Open Letter Opposing Eldercare Project in Highland's Coastal Parklands Area

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To the Honorable California Coastal Commissioners:

We call on you to grant the Appeals in CCC Post Cert. Case No. 5-PPL-18-0034 regarding the proposed Project at 1525 Palisades Dr., Pacific Palisades, CA 90272, and overturn the City of Los Angeles Decision to approve a Coastal Development Permit (CDP) for the Project. The Project violates numerous provisions of the Coastal Act (“Act”), and the City ignored the Regional Interpretive Guidelines (“RIGS”) as well as the City’s own Brentwood-Pacific Palisades Community Plan.

The Project is a 4-story, 45 ft. high, residential Eldercare Facility (Assisted Living/Dementia Care) with 96 residents. Although characterized as a commercial development, the Project actually consists of 82 long-term residential dwelling units and its 4-story mass and scale is out of character with the surrounding neighborhood of predominantly 2-story structures.

The Project is located in a highly scenic area bordering Santa Ynez Canyon City Park and within 200 ft. from Topanga State Park, both recreational areas within the Coastal Zone. The Project’s site can be seen from numerous, popular hiking trails and it would block public scenic views from Palisades Drive and from Vereda De La Montura and Michael Lane, which are local streets.

The City incorrectly concluded that only ocean views are protected by the Coastal Act and that other coastal resources, such as views of coastal hills/mountains or views from hiking trails, are not protected. The City refused to consider and evaluate scenic public views from nearby trails in the adjacent parkland solely because the Project is 2½ miles from the ocean.

The Project is in a Very High Fire Hazard Severity Zone and will be required to create fire buffer zones next to Santa Ynez Canyon Park. This fire suppression will destroy the natural habitat surrounding the project, further exposing the Project structure to nearby parkland and trails.

The Project failed to specify the number of visitors, including employees, independent medical care providers, delivery vehicles and other visitors to this 24/7, facility with 3 employee shifts. Without this information, any traffic projections were seriously inadequate. There is no public transportation within 2 miles, so all persons must drive to and from the Project. There is no separate parking for the nearby parks and overflow employees, visitors, etc. to the Project will park on the adjacent streets and interfere with park access. Therefore, a Substantial Issue exists regarding public access to nearby parkland. There was no traffic study and therefore, the City had insufficient information to conclude that there will be no significant effects relating to traffic, parking and park access.

The City simply acknowledged the existence of the Regional Interpretive Guidelines and then without further analysis, concluded that the Project complied with them. The City made no effort to adequately review, analyze and consider the Regional Interpretive Guidelines.

The City does not have a certified Local Coastal Program (LCP). The Project will have a precedential effect on the City's interpretation of any future LCP and will prejudice the ability of the City to prepare an LCP that is in conformity with the Coastal Act. The Commission should find the existence of Substantial Issue regarding the Project, grant the Appeals and deny a Coastal Development Permit to the proposed Project.

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