N.1. 21-2530 DISCUSSION AND POSSIBLE ACTION REGARDING THE SUBMITTAL OF CITY OF REDONDO BEACH WRITTEN COMMENTS IN RESPONSE TO THE DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR) FOR THE BEACH CITIES HEALTH DISTRICT (BCHD) HEALTHY LIVING CAMPUS
The BCHD DEIR understates and under reports many impacts. For instance, Phase 2 is not shown in any photo-simulations and thus agencies and the public cannot make a reasonable determination. The city should at a minimum request this.
I support the BCHD DEIR comments submitted to you this evening by Community Development Director Ms. Forbes. The report requested changes to the DEIR that may result in additional impacts but the report did not include a request to revise and recirculate the DEIR. While I am not a professional in this area, it seems appropriate given the changes requested, to make that request to recirculate.
I have many concerns about the BCHD proposed project. The following short list shows how, in my view, the project conflicts with the current Land Use Element and the Municipal Code.
The proposed project conflicts with RB General Plan-Land Use Element
Goal 1K In the Land Use Element states that the P land use will “provide for public uses which support the needs and functions of the residents and businesses of the City.” The proposed RCFE is not a public use, it is a private use and therefore conflicts with this goal to provide for public uses.
Land Use Element Policy 2.1.3 Table 2 identifies “uses for the P (Public) Land Use category includes governmental administrative and capital facilities, parks, schools, libraries, hospitals and associated medical offices, public cultural facilities, public open space, utility easements, and other public uses.” The proposed RCFE is in conflict with this policy because it not a public use, it is a private commercial use.
The proposed project conflicts with the RB General Plan Municipal Code Zoning Ordinance
Municipal Code Section 10-2.1100(a) Specific purposes for P public and institutional zones: “Provide lands for park, recreation and open space areas, schools, civic center uses, cultural facilities, public safety facilities, and other public uses which are beneficial to the community.” The proposed RCFE development is in conflict with this municipal code because it is not a public use, it is a private commercial use.
BCHD's DEIR is defective and should be revised and recirculated, and I ask that be included in the City's comments to the DEIR.
In 2018, the California Supreme Court held that an EIR must (1) include “sufficient detail” to enable readers to understand and to “consider meaningfully” the issues that the proposed project raises, and, (2) make a “reasonable effort to substantively connect” the Project’s significant air quality impacts to likely health consequences.
(1) BCHDs DEIR fails to provide sufficient detail of the negative health impacts and negative environmental impacts of its Project. BCHD elected to exclude analysis of Recreation impacts ex ante, despite comments in the NOP phase requesting Recreation impacts be examined. Public review of the DEIR ferreted out the impacts of shadowing/shading on the public recreation fields of Towers Elementary, thereby negatively impacting public recreation. BCHD neither examined Recreation nor discussed the impacts. As a result of this omission and a general lack of detail on negative health impacts, the public, and the City of Redondo Beach, have insufficient information and analysis from BCHD to meaningfully consider the Project's impacts.
(2) Further, BCHD has not connected the project's negative impacts with health impacts as per the Court's direction. BCHDs incremental emissions, denial of sunlight to residential and recreational uses, noise, vibration, glare, excess night time lighting and other negative impacts have no discussion of their myriad negative health impacts. BCHD also fails to discuss the specific health impacts of their proposed mitigations. As a result intelligent participation in the CEQA process is denied to the public.
Again, the DEIR is defective, should be revised and recirculated.
The BCHD DEIR understates and under reports many impacts. For instance, Phase 2 is not shown in any photo-simulations and thus agencies and the public cannot make a reasonable determination. The city should at a minimum request this.
I support the BCHD DEIR comments submitted to you this evening by Community Development Director Ms. Forbes. The report requested changes to the DEIR that may result in additional impacts but the report did not include a request to revise and recirculate the DEIR. While I am not a professional in this area, it seems appropriate given the changes requested, to make that request to recirculate.
I have many concerns about the BCHD proposed project. The following short list shows how, in my view, the project conflicts with the current Land Use Element and the Municipal Code.
The proposed project conflicts with RB General Plan-Land Use Element
Goal 1K In the Land Use Element states that the P land use will “provide for public uses which support the needs and functions of the residents and businesses of the City.” The proposed RCFE is not a public use, it is a private use and therefore conflicts with this goal to provide for public uses.
Land Use Element Policy 2.1.3 Table 2 identifies “uses for the P (Public) Land Use category includes governmental administrative and capital facilities, parks, schools, libraries, hospitals and associated medical offices, public cultural facilities, public open space, utility easements, and other public uses.” The proposed RCFE is in conflict with this policy because it not a public use, it is a private commercial use.
The proposed project conflicts with the RB General Plan Municipal Code Zoning Ordinance
Municipal Code Section 10-2.1100(a) Specific purposes for P public and institutional zones: “Provide lands for park, recreation and open space areas, schools, civic center uses, cultural facilities, public safety facilities, and other public uses which are beneficial to the community.” The proposed RCFE development is in conflict with this municipal code because it is not a public use, it is a private commercial use.
BCHD's DEIR is defective and should be revised and recirculated, and I ask that be included in the City's comments to the DEIR.
In 2018, the California Supreme Court held that an EIR must (1) include “sufficient detail” to enable readers to understand and to “consider meaningfully” the issues that the proposed project raises, and, (2) make a “reasonable effort to substantively connect” the Project’s significant air quality impacts to likely health consequences.
(1) BCHDs DEIR fails to provide sufficient detail of the negative health impacts and negative environmental impacts of its Project. BCHD elected to exclude analysis of Recreation impacts ex ante, despite comments in the NOP phase requesting Recreation impacts be examined. Public review of the DEIR ferreted out the impacts of shadowing/shading on the public recreation fields of Towers Elementary, thereby negatively impacting public recreation. BCHD neither examined Recreation nor discussed the impacts. As a result of this omission and a general lack of detail on negative health impacts, the public, and the City of Redondo Beach, have insufficient information and analysis from BCHD to meaningfully consider the Project's impacts.
(2) Further, BCHD has not connected the project's negative impacts with health impacts as per the Court's direction. BCHDs incremental emissions, denial of sunlight to residential and recreational uses, noise, vibration, glare, excess night time lighting and other negative impacts have no discussion of their myriad negative health impacts. BCHD also fails to discuss the specific health impacts of their proposed mitigations. As a result intelligent participation in the CEQA process is denied to the public.
Again, the DEIR is defective, should be revised and recirculated.