By Jorge Casuso

March 13, 2012 -- Attorneys for the Santa Monica Coalition for a Livable City (SMCLC) on Monday submitted a 26-page letter to City Planning officials outlining the group's objections to the Bergamot Village Transit Center Project.

The detailed comments, sent by the law firm Strumwasser & Woocher, came on the final day for the public to comment on the Draft Environmental Impact Report (DEIR) for the proposed 766,000-square-foot project at the former Papermate site on Olympic Boulevard and Stewart Street.

"SMCLC has serious concerns regarding the size of the proposed project -- which appears to be one of the largest in Santa Monica's history-- and its significant negative impacts in an already gridlocked area," attorney Beverly G. Palmer wrote in the letter, which included 88 pages of exhibits.

The proposed project "is simply too massive for the City's existing infrastructure," Palmer wrote, adding that the DEIR "fails to adequately analyze the proposed project's impacts on traffic, land use, hazardous waste (and) climate change."

City officials should wait to "adequately assess the proposed project's conformity with the currently-in-progress Bergamot Area Plan" before moving ahead with the draft EIR, the letter said.

The letter came on the day a press conference was held in front of City Hall by community and neighborhood leaders from Santa Monica, Brentwood, Pacific Palisades, West LA, Mar Vista and Venice to announce a new regional alliance formed to oppose the project.

The coalition and its allies urged the City to address the concerns expressed in the letter, calling for downsizing the project, which would sit across the street from a future Expo Line station, and placing it in the context of the larger area.

The letter expressed concerns about "the cumulative effect" of projects proposed or being developed in Santa Monica's old industrial district and the draft EIR's failure to "adequately assess the proposed project's conformity with the currently-in-progress Bergamot Area Plan."

Opposition to the Bergamot project has been growing since the City council voted 6 to 1 last August to direct staff to negotiate a development agreement with Texas developer Hines.

The vote came after Hines reduced the size of the project -- which includes creative space, retail, and residential units in five buildings standing five to seven stories tall -- from nearly one million square feet to the proposed 766,000 square feet.

The developer also added a new park and street, open spaces and walkways and varied the building heights and facades.

But the reduced project does not seem to have allayed the concerns of neighboring residents and community leaders around the Westside.

Last Wednesday, the Los Angeles City Council approved a motion asking Santa Monica to mitigate impacts at nine LA traffic intersections impacted by the project or scale down the "size and magnitude" of the development.

Last month, the 15-member board of the West LA Neighborhood Council unanimously voted to oppose the project.

Monday's letter from a law firm indicates that if the DEIR is certified and the project moves forward, opponents will likely be willing to go to court.

In an interview with The Lookout Friday, LA Council member Bill Rosendahl, who represents the district bordering Santa Monica, did not dismiss the prospect of litigation to stop the project as currently proposed.

"I'll see what legal remedies I have," Rosendahl said. "But I'm nowhere there yet. I'm starting with a positive spirit.

Monday's letter seemed to be laying the groundwork for a potential lawsuit.

The draft EIR, the letter said, "does not accurately state the proposed project's impacts on the environment, fails to require mitigation for the project's serious impacts on the street grid and traffic, and fails to consider a reasonable range of alternatives that might avoid or significantly lessen those impacts."

What's more, the draft EIR fails to "present information in a meaningful form so that it can be readily understood by decisionmakers and the public alike," the letter said.