July 23, 2021
Los Angeles City Council
200 N. Spring Street
Los Angeles, CA, 90012
Re: Case Nos. CEQA No. ENV-2020-151-CE; DIR-2020-149-TOC-HCA
Project Location: 715 S. Mariposa Avenue. (“the Project”)
Dear Los Angeles City Council:
On behalf of Coalition for an Equitable Westlake/Macarthur Park (“Coalition”), an unincorporated
association of long-time community residents, we are writing to object to the City’s CEQA
determination. A project qualifies for a Class 32 Categorical Exemption if it is developed on an infill site
and meets certain criteria. However, before a project can be determined to qualify for a categorical
CEQA exemption, exceptions to the exemption, such as cumulative impacts, must be considered. If an
exception to a categorical exemption applies, CEQA review in the form of an MND or EIR must be
conducted. CEQA Guidelines section 15355 states: “Cumulative impacts refer to two or more individual
effects which, when considered together, are considerable or which compound or increase other
environmental impacts.”
The City has a burden to provide substantial evidence, which must be based upon facts,
reasonable assumptions based on facts and expert opinion, rather than the City’s mere speculation, to
support its findings. CEQA Guidelines § 15384(a); Save Our Big Trees v. City of Santa Cruz (2015) 241
Cal. App. 4th 694, 711 (citing Muzzy Ranch Co. v. Solano County Airport Land Use Com. (2007) 41 Cal.
4th 372, 386). The City must demonstrate with substantial evidence that the Project would not result in
significant environmental impacts pursuant to CEQA Guidelines § 15332
Additionally, any environmental impacts based on pre-Covid levels of public transit ridership
that do not take into account declining public ridership, which is expected to further decline after Covid.
https://caltransit.org/news-publications/publications/transit-california/transit-california-archives/2019-
editions/may/ridership-study-revisited; https://www.latimes.com/opinion/story/2021-04-07/los-angeles-
public-transit-crisis
Below the Coalition submits a list of past projects, current projects and future projects spanning back
to January 1,2017 that contribute towards the cumulative impacts of the Project that must be considered. The
projects listed below are all within a 1-mile radius of the Project. Many have already been approved. The
area within a .05 mile radios is heavily populated and is a high pedestrian and car traffic area.
The projects are listed by the date the application was filed with City Planning, the address of the
development, the number of units being constructed, and the distance from The Project.
address of proposed projects