Monochrome photograph of hands and a laptop

The City of Long Beach has commenced the CEQA process for a 20 acre parcel of land at 712 Baker Street. It should be a park, but it’s currently on its way to being a 227-building gated residential development. There will be several opportunities for public comment, the first closes on Monday April 12, 2021 at 5 pm.

Your comments need to be sent to:
Amy Harbin
Planner, Development Services Department
City of Long Beach
And I recommend CCing Mayor Robert Garcia as well as each councilmember (the formula for those emails is – sub the x for the district numbers 1-9) or here’s a helpful list:

Useful links:
The Notice of Preparation for 712 Baker Street
An abundance of resources and information from the Riverpark Coalition
A petition to sign
Shocking stats on park inequities in Long Beach
The Lower LA River Revitalization Plan
More on 3701 N Pacific Place
More on 712 Baker Street

You’re welcome to reuse anything from my letter. The important thing is that you send a letter, by Monday April 12.

Amy Harbin
Planner, Development Services Department
City of Long Beach

12 April 2021

Dear Ms Harbin,

712 Baker Street Initial Study for CEQA Process

I am writing to comment on the Initial study for CEQA on the 712 Baker Street parcel, also known as the Long Beach RiverPark Residential Project.

I am an independent scholar and the founder/curator of Los Angeles River X.[1] I have over a decade of international research and community engagement expertise in river landscapes and their complex interrelationships with surrounding communities, particularly the Los Angeles River. On that basis, I make the following comments on the Initial Study. I look forward to seeing them addressed in the forthcoming Draft EIR.

Adverse effect on habitat

Considering the substantially altered state of the Los Angeles River and the commitments made at city, regional, county, and national levels regarding its revitalization, it is clear that the EIR will have to robustly consider how the proposed development will ‘have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species’ (p. 23) and also the dire impact of eliminating any possibility that the 20 acre site could immediately or in the future become public open space. There are at least 124 sensitive species on the site and in the immediate area, 23 of those threatened or endangered (p. 26). Safe habitat is essential for these threatened, endangered and otherwise at-risk species. To say that ‘the Project Site consists of disturbed vacant land surrounded by existing residential development and urban infrastructure’ (p. 27) hides the ecologically significant impact on the entire watershed of protecting this site from development. The Letter from the Department of Fish and Wildlife has particular points which I look forward to seeing addressed in the EIR, including a recommendation that replanting be at a 3:1 ratio for removed native trees. It would be a mistake to conceptualize empty lots as devoid of ecological values or habitat, as evidenced by the finding of Burrowing Owls (Athene cuniculara) – a California Species of Special Concern – in empty lots a mile north and immediately adjacent to the Project site. The removal of ‘some old foundations, roads, and pipes [that] are still present on the site’ could well destroy habitat for owls.[2]

I note an error on p. 75 in relation to habitat and impacts on plant and animal communities. It is marked as both ‘Less Than Significant Impact with Mitigation Incorporated’ and ‘Potentially Significant Impact’. I trust the EIR will treat this as the latter.

Air quality

As well as considering the air quality impacts of the proposed development (p. 20), the EIR process must adequately consider the ethical and public health implications of knowingly moving several hundred new residents into an area known to have catastrophically poor air quality already. Locating a large and dense residential development in an area known as the Diesel Death Zone, with residents at high risk of adverse health outcomes including cancer, asthma, and diabetes, needs rigorous environmental and ethical appraisal.

Cumulative Impacts

When the EIR considers ‘impacts that are individually limited, but cumulatively considerable’ (p. 75) please ensure that the following themes are fully elucidated: equestrian culture, public open space, environmental injustice, housing affordability, air quality, and traffic.


The Initial Study cites the proposed density of 14.6 dwelling units/acre (p. 9) but does not compare this to the existing density in the immediate neighborhood, or of West Long Beach. For the Draft EIR to adequately scope the impact, these comparisons will need to be included.


The Initial Study indicates that the project site is not within a risk zone for a 100-year or a 500-year flood (p. 50). I understand that FEMA have been remapping stretches of the LA River to upwardly revise the flood risks. The EIR will need to investigate whether there have been or are likely to be forthcoming changes to the thirteen-year-old mapping that is currently published by FEMA for the area.

