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Neighborhood Organizations To: Nick Meisinger re: Healthy Living Campus Wood Environment & Infrastructure Solutions, Inc. 9177 Sky Park Ct. San Diego, CA 92123 Public Comments Beach Cities Health District (BCHD) Healthy Living Campus (HLC) March 2021 Draft Environmental Impact Report June 1, 2021 Comments submitted by: Alan D. Archer Stephanie Ishioka Alice Ronne Ann Wolfson Carl and Marcia Gehrt Mark Miodovski Robert Ronne Brian Wolfson Lyndon Hardy Tim Ozenne Judy Scott Susan Yano Torrance Redondo Against Overdevelopment (TRAO) Table of Contents Page 1 Introduction 5 1.1 Roadmap 5 1.2 Advocacy 7 2 DEIR Deficiencies 8 2.1 Legality 8 2.1.1 The HLC Project is Not Legal 8 2.2 Objectives 9 2.2.1 The Need for Seismic Retrofit has Been Misrepresented by BCHD 9 2.2.2 Supporting Current Level of Services is a BCHD Want -- Not a Public Need 12 2.2.3 The Silver Tsunami is Not Going to Happen in the South Bay 16 2.2.4 The Parklands Enticement is a Bait and Switch 17 2.3 Mitigations 18 2.3.1 Aesthetics 18 2.3.2 Air Quality 24 2.3.3 Noise 31 2.3.4 Traffic 36 2.3.5 Greenhouse Gasses 52 2.3.6 Hazardous Waste Disposal 62 2.4 Applicable Plans 64 2.4.1 HLC Plan is Unstable Until After Flagler Lane Modification is Finalized 64 2.4.2 Key Provisions of any Partner Agreements are Missing 66 2.4.3 Design Build Violates the Intent of CEQA 67 2.4.4 LAFCO Requirements Are Not Being Satisfied 70 2.5 Alternatives 74 2.5.1 Define the No-Project Option Properly 74 2.5.2 Build a Minipark Instead - Abandon the HLC Altogether 75 2.5.3 Reduce Expenses 80 2.5.4 Explore Alternate Site Options More Fully 84 2.5.5 Issue Tax-Free Bonds or Raise Taxes 86 2.6 Cumulative Impacts 88 2.6.1 Concurrency Analyses Strikingly Absent 88 2.7 Economic Characteristics 98 2.7.1 BCHD does not have the Management Experience Needed 98 2.7.2 The HLC Project will Fail Financially 102 2.7.3 The True Purpose of the HLC Project Has Not Been Disclosed 109 2.8 Economic and Social Effects 115 2.8.1 An Assisted Living Facility is Misguided 115 2.8.2 Real Estate Value Depressions Analysis is Missing 118 2.8.3 Effect of Project Construction Failure Not Evaluated 120 2.9 Additional Transportation and Traffic Deficiencies 122 2.9.1 Impact on Local Schools During Construction Is Missing 122 2.9.2 Impact of Construction Worker Parking Is Missing 125 2.10 Geology/Soils Deficiencies 126 Table of Contents Page 2.10.1 Insufficient Toxic Waste Samples Have Been Collected and Analyzed 126 2.10.2 Safeguards During Excavation and Construction are Incomplete 130 2.10.3 Impacts from an Abandoned Oil Well Have Not been Addressed 131 2.11 Additional Noise and Vibration Deficiencies 137 2.11.1 Increased Fire Department Services Noise Analysis Is Deficient 137 2.12 Public Services Deficiencies 140 2.12.1 Analysis of Personnel Impact on Fire Department EMT Services Is Incorrect 141 2.12.2 Power Substation Construction Details are Deficient 143 2.13 Biological Resources Deficiencies 145 2.13.1 Analysis of Increased Rat Invasions is Missing 145 2.14 Additional Air Pollution Deficiencies 146 2.14.1 Strong Ozone Mitigations are Required 146 2.15 Additional Aesthetic Deficiencies 151 2.15.1 Effect of Impact of Shadowing Not Analyzed Correctly 151 2.15.2 Effect of Glare Impact is Insufficiently Analyzed 155 2.16 Hazardous Waste Removal Deficiencies 160 2.16.1 Asbestos Removal Compliance Not Fully Specified 160 2.17 Cultural Resources Deficiencies 161 2.17.1 Coordination with Local Native American Representatives Not Enforceable 161 2.18 Find out more 163 3 Appendix 163 3.1 Attached Documents 163 3.1.1 Request for HLC Project Definitions 163 3.1.2 Reply to 3.1.1 164 3.1.3 Request for Project Account Information 165 3.1.4 Reply to 3.1.3 165 3.1.5 An Example of Financial Parameter Sensitivity 168 3.1.6 Letter to BCHD March 30 2020 170 3.1.7 Pages 1-2 from CEO Report to BCHD Board of Directors 10/28/2020 179 3.1.8 Request for Attendance Information 180 3.1.9 Reply with Attendance Affiliation 181 3.1.10 Excerpts from the Wall Street Journal 11/16/2020 184 3.1.11 EIR Presentation for Public Meeting_032421-2.pdf - pg.42 184 3.1.12 Site View of Flagler Lane Now 185 3.1.13 Site View of Flagler Lane Proposed 185 3.1.14 Site View of Beryl Street Now 186 3.1.15 Site View of Beryl Street Proposed 186 3.1.16 Lead Agency Brief 186 3.1.17 Land Use Brief 196 3.1.18 Views of a BCHD Community Working Group Member 205 3.1.19 Email from BCHD to Torrance 209 3.1.20 LAMTA Quarterly Progress Report - Itemized Expenses 210 3.1.21 Premature Approval Brief 214 Table of Contents Page 3.1.22 AES Power Station Letter 219 3.1.23 View of BCHD from Sunnyglen Park 220 3.2 References 222 1 Introduction 1.1 Roadmap Below are public comments to the March, 2021 release of a “draft” document entitled “Environmental Impact Report for the Beach Cities Health District Healthy Living Campus Master Plan”. Each and every word of every comment made in this document, including, but not limited to those contained in the appendices hereto, and all attachments, are meant to be public comments to the March, 2021 draft of an EIR. This document, prepared by Torrance Redondo Against Overdevelopment (TRAO), presents 217 deficiencies of the BCHD Healthy Living Campus (HLC) Draft Environmental Impact Report (DEIR). Our intended audience is more than merely BCHD and its hired consultants. We hope that elected and appointed officials of the cities of Redondo Beach and Torrance also will gain insight by reading relevant portions of what is presented here. In section 2, we have organized these deficiencies into 41 arguments for why the HLC project should be abandoned. Each argument references appropriate sections of the Title 14, California Code of Regulations that pertain to the California Environmental Quality Act (CEQA). They include not only the traditional list of impacts such as Air Quality, Noise, and Traffic, but also general CEQA concerns such as Economic Characteristics and Economic and Social Effects. Among our argument conclusions are: 1. The HLC project is not legal. If you have a legal background, please concentrate on section 2.1. If you would like to contribute pro bono to help pursue this argument through the courts, please email TRAO90503.org. 2. Five of the six BCHD objectives are misleading and serve BCHD wants rather than the public needs. If you are a member of a city council or commission, please concentrate on section 2.2. 5 3. Five of the proposed mitigations do not sufficiently protect the public from adverse effects. If you feel that such shortcomings must be fixed before the project is allowed to proceed, please concentrate on sections 2.3. 4. The BCHD applicable plans, alternatives, and cumulative effects are not evaluated to sufficient depth. Four alternatives with merit have not been addressed at all. If you feel that these topics are important and must be analyzed, please concentrate on sections 2.4 – 2.6. 5. Nine CEQA Appendix G topics have not been adequately addressed. If you have a particular interest in some of these, please concentrate on sections 2.7-2.17. The number and substance of all of these shortcomings demonstrate that this project should not go forth. It should be abandoned entirely. For each argument in section 2, we reference the appropriate section of the DEIR and its supporting documents with the sources of facts that we assert to be true. Access to longer references, designated by [Ref:] in section 2, are listed in section 3.2. If you are reading this document on a computer rather than print, some references will have to be downloaded to a local computer before they can be viewed. They are in one of two formats: .pdf or .php. Both formats are readable in Adobe Acrobat. If the format is .php, Firefox and possibly other browsers will not be able to read a referenced file immediately. If this is the case, download the file, open Adobe Acrobat, and select Open from the File menu.2. SetFive the of file the selection six BCHD filter objectives to All files are, not misleading just those andwith servea .pdf extension.BCHD want Navis rathergate to than your the Downloads public needs folder. In the open dialog that appears, and click on the most recent file with a .php extension. If you are a member of a city council or commission, please 6 concentrateSome ofon our section reference 2.2. s are to shorter documents, designated by [See:] rather than [Ref:]. They are reproduced in their entirety in either another3. subsectionFive of the of proposed section 2 mitigation or are attacheds do notin section sufficiently 3.1. protect the public from adverse effects. The attached documents in section 3.1 are not only for reference, however.If you They feel are that part such of ourshortcomings formal comment must be to fixed the DEIR before and the should project beis allowed reviewed to in proceed, the same please manner concentrate as the material on sections in section 2.3.
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