SAMPLE COMMENTS

Not sure what to say?

A brief comment works - every single comment matters to show decision makers the project is being challenged and the DEIR is deficient.

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Send email to: EIR@bchd.org

Subject: Public Comments to the BCHD DEIR

 

Can also send to responsible agencies Cities of Redondo Beach and Torrance

at: CityClerk@TorranceCA.gov; CityClerk@redondo.org 

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To: Nick Meisinger

 

• Begin with brief personal statement about your concerns with the project (1-2 sentences)

• Include deficiencies to the DEIR or issues that matter most to you. See some examples below:

 

The DEIR is deficient and minimizes impacts, makes assumptions and omits data and analysis in key impact areas including, Aesthetics, Land Use, Transportation, Hazards and Hazardous Materials, Noise, Air Quality, Biological Resources and Recreation. The DEIR provides restrictive assumptions in its Project Objectives and Project Alternatives.  Phase 2 descriptions are vague, lack proper visualizations and result in an unstable project. The cumulative impact of these deficiencies should be addressed and result in a reissue of the DEIR to ensure agencies and the public have sufficient and appropriate data and time to make their determinations and responses.

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A few examples below:

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Aesthetics and Visual Resources

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RCFE is clearly Incompatible with surrounding neighborhoods. Its placement on the extreme perimeter of the property, combined with the proposed scale and mass causes the most damage to surrounding neighborhoods.

Violates General Plan land use policies for cities of Torrance and Redondo Beach municipal code to be “compatible in scale, mass, and character with surrounding neighborhoods”.

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• Torrance General Plan Policy LU.2.1. “Require that new development be visually and functionally compatible with existing residential neighborhoods…”

• Torrance General Plan Policy LU.3.1. “Require new development to be consistent in scale, mass and character with structures in the surrounding area”

• Redondo Beach General Plan Policy 1.46.4. “... ensure that public buildings and sites are designed to be compatible in scale, mass, character, and architecture with the existing buildings and pertinent design characteristics prescribed by this Plan for the district or neighborhood in which they are located.”

 

Single family homes surround the site as close as 80 ft. from proposed structures to the East, West, and South with up to a 30 ft. height limit. To the North by Residential RMD and Light Commercial C-2, both with 30-foot height limits. RCFE is built out to the edge of the property on a 30 ft. bluff, with properties to the East situated another 60 ft. below grade. It will:

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• Cause significant damage to blue sky views and major privacy issues.

• Subject residents to significant glare and night-time lighting of the 24/7 operations facility. DEIR provides no substantive analysis of impact.

• Create shadow effects that are significant to Torrance homes to East, Towers Elementary school and Redondo Beach homes to the North.

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Key viewing locations (KVLs) are flawed and deceptive. Main KVL from 190th and Flagler used to justify mitigation of reduction of 20 ft. height is flawed.

• Viewing location is deceptive, one of the few viewing locations where the project site appears to be lower than street level, rather than elevated 30 ft. above street level to the East.

• View of PV Ridgeline from this viewing location is not representative of views Not the highpoint as stated

 

Responsible Agency - City of Torrance was not consulted on key viewing locations, as stated in their response to the DEIR. New KVLs from the city of Torrance must be provided with city input.

 

Phase 2 realistic photo-simulations are completely missing. Thus impacts of the whole project is never shown or can be analyzed. DEIR states: “maximum building footprints and maximum building heights” of Phase 2 are addressed in the DEIR.

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Request

DEIR is deficient and missing information and visual aids necessary for agencies and the public to make reasonable assessments. Substantial setbacks and reduction of height would help mitigate damage to neighborhoods. Provide photo-visualizations and other physical visual aids such as silhouettes, poles, flag banners showing proposed height and mass of structures for Phase 1 and Phase 2.  Provide new key viewing locations consulting with the City of Torrance as requested. Detailed health impacts are not presented and are completely absent in regards to glare and nighttime lighting, and shadow effects on surrounding Redondo Beach and Torrance neighborhoods, and Towers Elementary school. 

DEIR should be recirculated to provide adequate time for the agencies and the public to review and provide comments. 

