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BCHD was discounting the views of the Community Working Group as early as April 2019

The following comments were directed at the BCHD Board in April 2019 when it was clear that BCHD was following an agenda while ignoring most input from the surrounding community.

Comments on Potential BCHD HLC Project and NOP/EIR Formulation


BCHD Board of Directors and Staff:


As a member of the Community Working Group, I have made many of these comments in writing or in

discussion during our group meetings. Typically however, our discussions in the CWG are more along

the lines of framing the project and reacting to proposals, and they are less about the multi-facets of the

environmental analysis and City of Redondo permitting. In any event, my prior comments have not

been made in light of a potential NOP, and as such, I am using typical portions of an EIR table of

contents to guide this comments.


hese comments are predominantly written from the perspective of the local Redondo Beach Beryl

Heights neighborhood where I live, which is most likely to be impacted by the project in both the

construction phases and the ongoing operations.


Project and Program Description

As is mandatory for an undertaking such as the Healthy Living Campus, the project must be described

in detail. Because this is mixed-use (residential, public, professional, food service, and perhaps retail),

the neighborhood residents will require significant detail to evaluate and determine its ultimate support

or opposition based on the benefits and detriments of the proposal. A number of specific issues come

to mind, including but not limited to descriptions and dispositions of: the specific facilities for use by

area residents, the timing of development of those facilities, the displacement (and accommodation) of

medical services that many of us currently use in the 510 building, anticipated phasing and timing,

operating days and hours, and the project’s physical characteristics. Because this is a program, that is, a

series of related projects across a significant timespan and likely several management teams (up to 15

years), a detailed description of each phase, its timing, and its linkages to other parts of the mixed-use

campus is required. An example would be the timing and linkages of residential housing, the Center for

Health and Fitness replacement, meeting rooms, cafes, etc. Also, the impacts cannot be determined

without an understanding of pricing and subsidy policies, such as: pricing policy for residential assisted

living, food service, fitness clinic, and other products and services.



The CWG has had only brief discussions about alternatives, and they included additional/replacement

land leases such as 510 and 520. No other uses other than the HLC have been brought forth that I am

aware of, and I believe that a robust set of alternative uses of the BCHD land is needed.


No Project Alternative

The CWG has had a limited discussion of the No Project Alternative in the form of some financial

projections of the retirement of 514. The No Project Alternative is not well understood to my thinking,

and it requires significant development and explanation such that the surrounding neighborhood can

understand what happens if the HLC or one of its alternatives fail to move forward. Some examples

include: a parallel to the AES Power Plant (shutdown, decommission, park land), sale for real estate or

other development, alternative use of the existing buildings, termination of BCHD, etc.


Purpose and Need

BCHD and its activities were a deviation from the South Bay Hospital that preceded it. The HLC will

be a deviation in some activities (district owned rental housing) from the BCHD activities to date.

Given that health districts in California have a variety of functions, a crisp discussion of the purpose

and need of the project will be very helpful. Over two years of discussion, the CWG has inferred

purpose and need, but communications to the adjacent landowners will need to be full, concise and

persuasive. Further, recent CWG discussions have focused on the HLC being a financial engine for the

BCHD other activities, and also as an engine to discount the cost of assisted living for financially

qualified local residents. That discussion seems to be an integral part of purpose and need that is

currently lacking a concise written form.



From the local neighborhood perspective, I continue to have my stated concerns about mass, height,

setbacks, artificial lighting, sun reflection, and invasion of the visual privacy of the surrounding

homeowners. Simulations, elevations, illustrations, and models will be needed to provide an adequate

disclosure of the design. Again, because this is phased, it will be important to understand timing and

activities on the BCHD site during the decade to 15 year interim period.


Air Quality

While I don’t currently anticipate any specific air quality issues, I am concerned that exhaust from the

underground parking and from any food preparation facilities are not a burden on the local receptors.

As a result, the program should disclose and analyze emissions beyond any onsite cooling towers,

generators, boilers or other equipment and include food preparation and parking ventilation at a

minimum. Construction is another issue however with respect to air quality impacts, with demolition

debris, truck and transport emissions, PM2.5s and PM10s from all sources, concrete flydust, fugitive

dust, portable generators, construction equipment, and other concerns. It is likely that the buildings are

laden with asbestos (to be discussed in HazMat) and any wind drift causing toxins to spread will be

unacceptable to the neighborhood, therefore, any potential winddrift accumulated biohazard will need

to be managed during demolition.



The biological impacts of the changing use of the BCHD campus will be analyzed, with special

emphasis needed on urban wildlife such as coyotes, raccoons, opossums, rats, mice, raptors, feral cats,

nuisance animals and insects, etc. The neighborhood, its children and pets are at risk from potential

disease and attack.



