Page 4 - northlake_appeal_20180423

Jodie Sackett, County of Los Angeles
June 16, 2017
Page 2

In addition, it appears that you are improperly relying upon the adopted 1992 NorthLake Specific
Plan because you are adopting a Tentative Tract Map which is inconsistent with it, as can be
observed by comparing the map at Exhibit 4-1 with the one at Exhibit 3-5. For one thing, there
is now a school site in the middle of the area designated for industrial development (which is
also poor and dangerous planning). For another, Table 4-4's Land Use area Comparison makes
clear how much more dense the proposed Project is compared to the originally proposed and
approved Specific Plan. The "Existing NorthLake Specific Plan" involves 600.3 acres for 3,623
dwelling units (du's) versus a proposed 333.4 acres for 3150 du's. The original plan was for
6.04 du's per acre on average and this plan is for 9.45 du's per acre. Such development is not
within the "concept[]" of the original Specific Plan, and is effectively an amendment. As a third
example, Exhibit 4-9 regarding planned sewer and wastewater utilities, is nothing like what is
depicted in Specific Plan Exhibit 11-10, the "Conceptual Wastewater Plan." The Conceptual
Wastewater Plan is not adequate for a Specific Plan under Government Code§ 65451(a)(2),
which provides that a specific plan shall include a text and a diagram or diagrams which specify
all of the following in detail: "(2) The proposed distribution, location, and extent and intensity
of major components of public and private transportation, sewage, water, drainage, solid waste
disposal, energy and other essential facilities proposed to be located within the area covered by
the plan and needed to support land uses described in the plan." And you are effectively
amending it. See also Gov. Code § 65453(a), "A specific plan shall be prepared, adopted and
amended in the same manner as a general plan, except that a specific plan may be adopted by
resolution or ordinance and may be amended as often as deemed necessary by the legislative
body." You are required to amend the Specific Plan here. Because you haven't done that, you
have failed to comply with the notice provisions under Gov. Code §§ 65090, 65355, 65453(a)
and 65867 and you have failed to provide for a public opportunity to respond under Gov. Code
§§ 65033 and 65094. See Rialto Citizens for Responsible Growth v. City of Rialto (2012) 208
Cal. App. 4th 899, 909.

The sewage system you depict in Exhibit 4-9 is inconsistent even with Option 1 of the
"Conceptual Wastewater Plan" in Specific Plan Exhibit 11-10 because the sewer trunk line runs
from NorthLake Blvd. whereas it runs from NorthLake Blvd. to Ridge Line Road and then south
in Exhibit 4-9 (to the extent anything can be discerned from the low-resolution drawing
provided).

At page 4-7 you contend that the Hillside Management Area ordinance does not apply because
the Specific Plan was previously entitled. We disagree because you are effectively amending the
Specific Plan.

Additionally, you state that the Phase 2 area of the site is planned for 35 large lot parcels of 20
acres or more for "future lease and finance purposes." Again, this is not in keeping with the
Specific Plan, which calls for development into single family homes. You specified 1, 176 such
homes for Phase 2.