 

Hazards and Hazardous Materials

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BCHD plans to:

• Demolish the 514 building (old South Bay hospital) which contains lead, mold, asbestos, and other contaminants.

• Excavate, grade and trench more than 31,000 cubic yards of soil, containing significant amounts of PCE.

 

According to the DEIR:

"Soil disturbance during excavation, trenching, and grading at the Project site would result in the disturbance of potentially contaminated soil. Ground disturbing activities (e.g., excavation, trenching, and grading) during Phase 1 and Phase 2 would disturb PCE-contaminated soils, beginning with the excavation of the subterranean levels of the RCFE Building to a depth of 26 feet during Phase 1. Similarly, grading within the vacant Flagler Lot would also encounter PCE-contaminated soils. The soil samples on the vacant Flagler Lot ...had the greatest concentrations of PCE on the Project site (Converse Consultants 2020; see Appendix G). "

 

The selection of boring sites is inadequate. The only 30 foot boring, at B-1, which was known to be far away from where the main contaminants were found, seemed a deliberate attempt to avoid finding more contaminants which were almost certain to be found with proper investigation and greater study. Converse [Ref: 3.2.38] advised unequivocally: “Deeper borings in the locations where pollutants were found would yield even greater findings of more pollutants.”

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Requested Action 

Additional deeper borings and analysis should be done on the construction site. The fact that the PCE was found in 29 of 30 samples throughout the site shows it is widespread, often found far from its potential original source,and is likely spreading deeper and downhill the slope from its origins. 

Study the impact of natural occurrences such as heavy rains and winds, as well standard mitigations and human error or occasional noncompliance the appropriate guidelines. What are the ramifications or penalties for noncompliance. Specify who is held accountable and pays fines? The BCHD, the City of Redondo Beach, the developer? More information is needed on watering down of construction debris, contaminated soils, etc. and it’s impact on streets like Beryl and Flagler which are downstream and in close proximity to homes and Towers Elementary. Provide analysis for the stormwater drain system and spread to water conservation/nature preserves to the lower elevations in the East such as Entradero Park in Torrance.

 

Air Quality

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DEIR states Air Quality impact is “less than Significant with mitigation”. 

“However, on-site construction-related emissions would exceed the SCAQMD localized significance thresholds (LSTs) for respirable particulate matter (PM10) and fine particulate matter (PM2.5) as they affect off-site receptors. “

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The project would create air quality hazards, diesel particulates and fugitive dust known to be health hazards, even with mitigation measures. Throughout the DEIR, Mitigation plans are not sufficiently discussed nor safeguards detailed adequately. MM AQ-1 “would require watering of exposed surfaces three times daily….and prohibiting demolition when wind speed is greater than 25 miles per hour (mph).”

The mitigation plan only accounts for prohibiting demolition during wind events greater than 25 mph. It does not account for potential ineffectiveness of mitigations from loading up of demolition debris, excavation of 30,000 cubic yards of soil with known toxic substances such as PCE, and concrete grinding onsite, etc.  with intermittent wind speeds at 25 mph and higher. For instance in March 2021, wind speeds were measured at 45 mph on the lower site adjacent to the construction site. This wind speed was enough to topple the Shell Station: https://losangeles.cbslocal.com/video/5397491-wind-blows-off-gas-station-canopy-at-redondo-beach-shell-station/

 

Sufficient detail is not provided in the plans for airborne contaminants and fugitive dust for the localized site that includes surrounding homes and Towers Elementary school. Likewise it does not account for torrential rainstorms and their affect on the construction site, hillside slope and hazardous materials in the sewer system and storm drains that go directly to nature preserve water preservation like Entradero Park in Torrance. The construction site sits on a 30 bluff. The effect of wind was not properly studied.

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Requested Action:

Provide additional detail of the mitigation plan on construction elements other than active demolition, including piles of soil, demolition debris, finishing sanding, painting, etc. for all construction and finishing phases of the project, at varying wind levels above the 25 mph limit imposed by the mitigation.

Provide analysis of natural events such as high winds and heavy rain’s effect on airborne contaminants and stormwater drainage.