Neighborhood concern regarding energy would arise in the long term if the facility had significant

onsite generation that would either pose a potential fuel and emissions hazard, or, a local area line

voltage fluctuation. Concerns over diesel fuel generator use during construction are needed, and

disclosure is required for the neighborhood’s review.



Aside from proper retaining walls, removal (not abandonment) of buried piping and tanks, etc., I see no

particular geotechnical concerns from a neighborhood perspective. The standard analysis should

suffice, including disclosure of the local seismic background.



GHG is a global issue. Again, the neighborhood may have concerns if BCHD uses onsite alternative

energy generation to mitigate GHGs, as wind turbines and solar panels can have unintended side effects

to wildlife, create noises that curtail neighborhood quiet enjoyment of our property, or create solar

panel glare or heat islanding. Any plans for onsite GHG mitigation should be disclosed.


Biohazards, biowaste, asbestos, PMxx, diesel, fuel oil, underground tanks, buried pipelines, etc. both

during demolition and during long term operation are a neighborhood concern that will require




Water capture (rain), water runoff (rain), and water runoff (irrigation) are at present the only impacts

that I see of concern to the neighborhood. BCHDs analysis will need to assess their needs for



Land Use/CUP

A clear understand of the future land uses for the project, alternatives and no project will be needed for

the local area to understand its optionality with respect to the project. Covenants on long term use may

be required for neighborhood support to assure that the site does not become an incompatible use with

the neighborhood, for example. Notwithstanding legal opinions, the local area may opt to sponsor a

local initiative “vote of the people” for any change in use of the site that was originally, legislatively a

hospital and was never contemplated for 400 residential units.



The current facility has significant operational noise with emergency vehicles, vehicle traffic, loading

and unloading, trash collection, night and weekend maintenance, etc. that impact the adjacent

neighborhood. A curtailment of long run noise is compatible with the housing component of the project

and with the neighborhood. A decade of construction noise and any amplified or acoustically

concentrated (constructive wave interference) noise from the green space or circular building will need

to managed heavily as well. If the Beryl Heights neighborhood is at the mouth of a de facto

amphitheater, it is unlikely that the neighborhood will support the project. Noise, both long term and

construction, is a very, very important design factor and concern.


Population and Housing

The Residential Care Facility for the Elderly (or assisted living) housing will be 400 beds from our

initial understanding. That is equivalent to about 125 local area homes homes, or roughly 4 blocks of

the surrounding homes worth of additional population and housing. While that doesn’t seem large, it

will be incumbent on BCHD to explain the impacts from services, occupant traffic, visitor traffic,

rideshare traffic, and other ancillary local impacts.


Public Services and Utilities

California is in the midst of a homeless crisis. Large open spaces are double-edged swords, and will

require tight management by the BCHD or lessees in order to assure that the neighborhood does not

end up with an encampment or increased levels of transients. Thus, a full description of both private

security and policies, along with a participating agency analysis by the RBPD and perhaps

surroundings Pds will be needed for local neighborhood assessment of the project. In addition, the

usual gas, water, sewer, and power analysis by local suppliers will be required to understand any local

impacts, such as drainage, sewer, water supply, gas/power, or other public utility services.


Transportation and Parking

South Bay Hospital had a very negative relationship with the local community with regard to parking.

Undersizing the parking at BCHD, or assuming high proportions of rideshare or other parking-reducing

actions must be revealed and carefully analyzed. In the 1980s and 90s, the surrounding neighborhoods

were forced to use permit parking as result insufficient and overpriced parking at South Bay Hospital,

along with poorly managed employee parking policies. That has happened once, and cannot be

allowed again.


BCHD traffic emerging from the 510/514 shared driveway has been a long term, unsafe situation.

Emerging traffic often does not yield for pedestrians in the crosswalk, creating an unsafe situation.

Further, the same traffic heading south asserts an illegal right-of-way and fails to yield to traffic exiting

the Prospect frontage road that has the clear, legal right-of-way. As a result, traffic control at the

intersection must be modified during this development to assure the legal traffic rights of the area

residents. Perhaps the 510/514 driveway should be removed, with access points limited to the existing

exits on Prospect to the south of 510 and the north of 520. In any event, the current situation is



This is not intended to be a complete issue listing, however, it will hopefully provide a view from a

local resident, who in my case, is approximately 100 feet from my east lot line to BCHDs west lot line

at the 510 building according to inspection using Google Earth. Thank you for the ability to participate

in this process from the beginning, which will hopefully avoid many of the project pitfalls and conflicts

that I’ve witnessed over the past several decades. Assuming my schedule cooperates, I plan to attend

the BoD meeting on the 24th of April.

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