The channelization of the Los Angeles River was made necessary by developers building carelessly in the flood plain, and it seems unfortunate to repeat this behavior some 90 years on, as this development seeks to do. Surely we have learned something since 1938? As a historian, I can’t help but think of how history has an ominous way of repeating itself, and I trust that the City of Long Beach won’t put people in harm’s way, as in the first decades of the twentieth century when the flood ravaged river destroyed residential, commercial, and industrial sites that had been the wrong developments in the wrong places.

Further, I understand there has been litigation in recent years relating to flooding in the area, and this should be investigated and referenced in the EIR.

Groundwater recharge

The assertion that there will be a Less Than Significant Impact in terms of ‘groundwater supplies or interfere[nce] with groundwater recharge’ (p. 48) is questionable and needs attention in the draft EIR. Likewise the document asserts that the creation or contribution of runoff water would be ‘less than significant’ (p. 52).

Is it true that in such a densely built development that the site is ‘38 percent pervious’ (p. 48), even though it is entirely dominated by streets and buildings?

The movement of water, and its biofiltration, appears not to be for aquifer recharge but rather expulsion from the site via the stormwater system into the LA River and out to the ocean. This wastage of water is not sensible nor justifiable in our drought-prone climate.

Designing homes and the clubhouse area to have rainwater capture and/or greywater reuse was not mentioned anywhere in the Initial Study. It must be considered in the EIR and in the City’s deliberations. In light of water scarcity in the region, which is only increasing with climate change, urban and architectural design can and must do their part to lessen our water footprint.

I am glad to see sufficiency of ‘water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years’ categorized as a potentially significant impact (p. 71) and I trust that groundwater recharge, rainwater capture and/or greywater reuse will be adequately incorporated into the project design.

Historic significance

The Initial Study comments that ‘according to the Long Beach General Plan Historic Preservation Element, the Project Site does not contain historic resources and is not in a historic district’ (p. 16, also p. 29) and yet it has a rich and materially documented equestrian history that spans back to the Spanish and the Rancho periods in our history, and remains as living history every day in Long Beach. Also, as noted, Native American historical significance must be robustly investigated and protected, through the EIR process.

Horse Overlay District

The proposed removal of the Horse Overlay District (p. 13) – a distinctive and essential element of Long Beach’s urban fabric – needs extensive attention in the draft EIR. My strong opinion is that the Horse Overlay must not be removed. My request is that the draft EIR fully address the following:

  • the history of Horse Overlays in Long Beach, including the EIR that was part of the overlay establishment in the 1970s, and also any relevant legal proceedings
  • how many of the original six overlays/equestrian communities remain intact and what the cumulative impacts would be to removing this one, in terms of the land use character of Long Beach, and the protection of Long Beach’s living equestrian history
  • the density allowed under a Horse Overlay compared to the density of the proposed project (I understand it is approximately 4 homes per acre, but I have not seen documentation of this)
  • effects of the removal of the Overlay, and the construction of the housing development on both the immediate equestrian community with open space and the trail, as well as linear connectivity for horses and their riders between Long Beach equestrian districts, and indeed into the San Gabriel River, the Rio Hondo, and north to Atwater and Burbank equestrian neighborhoods

Land Use

It’s not just the Horse Overlay District under threat. As recently as late 2019 in the City’s 2040 General Plan, the land use designation for this area was affirmed by the City as Founding and Contemporary Neighborhood (FCN) and Open Space (OS)  (p. 4). The current zoning from Commercial Storage (CS) and Single‐Family Residential Standard Lot (R‐1‐N) would be changed to residential Planned Unit Development (RP) and Council would waive height restrictions. Other approvals forecast in the Initial Study include Vesting Tentative Tract Map and a Street Vacation – meaning the complete or partial abandonment or termination of the public right to use a street, highway, or public service easement – to enable the development to proceed

Given all of this, I challenge the appropriateness of the Less Than Significant Impact rating given regarding any ‘conflict with any land use plan’ (p. 55). I would also ask that the consultants ensure plain English language explanations of technical terms such as Vesting Tentative Tract Map and Street Vacation so that lay readers like me can be fully aware of the meaning and implications.

The City made a promise in an undated recent document that FCN constitutes ‘more than 34 percent of the City’s land area and will not be changed‘ [emphasis added].[3] The Initial Study suggests the City would be breaking this promise by approving the proposed development.

