The City of Los Angeles is preparing to give approval to building a truck depot on the land where the South Central Farm once stood unless the public speaks out about the impact the developer's plan on the South Central Los Angeles community. This community exists in a food desert facing daily environmental racism, constant toxic emissions, constant noise, neglect and is a high-density urban sacrifice zone.

Please add your public comment and Demand the City Provide A Public Scoping Hearing to hear from the people directly impacted by this horrible, speculative overbuilt monstrosity proposed by the four little sweatshops known as PIMA, known for manufacturing clothes for Forever21, a dirty, non-union retailer. A small commitment of your time will have a big impact on the quality of life issues which are critical for all of us.

Attached are the City Notices dated June 10, 2014 and June 17, 2014. The deadline for public comments is now July 17, 2014. Talking points for your comments will be provided as soon as they become available. Please check this group throughout the next week for the latest news. Thanks.

http://email.scfcooperative.com/link.php?M=20148&N=74&L=33144&F=H

July 8, 2014

Bruce Campbell

………………….

Los Angeles, CA 90034

Srimal Hewawitharana
Environmental Specialist II
Department of City Planning
200 N. Main St. 7th Floor
Los Angeles, CA 90012
Via email: srimal.hewawitharana@lacity.org

Re: Case No. ENV-2012-920-EIR, AA-2012-919, DIR-2013-887-SPR/ Proposed Construction of Four Industrial Buildings

Dear Ms. Hewawitharana, Planning Dept., and to whom it may concern:

These are my scoping comments on Re: Case No. ENV-2012-920-EIR, AA-2012-919, DIR-2013-887-SPR/ Proposed Construction of Four Industrial Buildings
-- also filed on behalf of the South Central Farmers Support Committee pertaining to the 4051 South Alameda Street Project.

I want to make a few initial crucial points:

1. I note (on a door on the 7th floor of L.A. City Hall) that the 41st and Alameda proposed project has been moved to the "Major Projects" part of the Planning Department.

2. I find it ironic that the project is apparently "major" enough to require an EIR, is "major" enough to be moved to that part of the Planning Dept., and yet it has been declared that the proposed project is not of regional significance and thus there are no plans for an in-person public meeting in which the public can comment on what the scope of the study should be.

3. Either in the EIR, or preferably as a prelude to scoping, the public deserves to have the knowledge of exactly who was "the grand decision-maker" who apparently decided that this neighborhood wherein a major project is proposed (involving polluting vehicles in a hard-to-access area in the already excessively-polluted Alameda Corridor region) was not deserving of public scoping hearing. (Please, either have someone admit to it, or we may pursue other methods to gather documents which expose the trail of who was involved. Was the District # 9 Councilmember's office, someone with the Mayor's office, and/or the applicant or his people involved with convincing the "grand decision-maker" to make sure to avoid a public scoping hearing since there allegedly was no regional significance?)

4. I consider the "current project" documentation to be invalid. Not only must there be a public scoping meeting to discuss the regional impacts of the proposed project, but when there are continued blatant lies in regards to such things as how wide streets are in the vicinity and whether homes exist south of 41st Street and east of Long Beach Ave., why should be believe things like sampling for toxic materials and believing the number of theorized vehicle trips per day relating to the project(?)

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I call for admission as to who pressured whom, and who made the decision to avoid a public scoping hearing on the regional significance of the PIMA project.

Then, have two humans bring a tape measure and measure the streets that surround the 41st and Alameda site. Record correct info, and replace bogus numbers in documents such as under "Environmental Setting" on page 7 of 581 with the correct numbers. (I am no lawyer, but I believe that many courtrooms like relative truth rather than easily-disproved lies, so change the street measurements if you want to retain any credibility.)

I want to point out that another major problem with the "Environmental Setting" portion is that it pretends that there are no residences south of 41st Street and east of Long Beach Ave. Please cease having Planning Dept. officials swallow whatever developers and often their Council lackeys tell them! You can go to the area and look for homes (which you will find) -- you can even bring a tape measure to do two tasks at once!!

It is my understanding that, though comments on earlier variations of the project are in "the file", that those comments will not count toward scoping comments on the current project. Though I will try to get important points in the record again, but why should an old case number and the applicant's earlier info still be valid, and yet the comments on such a case number apparently will not count unless re-submitted? (Please point to a legal regulation which says that applicants can keep documents in the record, while also saying that comments on such documents would not formally be considered in the record to challenge the newer project.)

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I note that "Environmental Settings" has changed from the earlier document. Taking my advice, Alameda Street was declared to be east rather than south of the site -- plus 41st Place was changed to 41st Street as I had pointed out. WHAT ABOUT BOGUS ESTIMATES / MEASUREMENTS OF THE ADJACENT STREETS to the 41st and Alameda site?? Those remain not only very suspect, but BLATANTLY INACCURATE!

