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BLUM I COLLINS LLP
Aon Center
707 Wilshire Boulevard
Suite 4880
Los Angeles, California
90017
213.572.0400 phone
213.572.0401 fax
June 16, 2017

Jodie Sackett VIA FIRST CLASS MAIL & EMAIL
Department of Regional Planning
County of Los Angeles
320 West Temple Street, Rm. 1362
Los Angeles, CA 90012
j sackett@planning.lacounty.gov

Re: Northlake Specific Plan DSEIR Comments, State Clearinghouse No. 2015031080

Dear Mr. Sackett and the County of Los Angeles:

On behalf of the Golden State Environmental & Social Justice Alliance, a California Social
Purpose Corporation, Entity #C4017878, this is to submit comments under the California
Environmental Quality Act ("CEQA") on the Draft Supplemental Environmental Impact Report
("DSEIR") for the Northlake or Northlake Hills Specific Plan project ("the Project"). These
comments are in addition to those submitted herewith from biologist Shawn Smallwood relating
to biological resources. Please include them as part of the administrative record on this project.

Our comments appear in the order in which they arise in response to the DEIR.

Project Description

Your Project Description in the Executive Summary is one of the least clear we have ever seen.

At 1-2, the County asserts that "Collectively, the Project is defined as the entire 1,330 acre
Specific Plan site including the 737-acre VTTM No. 073336 area and associated External Map
improvements (Phase 1 ), and the remaining property for Phase 2 to be developed at a future
time." We have no idea what this means. Are you evaluating impacts from the development of
Phase 2 or not? We can't determine this from either the Executive Summary or Chapter 4,
"Project Description." If you are not evaluating the impacts of Phase 2 of the development, this
violates CEQA's requirement that you assess "the whole of an action," and constitutes improper
segmentation. Chapter 4 seems to suggest that you evaluated biological impacts from
development of the entire parcel, but not necessarily the air quality, GHG or traffic impacts.
This omission would be improper, as it is clear that you intend to develop the entire parcel, and it
seems that you actually intend to grade the Phase 2 site as well.