Redondo Beach General Plan Comments (2024-04-03)

These comments have been included in the General Plan document. You can support them by emailing them to PlanRedondo@redondo.org and CityClerk@redondo.org for the General Plan and the City Council

StopBCHD Group Comment

A Special Policy Area for Torrance-Redondo Beach that impact the Torrance Hillside Overlay should be developed. See full details (public comment) at https://www.stopbchd.com/post/protecting-torrance-hillside-overlay-property-from-redondo-beach-development-damages

StopBCHD Group Comment

Due to the formatting limitations of this tool, the provided link contains a formatted, detailed comment on creation of a Torrance-Redondo Beach Interface Overlay to protect the Torrance residents in the Torrance Hillside Overlay from overdevelopment on adjoining Redondo Beach parcels.

https://www.stopbchd.com/post/protecting-torrance-hillside-overlay-property-from-redondo-beach-development-damages

TECHNICAL COMMENT - this platform does not provide formatting controls for comments. That should be updated or replace this tool with another commercially available one.

StopBCHD Group Comment

No PCDR should be required for City of Redondo Beach projects that service residents of the City.

StopBCHD Community Comment

It's not at all clear that BCHD intends to use the P-CF zoning for PUBLIC use. It appears that BCHD plans to lease 3 acres to a 100% private entity for 95 years for commercial use. BCHD's estimates show that 80% of the use will be by non-residents. https://www.stopbchd.com/post/only-bchd-preserve-public-space-by-leasing-it-to-a-100-private-developer-for-95-years

StopBCHD Group Comment

Back in early 2022, City staff along with the City Council were forced by a State law change to add rigor and pre-published standards to development in the City. One of the few land use/zonings with significant Planning Commission discretion was in the public sector.

For example, P-CF (Public – Community Facilities) zoning had only subjective standards on how much building could be crammed onto a P-CF zoned lot. The Planning Commission was free to allow only 1 story, or 10 stories. The Planning Commission could enforce an FAR (Floor Area Ratio) of 0.1 or 2.0. Essentially, there were no objective rules for P-CF development.

“A design standard that involves no personal or subjective judgment by a public official and are uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official prior to submittal.” (California Government Code, Section 65913.4)

As a result, the Council provided a base FAR of 0.75 for P/I public-institutional land use and allowed for a 1.25 FAR in certain areas of City owned property for public services development. This was merely a conformance with the change in State law and provided the required objective standards.

BCHD has elected to claim this is “spot zoning” and is a taking from the District. By law, that is not true. The prior flexibility used by the Planning Commission no longer meets State law. Furthermore, the Planning Commission was free under the prior Redondo Beach Code to issue BCHD an FAR of 0.5 for future development. That would have been completely compliant with City Code. So BCHD is actually better off with 0.75 than with subjective standards.

City Staff and Council provided the FAR 0.75 base FAR and 1.25 limited FAR to the General Plan Advisory Committee (GPAC) in March of 2022. The draft document was provided to the members and the public three times, in March, August and September. How it could be that few GPAC members bothered to review the draft document throughout 2022 is simply astounded. Some did, and they even filed comments.

For the protection of the surrounding public, the City should roll back the FAR for P/I to 0.75 uniformly.

StopBCHD Group Comment

Consolidated property damage values from existing 0.72 FAR P-CF site on RB/Torrance border:

$97M Redondo Beach property value declines within 1/2-mile

$65M Torrance property value declines within 1/2-mile

StopBCHD Group Comment

The property value decline ($97M) in Redondo Beach surrounding the 312,000 sf, 99.7% under 52-foot tall campus is estimated by econometric models and the dataset used by BCHD's MDS consultants for market analysis (purchased and licensed by StopBCHD). https://www.stopbchd.com/post/redondo-beach-property-value-loss-within-1-2-mile-of-bchd-campus-over-97m-2024-update

StopBCHD Group Comment

The impact of being within 1/2-mile of BCHD campus has been estimated for Torrance residences, using the Redondo Beach model as a proxy. The property value damage from proximity to the 312,000 sf, 99.7% under 52-foot tall existing campus is $65M. Greater FARs and denser development will undoubtedly create larger losses for surrounding property values and property owners. https://www.stopbchd.com/post/torrance-property-value-loss-within-1-2-mile-of-bchd-campus-is-65m

StopBCHD Group Comment

The PCDR requires that new developments are subject to protecting property values. The 0.72 FAR of BCHD site damages surrounding property by $100M. The current 0.75 proposed FAR will result in increased property value damage.

StopBCHD Group Comment

From a policy perspective, P/I land should be used primarily for the benefit of Redondo Beach residents. Based on BCHD's consultant's work, Kensington (P-CF zoned) likely services 80% non-residents on 3 acres of P/I land. The use of Redondo Beach public land is unsustainable if it is consumed for non-resident use.

StopBCHD Group Comment

BCHD's HLC is supermajority benefit of non-residents

RCFE - BCHD's MDS consultant demonstrates 91% non-Redondo Beach resident tenants by zip code for the assisted living

PACE - BCHD's PACE will be 97% non-Redondo Beach resident enrollees.

allcove - BCHD's allcove services LA County SPA8 (1.4M population) and is 95% non-Redondo Beach residents.

While the damages of P/I fall entirely to Redondo Beach, the benefits of BCHD proposed HLC accrue to 91% to 97% non-Redondo Beach residents.

Residents should NOT have damages to service NON-RESIDENTS on P/I land

StopBCHD Group Comment

Sites developed by the City of Redondo Beach for the majority benefit of residents should not require any an PCDR process. They should be assumed compliant.

StopBCHD Group Comment

It should be explicitly stated that P/I land use should be for at least a majority benefit of the residents of Redondo Beach. The damages accrue 100% to Redondo Beach residents, therefore, they should receive a minimum level of a majority of benefits from the land use.

StopBCHD Group Comment

At least one P/I site, the BCHD campus, no longer has a hospital, therefore, "associated medical" are no long permitted uses. The can be allowed to remain until their natural sunset lifespans.

StopBCHD Group Comment

The State mandate for objective (not subjective) standards requires the city abandon the PCDR chosen FAR and it be replaced by objective standards. This proposal is consistent with State mandate.

StopBCHD Group Comment

Nick Biro was the Chair of GPAC and a $10,000 to $15,000 per month retained consultant of BCHD. Mr. Biro had both a GPAC obligation and a fiduciary taxpayer obligation via his BCHD to review all draft General Plan documents and provide comments timely.

StopBCHD Group Comment

March, August and September 2022 GPAC meetings and 2024 CEQA NOP for GP all included public notice of the P/I proposed 0.75 and 1.25 FAR.