A few of us mentioned large trucks in earlier comments. The EIR must be very clear as to exactly what kind of trucks will be able to access which streets and which driveways in the area of the 41st and Alameda St. site. Will the trucks with 53 foot trailers and large sleeper cabs be able to access the area -- by which streets and to which driveways? If not, explicitly mention in the EIR that no trucks with 53 foot trailers and sleeper cabs will be forbidden to enter the area. Even some other trucks will have a hard time with Long Beach Ave. and other streets and driveways in the area.

Please examine Sarah Nolan's concerns about lined up traffic waiting to turn in their scrap metal (when considering how accessible certain roads would be when giant trucks are seeking to travel on narrow roads), as well as the Food Bank's concern that there still be parking on both sides of 41st Street.

It is also odd that the documentation omits the inescapable fact that the Metrorail Blue Line runs on some tracks adjacent to the Pacific Railroad's tracks and crosses the fairly busy 41st Street. So, the fantasyland of this development proposal envisions wide roads, disappearing residences, and a seemingly vanished light-rail line. That is simply not the reality of this site. (I hope to have included in the record some of Metro's earlier concerns about the proposed project's impact on safety in the 41st Street and Long Beach Avenue area.)

The latest "Environmental Setting" says that the site is level. While it is fairly level, yet a map in the record notes that it is a few feet higher at northeastern end than it is at the southwestern end of the property.

Also, I realize that not only was there a concerted effort made to pretend that there are no residences south of 41st St. and east of Long Beach Ave., but they even have the nerve to pretend that the fairly densely populated neighborhood to the west of Long Beach Ave. is mere warehouse / industrial. Basically, after going about a block west of Long Beach Ave. on 41st Ave., then it is predominately a residential area, and quite a populated one at that. Thus, do not pretend there are not a bunch of "sensitive receptors" in the immediate as well as greater vicinity of the 41st and Alameda site.

I will now peer at the map in the record and mention some key parcels in the general area which could be considered "sensitive receptors" or otherwise contributing to safety concerns in the region. Glancing at page 27 of 781, the Snyder Recreation Center would be the closest site which would have a number of sensitive receptor people (unless one counts individuals with asthma, other ailments, or a baby or elder in closerby residences) I note that the nearest school is Nevin Ave. School -- followed closely by Jefferson High School, then the Roberts Recreation Center, the Ascot Avenue School, and the Holmes Ave. School. Carefully evaluate the likely impacts of added air pollutants on the sensitive receptors at each school and recreation site mentioned above.

Increased diesel emissions, increased congestion, inadequate street size, and other aspects relating to the project will certainly add to the already excessive toxic burden which the Alameda - Central community carries at the aforementioned schools and recreation centers, as well as otherwise. While I personally have not surveyed the neighborhood for nursing / retirement homes, or for places for medical or psychiatric care, please identify such facilities in the EIR if they are within 3/4 of a mile of the 41st and Alameda site.

With the increased congestion on all 4 surrounding streets, as well as the proposed surge in vehicle journeys associated with the project, this increase in emissions which clearly has an impact on many sensitive receptors must be carefully analyzed in the EIR. In addition, these emissions, plus the impact on health and safety of sensitive receptors in the neighborhood, must also be carefully analyzed in an Environmental Justice context.

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IMPORTANT SUBSTANCES FOR WHICH TO TEST:

I find 14 samples at 5 foot depth, with perhaps two at a 15-foot depth as part of a soil vapor probe, to be an inadequate characterization of this heavily abused site for toxic materials.

I call for a thorough assessment of hazards and hazardous materials to be included in the EIR. Such thorough testing would involve numerous sampling sites within each acre within the 41st and Alameda site. A mere one sample per acre is certainly inadequate if one is concerned about health and safety. I am not an expert on sampling, but the more the better, and taking samples at differing depths could bring useful information forward.

The toxic materials which must be tested for (in the EIR) include: Total Petroleum Hydrocarbons (TPH), VOCs, SVOCs, CCR Title 22 metals, organochlorine pesticides, PCBs, pentachlorophenol, creosote, formaldehyde, xylene, benzene, toluene, 2,4-D , DDT / DDE, glyphosate, atrazine, ARSENIC, lead, fluoride, HEXAVALENT CHROMIUM, cadmium, chromium, chromium-6, chromium-12, perchlorate, TCE, Tetrachloroethene, PCE, diesel constituents and breakdown products, as well as for substances one might find from a color and dye company and from a dry-cleaning company once on the site.