Park Space

Detailed analysis about access to parkland open space will be important in the EIR, and I ask the preparers to ensure that analysis is more nuanced than at a whole-of-City level. West Long Beach is substantially underserved in terms of open space, and overserved in terms of environmental injustices. For this reason, please ensure that the EIR analysis addresses West Long Beach in particular as well as referencing city wide statistics. Can the EIR please calculate the impact of 624 new residents on West Long Beach’s current park ratio, which I believe is 1 acre per thousand residents?

Given the open space deficits that exist in West Long Beach, the addition of 624 residents and the provision of 5‐acres of recreational open space (p. 66) is insufficient.

The EIR needs to systematically document past promises made in planning documents and elsewhere about this land parcel and others in terms of creating public open nature space .

Plant palette

The planting list for the condominium area does not indicate any intention of the developer to use a native plant palette. Instead it specifies Tipu Tree, Purple Orchid Tree, Magnolia, Marina Arbutus, Australian Wouldow, Brisbane Box, New Zealand Christmas Tree, Chanticleer Pear, Crape Myrtle, and Majestic Beauty (p. 13). The developer needs to design with a commitment to native plants, at a minimum adhering to the standards in the Draft Los Angeles River Master Plan of at least 85% being native to the LA River watershed and no more than 15% being non-native, non-invasive plants.

Population growth

This project would by definition ‘induce substantial unplanned population growth in an area, directly (for example, by proposing new homes and businesses)’ and yet this is ascribed a ‘Less Than Significant Impact’ rating (p. 60). It will not meet the City’s own Founding and Contemporary Neighborhood (FCN) General Plan Land Use designation per the City’s recent 2040 General Plan.

It is too blunt, some may even say disingenuous, to use a city-wide thirty-year growth projection to make the magnitude of this development look smaller than it really is.

Ascribing this point a ‘Less Than Significant Impact’ appears to be in error and needs to be corrected.

Public Engagement

I ask the City and the consultants to all they can to facilitate engagement of the general public with the EIR process, accommodating linguistic diversity, socioeconomic status, education, as well as cultural and social capital. Environmental injustices disproportionally impact disadvantaged, minority, and marginalized communities and the City has a responsibility to address this in the current CEQA process, and in general. Outreach initiatives should be documented in the EIR.

Scenic vista

I disagree with the assertion that the development will have a less than significant impact on a scenic vista (p. 15). The River is designated as ‘a scenic route as it provides a viewshed that is worthy of protection and enhancement’ (p. 16) and no convincing argument is made that the addition of 227 buildings in a jumble of high-density Spanish Colonial, Italianate, and Santa Barbara architectural styles ‘would not substantially alter the existing views along the Los Angeles River’ (p. 16). The Los Angeles River is internationally and locally iconic, and the viewshed needs not only to be protected but also enhanced.


I note that the Department of Transportation has stated several strong concerns about the development in terms of adverse traffic outcomes.[4] I share these concerns and look forward to seeing them addressed in the EIR. The addition of at least 511 vehicles (p. 9) to the neighborhood needs to be addressed and mitigated.

Urban Heat Island

The density and character of the development looks as if it will contribute substantially to urban warming, an increasing problem in the face of climate change. This needs to be addressed in the EIR and mitigated in the site design.

In conclusion, the highly developed/degraded nature of a site is often used by EIR preparers to craft an illusion of the development being unproblematic because it is proposed on land already substantially altered, a brownfield not worthy of environmental protections. This is a paradigm that is philosophically and practically unviable, particularly in hyper urban landscapes such as those along the Los Angeles River. The character, scale, and function of the proposed development is vastly unsuitable for the site, particularly in light of the draft Los Angeles River Master Plan, the Lower LA River Revitalization Plan, and RiverLink.

When the EIR proposes alternatives, as per CEQA Guidelines, I hope that an environmentally superior alternative to the project or its location will include the possibility of the land parcel being protected as public green space, and that the developer may be encouraged to build in a more suitable manner on a more suitable site. The protection of this land parcel as open green space would be game-changing for Long Beach, and the entire river. I trust the City and the CEQA process to protect the river, the 712 Baker Street parcel, and the adjacent community.

Best regards,
Tilly Hinton, PhD

Cc.               Mayor of Long Beach
Long Beach Councilmembers



  1. Mark Kenyon

    Thank you Tilly!!
    I will work on a letter for Monday! But first a bit of reading. All your prep will help immensely.


  2. This is so thorough and detailed. As a Board Member of Riverpark Coalition, I can not begin to tell you how fortunate we are to have connected with you. Thank you!

Comments are closed.