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.
T
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.
Alternatives
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.
Aesthetics
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.
Biology
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.
Energy
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.
Geotechnical
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
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.
HazMat
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
disclosure.
Hydrology
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
construction.
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.
Noise
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
unacceptable.
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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