In addition, test for these components and/or breakdown products of diesel. I note that Table 1: Substances in Diesel Exhaust Listed by Cal EPA as Toxic Air Contaminants mentions these: acetaldehyde; acrolein; aniline; antimony compounds; arsenic; benzene; beryllium compounds; biphenyl; bis[2-ehtylhexyl)phthalate; 1,3-butadiene; cadmium; chlorine; chlorobenzene; chromium compounds; cobalt compounds; creosol isomers; cyanide compounds; dibutylphthalate; dioxins and dibenzofurans; ethyl benzene; formaldehyde; inorganic lead; manganese compounds; mercury compounds; methanol; mehtyl ethyl ketone; naphthalene; nickel; 4-nitrobiphenyl; phenol; phosphorus; polycyclic organic matter, including polycyclic aromatic hydrocarbons (PAHs) and their derivatives; propionaldehyde; selenium compounds; styrene; toluene; xylene isomers and mixtures; o-sylenes; m-xylenes; and p-xylenes. Please test for some of these components of diesel emissions in soil at various sites throughout the approximately 14 acres.

Some review of the earlier documentation indicated that certain substances were found at levels of concern.

Seeing that an AQMD official or staffer advised that the earlier incarnation of this proposed development be mitigated by having a ramp for traffic to travel all the way from the 41st and Alameda site up to the Santa Monica Freeway, does it sound like the AQMD considers this fairly similar development (except on even more of the site) of regional significance?

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Let me quote three paragraphs which are the third to fifth paragraphs under "Background" which is beneath "1. Introduction". The third paragraph reads: "At least five phases of environmental soil investigation has been conducted on the Property with testing for total petroleum hydrocarbons TPH), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), metals, hexavalent chromium, organochlorine pesticides, polychlorinated biphenyls (PCBs) and herbicides. No significant concentrations were detected for most of these chemicals of potential concern.

However, elevated concentrations of certain metals were detected in a limited number of samples, but in no discernable pattern. A limited risk assessment addressed the 'elevated' arsenic concentrations and concluded that the risk from arsenic did not require remediation or mitigation measures beyond what would normally be appropriate for construction sites. It has been further concluded that additional characterization of the soil for metals may be warranted if the Property were to be used for residential purposes, or soils were to be removed from the Property.

In addition, low concentrations of VOCs were identified in scattered soil samples in earlier investigations. No soil vapor assessment has been conducted on the Property to date. Consequently, it is not clear whether these VOC detections resulted from small release incidents or are indicative of a wider, more significant problem. A comprehensive Property-wide soil vapor assessment was recommended."

Let us re-examine the earlier sentence (3 paragraphs up) that says: "No significant concentrations were detected for most of these chemicals of potential concern." This is an unusual way of saying the site is doing alright in regards to its contamination by "most" chemicals, but it does not state clearly which precise substances were tested that were found beyond regulatory levels.

Are all the substances that exceeded regulatory levels mentioned in the first paragraph (immediately below the line of asterisks) or in the following paragraph (arsenic and perhaps other metals)? Please clearly state which toxic materials were found at the site which exceeded the "usual" regulatory level. Please also make another distinction -- that would be how many (and identify) the toxic materials that would need remediation if the site was to host residences (or if soil was to be removed from the site). There are repeated references (especially by SCS Engineers reports) that a number of toxic materials are too high if the area was to be residential, but apparently a fairly high toxic material level is acceptable if a site is merely a "construction" or "industrial" site. Is part of this logic that people may well spend over half their 24-hour day at their residence, but spend closer to 8 or 9 hours at their workplace? However, sweat-shops are known for long hours. Should hours of a worker at the 41st and Alameda site be limited so that they do not receive excessive exposure from toxic materials lurking in the soil? Please explain. Also explain how much soil would need to be "removed" from the site in order to trigger a more thorough investigation and remediation of such toxic substances. Are there plans for the removal of any soil from the 41st and Alameda site? Explain…

I will now quote the "5 REGULATORY LIMITS" portion of the March 2011 soil vapor study by SCS Engineers: "The California EPA Office of Environmental Health Hazard Assessment (OEHHA) published the Human-Exposure-Based Screening Numbers Developed to Aid Estimation of Cleanup Costs for Contaminated Soil, dated November 2004, revised January 2005. Within this document, California Human Health Screening Levels, or CHHSLs, were developed for certain VOCs in soil gas at 5 feet below buildings for vapor intrusion into structures under residential and industrial / commercial land use scenarios. The CHHSLs are based on general assumptions regarding soils and buildings at VOC-impacted sites, the chemical characteristics of various VOCs, and potential health risks. The OEHHA guidance states that CHHSLs are 'useful to get a general understanding of potential problems with a site, but cannot be used to assess actual health risks.' Further, OEHHA has stated that CHHSLs have 'no regulatory effect, and have been published solely as a reference value that may be used by citizen groups, community organizations, property owners, developers, and local government officials to estimate the degree of effort that may be necessary to remediate a property.'

