April 30th, 2018
​Chinatown Community for Equitable Development
418 Bamboo Lane, Suite A
Los Angeles, CA 90012

Johnny Le
City of Los Angeles Department of City Planning
200 North Spring Street, Room 750
​Los Angeles, CA 90012
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Written Comment for College Station Draft EIR

Chinatown Community for Equitable Development (CCED) is a multi-ethnic and intergenerational organization based in Chinatown Los Angeles. Started in 2012, we have been organizing with low-income and immigrant communities for tenant rights, quality affordable housing, and socioeconomic equity. Our members include residents of Chinatown and Lincoln Heights, particularly low-income renters and workers that make up the majority of our community. 
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We are writing today in response to the Draft Environmental Report (“Draft EIR”) for College Station. All development proposals and city planning processes in Chinatown should be culturally appropriate and attentive to the community’s social, economic, and cultural needs. After reviewing the Draft EIR, we strongly oppose this development for the following reasons:

College Station will erode the cultural and historical fabric of the neighborhood.

Chinatown stands proud of its cultural heritage, with businesses and community organizations reflecting the demographic makeup of the residents they represent. The neighborhood is also home to the Mid Autumn Moon festival and the Chinese New Year Parade which draws over 150,000 participants annually. When Angelenos come to Chinatown, they do not merely want to walk through empty facades of locally owned stores that have been pushed out. They want to be a part of the diverse, rich community of residents and store owners who have their history rooted in the neighborhood in which they live.
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By not building any affordable housing and culturally competent retail and services into College Station, the project (and many like this one) guarantees that the history of our neighborhood will be destroyed in due time. We urgently oppose all contributions to the cultural erosion of Chinatown. This project’s potential impacts on direct and indirect displacement of commercial and residential residents should be analyzed and addressed in the Environmental Impact Report. The Draft EIR fails to do so.

College Station seeks exemption from existing obligations to build affordable housing, failing to meet the needs of the community.

Existing planning code requires a percentage of new units be set aside as below market rate housing for low and moderate income households.[1] The developer is seeking amendments whose sole purpose is to exempt the Project from having to include affordable units. By approving this planning case, the city is granting the developer a blank check to build with no regard to either environmental impact or existing requirements for developers to build affordable housing.
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Seeking this amendment completely disregards our working-class community’s housing demands. In 2016, a significant number of CCED members attended the College Station’s Public Scoping meeting and voiced the need for truly affordable housing with the College Station’s city planner and other staff at hand. Many residents and community members also sent in written comments in both Chinese and English to the assigned city planner Sarah Molina Pearson in response to the Initial Study. We explicitly and collectively named issues in regards to affordability, accessibility, and environmental concerns that should be examined in the Environmental Impact Report. This Draft EIR fails to adequately and critically address the issues that residents have and continue to raise.

The latest regional housing assessment conducted by the Southern California Association of Governments (SCAG) highlights the need for 46,590 new units affordable to very low, low, and moderate income households between 2014-2021.[2] This represents 57% of the overall projected need for new housing in Los Angeles. Of all new mixed-use developments built in Chinatown after 2013, astonishingly few units have been set aside as affordable.

To truly meet the neighborhood’s demands, 100% of units at College Station should be made available at low-income levels reflective of Chinatown’s residents and their median household income. The need for housing affordable to low income households and seniors is particularly acute in Chinatown. Median household income here is less than $19,000 per year. This is the second lowest of any neighborhood in Los Angeles. When Blossom Plaza opened in 2016, only 53 below market rate units were available. Several thousand qualified low-income households applied for these 53 units. This demand speaks to the Chinatown’s need for significantly more affordable housing, not market-rate housing.

In its application, the developer of College Station is asking for approval to build an all market-rate development. Per month rent for comparable units at Blossom Plaza and Jia start at around $1,981 per month ($23,772 per year), which is more than the total earnings of the median Chinatown resident. These developments also harm the entire surrounding community, as landlords look for ways to displace long time residents to attract the same demographic these new developments cater to.

