have reviewed the draft EIR for the Village Entrance project in detail and offer our comments below.  Overall, we find the document a competent effort. However, it suffers for a lack of perspective on the dilemma Laguna Beach is facing in deciding on a Village Entrance project.  This project is serving as a forum for the renewal of our community’s priorities. 

Shall we change radically from the small art-colony village to a mall-like center focused on the demands of the automobile and parking—with an overwhelmingly large parking garage?  Or should we go forward in our own artistic and environmentally oriented way to set our sights on what we want—a parklike entrance to our town, an acknowledgment of our devotion to Laguna’s canyon and landscape, a fitting counterpart to Main Beach Park at the other side of our downtown area?

The EIR presents us with the information that, together with the parking needs analysis and the feasibility studies, should plainly set us on the latter course. 

This is the community that saved Main Beach Park from a convention center.  This is the community that rejected high-rise construction and limited building heights to thirty-six feet.  This is the community that created the Laguna Greenbelt.

We would be well advised to look at the Village Entrance alternatives from a historical perspective, in relation to the expressed preservation goals of our community.

Our comments, organized by page number in the document, on the draft environmental impact report are as follows:

I: In the table of contents, Chapter IV.J isn’t listed.

I-8: The summary of the proposed project neglects to explain the context of the project and the overall goals, which, as we understand them, are
•  to provide an attractive entrance to downtown Laguna Beach.
•  to provide a park linkage between the festivals area and downtown.
•  to acknowledge the significance of the natural canyon and Laguna Creek by
   restoring its natural setting as much as possible.
•  to provide parking for city, downtown, and festivals use.

III-2: Here the Village Entrance Park is described only as “a pedestrian-oriented area” and “a public area . . . with an undulating park-like landscape.” Why the reluctance to identify the area between the channel and Broadway/Laguna Canyon Road as a park?

III-12: The “Creekwalk Park” is not to be located in the area “where the Lumberyard Parking lot currently exists.” Most of it is proposed to be between the creek and Broadway/Laguna Canyon Road.

III-14: This diagram includes callouts of features of the southeast corner of Broadway and Forest, but the legend doesn’t identify them.

III-32: Here again, the project objectives should begin with the overall goals outlined above and identify the area between the channel and Broadway/Laguna Canyon Road as a park.

III-32: “580 parking spaces” seems to be left over from the previous draft.

III-33: Now that the Corporate Yard has been moved to the ACT V lot, it’s unclear why the structure still contains so many City maintenance and storage uses. At the same time, the project includes other City uses (employee restrooms, lockers, meeting room, offices) that do not appear on this list of objectives and whose impact is not considered in the document. Would these uses be better housed elsewhere?

IV.A-3: The “Aesthetics” section downplays the aesthetic importance of the site.  It states, “The Project site is located within the viewing corridor of Laguna Canyon Road, also known as State Route 133, which is neither eligible nor and officially designated State scenic highway.”  Whether or not the road is eligible for listing as a state scenic highway, it is listed by both the County and the City as a scenic highway (see the Landscape and Scenic Highways Resource Document).  Our City’s whole reason for being is its beauty and aesthetics. This is what brought our first artists here and continues to draw crowds of visitors every year.  It is a mistake to assume that a massive five-level parking structure at our entrance will  have no effect on the aesthetics, image, and ambiance of our city. A substantial adverse impact on the view of the canyon and Mystic Hills is evident in the simulations of Figures IV. B-7 and B-8. 

IV.A-19: Here the language should be updated to include the new traffic signal at the Festival Grounds.

IV.A-20: The conclusion that the Project would not result in inadequate emergency access seems to overlook the impact of a mass exodus from the structure in the event of an emergency that occurs when the structure is fully occupied.

IV.B-4: Here again, no information is provided regarding the scenic nature of the canyon context.  In addition to the unsightly parking lots, storage areas, etc., that the project is intended to correct, there is a scenic setting of steep hills, outcrops, and native vegetation that is not mentioned.  The statement “Although the majority of the site is developed and disturbed, several native trees and mature stands of eucalyptus trees are located throughout portions of the Project site” is inadequate.  The locations and descriptions of the existing trees should be documented and the evaluations should note which of the alternatives retains which of those trees.

In addition, the evaluation neglects to describe the view over the Lumberyard parking lot, through the mature grove of eucalyptus trees to the rusty sheds and their roofs, beautifully embellished with climbing morning glories.  This view is a reminder of old Laguna and should be acknowledged and retained where possible.