Effect on employees and the public in medical offices onsite the BCHD construction site. and local businesses (Vons Village Shopping Center) directly below the site are not addressed.

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Noise 

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According to the DEIR,NOISE ​"Is a Significant impact that cannot be mitigated." Even with standard construction-related mitigations applied, noise levels during the 5+ years of construction will EXCEED the Federal Transit Authority (FTA) thresholds. 

According to the DEIR, residents and the public will be exposed to hazardous noise levels of 80 to 90+ dBA.The DEIR shows the Noise levels will exceed both daily and 30-day average standards permitted by law.

Construction schedule is 6 days a week: Monday to Saturday.

The DEIR section on noise states in part: 

 

“Prolonged exposure to high levels of noise is known to have several adverse effects on people, including hearing loss, communication interference, sleep interference, physiological responses, and annoyance (Federal Interagency Committee on Urban Noise [FICUN] 1980).” [Ref: DEIR Sec. 3.1 Noise]

 

The impacts will be greatest throughout the areas surrounding the 11-acre site.

“…significant and unavoidable noise impacts would occur through implementation of proposed construction.” [Ref: DEIR p.3.11-35]

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The hazards of noise to all residents/sensitive receptors including the public at large include:

• Surrounding residents to the South, North, West and East of the site,

• Tenants of Silverado who are on-ste throughout the entire construction period

• Towers Elementary School with 600+ 4-10 year old students, staff, and visitors

• Adjacent businesses, workers and the public

• Medical offices onsite employing health care workers, doctors and others, serving the public

The operational noise levels for anticipated events on-site is not sufficiently discussed or analyzed.

 

Requested Action:

The study of noise is deficient, the data was based on modeling averages and not intermittent noise. The effects of the noise disruptions as well as ground vibrations caused by truck traffic and construction on student performance in classrooms was never studied. 

Viable mitigations to noise were not considered in the DEIR, such as for structure to be significantly set back to the center of site as well as reduce the height structure to no more than 30 ft., the maximum height of potentially viable noise barriers.

 

Any non-mitigatible impact affecting surrounding residents, students, employees, medical workers, and the public at large for the 5-years of construction is cause for BCHD Board and approving agency to reject the Project as proposed.

 

Missing category: Recreation

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CEQA category on Recreation is completely omitted in DEIR.

 

Requested Action:

Recreation at Towers Elementary is missing. Discuss impacts of construction air quality, transportation, and shadow effects on Towers Elementary schoolyard during school hours and key after hours programs such as YMCA daycare.

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Impacts on recreation for Dominguez Park, adjacent to the construction site and disruption to Dominguez Dog Park is not addressed. Heavy construction activities, heavy construction and demolition equipment and flagmen will greatly hamper access due to heavy construction equipment route, access and staging near Flagler lot and Beryl, as well as increased use of local facilities and services after operation must be analyzed and  addressed.

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Alternatives

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The California Environmental Quality Act (CEQA) Guidelines state that an “EIR shall describe a range of reasonable alternatives to the proposed project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives” (CEQA)".

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The DEIR states, “Alternate sites for the relocation of existing BCHD uses and the development of proposed services and facilities were considered. Such sites would need to be located within Redondo Beach, Hermosa Beach, or Manhattan Beach and have similar attributes to the Project site. For example, an alternative site would need to be large enough (i.e., 9.78 acres or greater) to accommodate the development footprint and uses associated with the proposed Healthy Living Campus. “

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There is no requirement that the RCFE of Phase 1 and other structures in Phase 2 be co-located on the same lot of land to meet project objectives. Being a “Center of Excellence” does not imply or require physical co-location of services; an alternative site would not need to be 9.78 acres of land or greater.

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Requested Action: Greater access to the services provided embedded and distributed throughout the three beach cities would be a benefit. This concept would provide better visibility and access for all taxpayers of the cities of Redondo Beach, Hermosa Beach and Manhattan Beach who fund the BCHD, and whom the BCHD is chartered to serve. Consider an alternative that distributes the RCFE in a location with less environmental impact than is currently proposed.

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