It's not our responsibility, therefore our actions will have no impact.
That's essentially the conclusion of the Draft Environmental Impact Report (EIC) released by Metropolitan Water District this week on the construction of the Jensen Solids Handling Facility Project, which will result in the closure of the Balboa Youth Sports Complex baseball and soccer fields before the end of 2010.
The report concludes that "There are no impacts to recreation resulting from this project" because "Providing park and recreational facilities for local communities in the City of Los Angeles is not the financial or institutional responsibility of Metropolitan and is not a required or feasible mitigation for Metropolitan for this project."
Although the report acknowledges that "loss of the recreational and social opportunities provided by the ball fields due to expiration of the lease would result in a significant inconvenience to residents through the loss of recreational opportunities," it goes on to specify that "CEQA does not require lead agencies to assume that a lack of capacity for each type of recreational activity (e.g., baseball fields, soccer fields) in the immediate area is, in and of itself, a significant adverse impact on the physical environment caused by a particular project."
Translation: Your recreation areas are going away, but we're not legally required to see that as a problem.
The inscrutable doublespeak of MWD's report seems to come to two opposite conclusions: closure of the ballfields will have an impact, and yet it won't.
Section 3.14.3 of the report says, "In determining whether the proposed project at issue would have a significant adverse impact on recreational facilities, the analysis in this EIR considers the non-residential nature of the proposed project and the fact that no additional residents or employees would move to the area as a result." This narrowly-focused conclusion, that because the project won't bring new people to the area, recreation won't be impacted, clearly overlooks the impact on the area's existing residents. Yet shortly afterwards, section 3.14.6 acknowledges one such impact, saying "If LADRP (Los Angeles Department of Recreation and Parks) chooses not to offset the loss in recreational opportunities from expiration of the lease... residents could be inconvenienced by having to drive to other facilities and may face more crowded conditions once they arrive." But long drives and overcrowding don't count as problems for MWD; again they conclude that "Such inconveniences... do not result in reasonably foreseeable significant impacts of the proposed project on recreation."
Translation: Not our fault = zero impact.
It's the fault of Recreation and Parks, MWD concludes, and they certainly have a point. MWD's report reminds us that "As identified within the lease, the ball fields and related facilities were never intended to be permanent. The property subject to the lease was also never meant to be considered a public neighborhood or community park." Lease terms and intentions aside, however, no one should be surprised that when a piece of land is used as a community park for close to twenty years, people begin to consider it a community park.
Entering into a temporary agreement and then doing nothing but hoping that it would eventually become permanent, as it seems was the Recreation Department's strategy, didn't work, and in its own circumlocutory style, the report seems to mildly chastise LADRP for its inaction in finding a suitable replacement property—especially since they've had since 1991 to do it. The resultant crisis has left locals scrambling to stall and come up with alternatives, the most likely of which at this time is relocating the fields to Sylmar.
In places, the report even takes on a somewhat defensive tone: "It is not unreasonable for Metropolitan to presume LADRP will comply with the lease terms and that the land would be restored and improvements removed as required therein."
Translation: We're not the bad guys here!
They're right; it's not unreasonable for MWD to assume that recreation is the responsibility of the Department of Recreation. "Ensuring the provision of adequate types and numbers of public recreational resources within a particular community is within the purview of LADRP, not Metropolitan, whose primary purpose is water treatment and conveyance," the report dryly and frequently reminds readers. That's true, but that's not enough to clear MWD's skirts of the attendant PR nightmare, which this report does zippo to remedy. One of the most striking attributes of this EIR that stands out to layperson reader is its total lack of holistic view; MWD's report is written from the assumption that it operates in a strictly compartmentalized world, in which any problem that doesn't fall under the assigned responsibilities of one's own department simply doesn't exist as a problem. And especially when coming from a publicly owned utility, such we-live-in-a-vacuum conclusions come off as inappropriate, or at least deeply tone-deaf. One might expect this sort of behavior from a strictly profit driven, investor-owned corporation, but the aloof isolationist pose seems garish when coming from a cooperative entity created by the California legislature.
Ultimately, the report comes to a self-serving, head-scratcher of a conclusion: that the removal of a recreation space used by thousands will have no significant impact on recreation, and, simultaneously, this impact—which does not exist—is the responsibility of another agency.
What puzzles me is this: why is MWD required to consider the impact of this project, and to create an environmental impact report that includes a section on recreational impacts, if such impacts, as the report concludes, aren't their job to worry about? And would an EIR commissioned by another agency, or created by an independent entity with a less departmentalized, more inclusive point of view have arrived at the same conclusions?
Expanding on the idea of holistic inclusiveness, it's reasonable to conclude that the community of Sylmar will most likely benefit from the addition of a recreation area. But ensuring the provision of adequate types and numbers of public recreational resources within the Sylmar community is not within the purview of GigaGranadaHills, whose primary purpose is edification of the Granada Hills community. Considering park and recreational facilities for local communities outside the town of Granada Hills is not the financial or institutional responsibility of GigaGranadaHills, and is not a required or feasible mitigation for GigaGranadaHills for this project.
Read the full report here
The Sludge Report: The End Is Nigh For Balboa Boulevard Youth Sports Complex Location