IV.B-9:  In the discussion of the Lumberyard Lot the view of morning glories and rusty sheds should be highlighted (see above).

IV.B-9: The assertion that the Lumberyard lot operates at 75% capacity most of the year is the only mention of parking supply and demand in the document. The results of the 2008 parking study conducted by Walker Parking Consultants should be incorporated into the document somewhere, as earlier recommended by the Planning Commission, and included in the evaluation of alternatives.

IV.D-22: The land in the canyon was acquired in 1878, not 1978.

IV.D-29: The third bullet point seems to be missing something that would make it intelligible.

IV.F-11: The discussion of hazards omits the impacts of damage to on-site sewage facilities in the course of construction or subsequently.

IV.H-29. The massive size of the proposed structure in relation to the pattern of downtown development, characterized by small buildings on small lots and pedestrian scale, is apparent in the diagrams and the simulations and should be recognized as a violation of Land Use Element policy 11A, “Encourage building design which minimizes the scale, bulk, and obtrusiveness of development, and require compatibility with the surrounding scale and type of development.”

IV.H-36: The construction of the parking structure into a 45% slope appears to be a violation of Open Space Element 14A, “Require construction and grading to be concentrated on slopes of 30% or less.”

IV.J-35: It’s unclear how the intersection at Broadway and Forest can be widened to accommodate a second left-turn lane, given that Forest has only one lane in each direction for most of its length. The traffic impact of the project and all its alternatives requires this addition as mitigation, and we need to be convinced that there is room for it and that it doesn’t have its own impacts that haven’t been addressed.

V-1: The discussion of possible growth-inducing impacts overlooks the effects of  the building of a large parking structure on downtown commercial uses. The Laguna Playhouse is contemplating renting its facilities to other community groups between productions; the Festival of Arts plans to provide year-round events; the Colony building is being remodeled and can be expected to produce more traffic in its new form;  and there may be development at the former Club Post Nuclear and adjacent properties owned by Mark Orgill. The provision of several hundred new parking spaces is likely to encourage businesses in Laguna Canyon to expand with the expectation of using the new City parking spaces to meet their requirements. The City, for its part, may welcome these proposals because it needs to pay for the parking structure and increased demand will facilitate that. This combination of interests could set up an almost automatic approval process for growth in the canyon and the downtown.

VI-2: The potentially significant project impacts listed do not include the aesthetic impacts. As pointed out earlier, the large parking garage will have substantial adverse impact on the aesthetics of the site and views of the canyon and Mystic Hills and on the City’s small-scale village character.

VI-5: The list of alternatives should include a much smaller garage, a “break-even” option with a smaller footprint that simply replaces the required parking displaced by the new park.

VI-28: The discussion of Alternative D maintains that the aesthetic impact would be the same as for Alternatives A, B, and C, when in fact the structure of Alternative D is set back farther from the creek, which should reduce the impact as seen from Forest and Broadway, and there is the possibility that some of the existing trees can be saved and incorporated into the proposed on-grade parking lot. This alternative also differs from the others in including on-site queuing for vehicles.

VI-37: The discussion of Alternative E neglects to mention the possible aesthetic impact of the 28 apartments that have been added to the design and fails to explain where they would be on the structure and what they would look like.

VI-41: Also in connection with Alternative E, it’s important to clarify that residential use is permitted in the Civic Arts District only if it is arts-related student housing or affordable artist’s live-work (see Chapter IV.H-17, “Building Height”) and that a judgment that other housing is “no more obnoxious” than those permitted uses is not a foregone conclusion.

VI-43: The chart has a + for Alternative E “Public Services and Recreation” but the text says that the additional impact is balanced by developer fees.

VI [mistakenly numbered 6?]-47: These paragraphs describe Alternative C as an environmentally superior alternative because it has a smaller (three-level) parking garage.  Yet the report discounts this alternative because it “would not meet all of the objectives of the proposed project” (that is, would not have the maximum number of parking spaces originally listed). A project with “break-even” parking would also require an adjustment to the number of parking spaces to be included.  However, these smaller projects should not be discounted, since the purpose of an EIR is to provide decision-making information that may cause some of the original project criteria to be reconsidered.

VI [6]-47: Here again, the reference to “minimum 580 spaces” seems to be left over from the previous version.

Thank you for inviting our input.

Sincerely,

Barbara Metzger

for the Village Laguna EIR Committee