April 20, 2020
Regional Planning Commission
c/o Erica Gutierrez, Senior Regional Planner
Department of Regional Planning
County of Los Angeles, CA 90012
Subject: Item 6, Regional Planning Commission Hearing April 22, 2020
Bridgepoint South Bay II IS/MND (Project NO. R2017-004820, Conditional Use Permit No. RPPL2017010467, Environmental Assessment No. RPPL2017010468)
Dear Regional Planning Commissioners,
Del Amo Action Committee (DAAC) has already provided extensive comments on the draft IS/MND for the above-referenced warehouse project proposed by Bridgepoint (Bridge). After reviewing Bridge’s response to comments, DAAC and the below signatories respectfully submit these comments—including the attached expert traffic and environmental comments (Exhibit A and B, respectively). By this reference, DAAC incorporates in their entirety these expert comments, as well as any other comments made by the public or public agencies.
First, as fully discussed in the attached expert comments, the IS/MND analysis of traffic, air quality, greenhouse gas emissions, human health, environmental justice, and cumulative impacts (to name a few) is fundamentally flawed by the IS/MND’s underestimating the Project’s truck trips. So too, current conditions of approval, purporting to prohibit the Project from operating as a high cube warehouse or exceed the IS/MND’s assumed truck trips (i.e., 37 round-trips or 74 one-way trips), is not adequately enforceable. This condition must be made more stringent to ensure compliance.
Second, noise conditions have not been adequately addressed; especially concerns that have been raised about 24 hours, 7 days a week operation which is common place for high cube warehouse facilities. These same noise concerns were raised in 2015 against the prior business operating on this site unpermitted for 20-plus years. Adjacent businesses currently operate under a conditional use permit that restricts operations from 7 AM to 6 PM Monday through Friday and 8 AM to 1 PM on Saturday in order to be more compatible with adjacent residential areas.
Third, given how woefully inadequate the draft IS/MND was, the Commission should take great pause before it relies on Bridge’s self-enforcement of conditions of approval. Here, numerous public agencies comment on the inadequacy of the draft IS/MND, such as the Attorney General, California Air Resources Board, County of Los Angeles Public Health Department, and South Coast Air Quality Management District. Bridge only made revisions to the IS/MND/s analysis and mitigation after it failed to fly under the radar. Yet, the Final IS/MND still fails to cure the Projects significant underestimation of truck trips, which directly impact the lives of the surrounding residents in this known environmental justice community.
In sum, notwithstanding the revisions to the Project’s IS/MND, it is still fundamentally flawed with underestimated truck trip assumptions and not adequately conditioned. This Project has long-lasting consequences that should be decided by the Board of Supervisors. For these reasons, and the reasons discussed elsewhere in the Project’s record, DAAC and the below signatures respectfully request the Regional Planning Commission the following:
- Stay approval of the Projects conditional use permit (CUP) and environmental approvals until a CEQA-compliant environmental impact report for the Project is prepared; or
- Refer the item to the Board of Supervisors with the recommendation that at minimum the CUP be subject to the following conditions:
- Place a restrictive covenant that explicit caps no more than 74 truck trips and/or 469 PCE total trips at the Site, subject regular mandatory reporting requirements akin to the reporting requirements currently proposed under SCAQMD’s proposed Warehouse Indirect Source Rule (“ISR”)31 or alternative reporting requirement relying on verifiable traffic counts.32 At minimum, the required monitoring should include—in addition to a master daily log maintained and made available to County Zoning Enforcement upon request—that: daily counts are monitored in real-time via video surveillance of each driveway accessing the Site on a publicly available website; that the future tenant(s) submit monthly or quarterly reports to the County of the daily master log entries with corresponding video files; require monthly/quarterly reports to adequately explain any discrepancies between the daily master log entireties and video files; and that any exceedance of trips (beyond 74 truck single-trips, 37 truck round-trips, or 496 PCE trips) is subject to further discretionary approval by the County.
- The Project should be limited to the hours of operations comparable to other nearby industrial uses, including 7 AM to 6 Pm Monday through Friday and 8 AM to 1 PM on Saturday
Del Amo Action Committee