Furthermore, the vacancy rates for market-rate high rises is high. In 2017, CoStar reported a vacancy rate of 12% in Downtown Los Angeles due to the surge in market-rate rental construction.[3] These properties are now offering free parking and months of free rent because they cannot fill their units. Many properties are now turning to AirBnb to generate income through their empty units. By not offering affordable units, College Station is contributing to the glut of (often empty) market-rate units while pushing out low-income residents who call Chinatown their home.

In addition to concerns about affordability, the proposed project as well as the five alternative proposals ignore the need for housing for families. The proposed project and five alternatives all prioritize developing studios and one-bedroom apartments, which make up the majority of the proposed units in each proposal. In a community where the average household size is 2.8 people,[4] these units do not meet the needs of the families who live in Chinatown. Instead, studios and one-bedroom apartments cater to single individuals and encourage overcrowding by families.

The statewide Housing Element Law requires cities to establish regional councils that assess current and projected housing needs across different income levels[5] and identify development patterns that are in alignment with statewide targets for ecologically sustainable development. This law requires cities to align planning and development policy with the findings of such regional councils, and serves as a way to allow cities to retain local control while holding them accountable to the needs of their residents.[6] College Station completely fails to adequately engage with working-class residents to ensure this project is driven by the community’s needs and vision.

The project does not help meet goals for reducing vehicle traffic and greenhouse gas emissions.

Existing state, local, and regional policy require the city to consider both the short term (during construction) as well as long term cumulative impacts a project would have on the local environment. These potential impacts include changes in growth patterns in the surrounding community (such as other developments and changes to the neighborhood/city overall). Generally, cumulative long term benefits should exceed short term harm resulting from construction.

The Draft EIR concludes that the project would have less than significant overall impacts because it is in “proximity to public transit,”, within a transit priority area, and would “contribute to sustainable development patterns” by likely reductions to vehicle miles travelled (VMT). The argument is that because the project is located near the Gold Line Chinatown Station, it would promote use of public transit in place of personal cars.

This line of reasoning appears sound, until the demographic characteristics of the typical Metro patron is considered. According to a fall 2017 survey conducted by LA Metro, the median income of Metro light rail riders is around $24,390 per year. We find the contention that a project with more parking spaces than units and yearly rent exceeding $20,000 per year would promote public transit usage highly suspect. The 770 proposed new units at College Station would be affordable only to a demographic unlikely to actually utilize public transit.

In fact, Metro Gold Line ridership has followed a downward trajectory, with the exception of the period immediately before and after the opening of the foothills extension from Pasadena to Azusa[7]. Despite hundreds of new market rate “Transit Oriented” units[8] built near Gold Line stations, there are fewer Gold Line riders today than in 2016.

Additionally, the College Station proposal includes 1,179 new parking stalls. The high number of parking units is antithetical to the goal of transit-oriented development — why offer so much parking if residents are expected to utilize the Gold Line? By proposing so many parking units, the proposal does nothing to encourage Metro ridership.

​The city needs to reconsider its assumption that building market rate housing near public transit would result in a net decrease in vehicle usage. Whether the number of hypothetical new public transit users living at these high rent complexes exceed the number of actual transit patrons displaced from nearby areas by rising rents is a question that warrants in-depth study.

The City has not considered alternatives that include affordable housing.

Before granting plan amendments and other approvals, the planning department must develop, assess and publish alternatives to the project proposed by the developer. At least one of these alternatives must be one that produces fewer environmental impacts aside from the “don’t build anything” alternative.[9]

​We believe that the lack of an alternative that includes affordable housing is a serious omission by the planning department. The benefits of an alternative that includes units affordable to the surrounding community as well as to actual users of public transit is sufficient to justify denying the current application from the developer.
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Until all of these issues above are addressed, CCED and working-class residents of the Chinatown community will not support the development of College Station.

Sincerely,
Chinatown Community for Equitable Development