BCHD Cannot Damage Neighborhoods Any Further
Public Comment - BCHD Incorrect Statements Regarding FEIR and RBMC/TMC Interactions
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Cc: firstname.lastname@example.org, Al.Muratsuchi@asm.ca.gov, Ben.Allen@sen.ca.gov, HollyJMitchell@bos.lacounty.gov
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BCHD appears to be misrepresenting the role of its EIR in the RBMC and TMC approval processes. In its May 2022 Board report, BCHD hand waves as to the importance of its FEIR, and BCHD states:
"Due to the fact that a certified and unchallenged Environmental Impact Report (EIR) was submitted as part of the CUP pre-application, it was a very thorough pre-application (emphasis on pre)."
However BCHD also correctly recognized the irrelevance of the EIR in the RBMC and TMC approval processes, coincidentally, in its FEIR, BCHD correctly stated the separation of the EIR and Discretionary Permitting Processes:
"It is important to note that the determinations of the consistency for the proposed Project are provided for CEQA purposes to determine the potential for physical environmental impacts."
"Unrelated to CEQA - plan, policy and regulatory consistency would be determined as part of the review and approval process with Redondo Beach and Torrance decision-makers during consideration of discretionary approvals for the Phase 1 preliminary site development plan and the more general Phase 2 of development program." [FEIR 3.10-17]
Because BCHD is thoroughly inexperienced in development, some agency needs to counsel BCHD. The Cities will need to protect their residents in the discretionary permit process or face appeal and litigation for such failure. To date, the Cities do not appear to have protected their residents, based on the BCHD Pre-CUP and its abhorrent, incompatible design and plot plan.