This is part two in a series of posts. The purpose of this series is to prepare the public to help our city council members with their homework considering the 5 million square foot warehouse project known as the Heartland project. The mayor has worked hard to pass the change in land zoning this project would need to move forward as a warehouse distribution center. It appeared in earlier council meetings that the members failed to do their homework and relied too heavily on a faulty staff report.
The health of our families is too important to hope they do their homework. A private citizen hired a law firm to review the staff report and filed a comment letter and presented it at the June 4 city council meeting. Based on this comment letter and a review presented by the South Coast Air Quality Management District, over the objections of Mayor Berg, put this project on hold and plan to hold a workshop. At the end of the series I will provide a list of questions we need to address at the July 2nd workshop.
Following are important excerpts from tonight's homework assignment pages 4-9 of the comment letter:
Water Quality Standards
Despite the significant change in land usage proposed under this Project, the Addendum claims the Project will not result in any new significant, substantively increased or different impacts.There is no support for this claim. For instance, the Addendum claims that the Project would not result in any new, additional, or different hydrology/water quality impacts. First, no hydrology/water quality study has been prepared for this Project, so it is unclear how the Addendum arrives at this conclusion. Second, the Santa Ana Regional Water Quality Control Board commented that the Project may violate water quality standards.
The Addendum does not require the Project be revised and finalized until after close of the public hearing process. Consequently, the description of the Project does not adequately inform decision-makers and the public of the true nature of this Project and its impacts. The Santa Ana Regional Water Quality Control Board commented in a letter dated April 23, 2013 that the nature of the basins must be accurately described in order to allow the City to enforce this Project's Water Quality Management Plan (which, as noted below, has not yet been prepared) and comply with its Permit.
Mitigation Monitoring Program
As a general note, and as explained further herein, the mitigation for this Project is improperly deferred and unbelievably deficient. Importantly, a Mitigation Monitoring Program has not been prepared for this Project.Traffic Study
The traffic study in the addendum is grossly distorted and deprives the public and decision makers of any chance of making an informed decision. This impact is not only felt relative to traffic but even more so for air quality. The Traffic Study assumes that only 4% of the total trips for the project will be large trucks. This amounts to only 337 one way trips per day for large trucks. This amounts to only 168.5 trucks visiting the site per day, a totally unrealistic number for a project that would be expected to have 600 dock doors.
Estimates from other sources indicate approximately 1 truck per 1,000 square feet of the building, which means that the proposed project would require 5,000 trucks per day (or 5,000 trip segments per day) for the Project.
Even worse, the average trip length is totally distorted with an average trip length of 7.7 miles per trip. This is in spite of the fact that 100% of the trucks are projected to use I-10. The distance to the ports at Long Beach is 90 miles one way. To Arizona it is substantially longer'.Rather than the 2,600 miles per day for heavy trucks identified in the TIA, the actual mileage would be 30,296 miles per day, over ten times the number claimed in the TlA.
Health Risk Assessment
Additionally, there is no discussion of Health Risk Assessment to determine the impact to the health of area residents from the toxic diesel emissions.
The Project is located within the South Coast Air Basin (SCAB). Residents in this region experience the worst air quality in the nation. Diesel trucks, which would necessarily be used in conjunction with the Project, emit many harmful pollutants including ultra fine particles, diesel particulate matter (a known carcinogen), and nitrogen oxides (I.{O"). While the traffic and criteria pollutants may not significantly differ, the use of diesel trucks associated with this Project will substantially increase toxic air contaminants.
The complete lack of mitigation measures adopted to address significant and unavoidable air quality impacts shows the utter inadequacy of environmental review in this case. Sadly, the few mitigation measures which are actually required of this Project are highly deficient.
The Staff Report claims this Project "will not be detrimental to the health, safety and general welfare of the community" (p. 6). To the contrary, the AQMD MATES III study places the Project in an existing carcinogenic risk area of nearly 500 cancers per million and in an area where "diesel particulate continues to be the dominant toxic air pollutant based on cancer risk."Health risks from Diesel PM are wide-ranging and well documented. The Project and cumulative projects in the area will add to these risks.
Questions for the council:
- If you estimate only 168 trucks would visit the facility daily, why do we need 600 dock doors?
- When will a mitigation monitoring program be available for public review and comment?
- Were you aware the project is in an existing carcinogenic risk area?