The VOCs detected in vapor samples collected from the Property may be compared to the CHHSLs (if any) listed at the bottom of Table 1. Of the samples collected at 5 feet bgs, two contained PCE (SV2-5' and SV6-5') above its commercial/industrial CHHSL of 0.603 ug/L. The remaining concentrations of PCE and other VOCs were below theoir respective commercial/industrial CHHSLs, if any."

First, explain PCE once more. One of the documents calls Tetrachloroethene "PCE", even though it seems like PCE would have penta or a per (rather than tetra) beginning the chemical name. But then I notice in the June 2013 SCS document that says PCE is actually "perchloroethene." Please alleviate any confusion regarding this alphabet soup matter.

It sounds like the CHHSLs is a basic reference which cannot be relied upon to properly assess health risks (whether it be for residential, construction, or industrial / commercial property). Would not the "precautionary principle" dictate that there needs to be a "real" health assessment with a firmer testing and remediation regimen, rather than some toothless general references? Are sweatshop workers, truckers, and construction workers expendable, or can they handle a higher toxic load? Explain thoroughly in the EIR.

It is vital to point out (as it was in the last paragraph under "6 SUMMARY AND FINDINGS") that "there has been no regulatory involvement or oversight of the investigations to date." Later in that paragraph from a SCS report, it says that "There is a possibility that regulatory agencies, upon review of this report, would require further investigation to confirm findings of this investigation and the vertical extent of VOCs in the soil. In addition, if the Property is to be developed for residential use, additional investigation or a health risk assessment may be warranted."

If a formal "health risk assessment" was undertaken, would that follow certain guidelines set forth by certain agencies? It also appears that one of the further investigations (and related sampling) needed pertain to the need for sampling at varying depths in order to gauge the vertical extent of VOCs in the soil.

I want to point out some "Data Gaps" which were admitted on pages v and vi of the SCS Engineers' June 2013 Phase I Environmental Assessment. Gaps are admitted in "individual parcel histories", and it is admitted that: "In light of the industrial usage of much of the Property, this is a potentially significant data gap." It is furthermore pointed out that much of the industrial activity on this site existed when there was little or no regulatory oversight of toxic materials. "Consequently, there are no records of hazardous material use or management. This is a potentially significant data gap."

Since there are admitted data gaps and uncertainties regarding extent of contamination, let us choose the side of caution and do thorough sampling for the substances which I have already mentioned in this scoping comment. The Alameda / Central neighborhood is already essentially a "sacrifice area". -- note that there is no admission in the record that there are actual residents in the neighborhood (either the quite immediate area to the south of 41st St. and east of Long Beach Ave.), but even no admission that residents exist in the quite populated area west of Long Beach Ave.

As an indication that the Alameda / Central neighborhood is essentially a "sacrifice area", I note that there are 11 hazardous waste sites (called US EPAHazardous Waste Generators) within a quarter mile of the 41st and Alameda site (see page 18 of SCS June 2013 report). This shows that the neighborhood is already overburdened with toxic materials and industry -- this must be part of a thorough Environmental Justice analysis on the proposed project.

The CUMULATIVE IMPACT of all the historic hazardous materials activities on the 41st and Alameda site, continued exposure to such materials on-site, combined with excessive air pollutants from industry in the region (including the nearby hazardous waste generators as well as the Exide battery facility in Vernon), combined with pollutants from nearby freeways and streets as well as from LAX-related air traffic (including the associated "fine particulates") combined with likely emissions from the project (in construction and operational phases) all need to be carefully evaluated.

By the way, what model will be used to predict emissions from construction activities on the 41st and Alameda site? How will NOX and "black carbon" be regulated as far as construction emissions at the site? Also, identify the VOC content of paint which may be used at this site. In regards to traffic, we need more detail on what trip generation assumptions are used to generate operational emissions from the project. As far as facility operation, will there be regulations pertaining to idling time for diesel trucks, or will cleaner trucks be considered since this area is already overburdened with toxic materials?

Apparently, mere sweatshop workers, groundskeepers, and truck-drivers do not deserve a level of remediation of the site that one would expect (and which may be legally mandated) if a residence or residences were planned on the property.

Lastly, I will mention that more things should have been checked on the checklist as applicable to this project -- though I mentioned it in earlier comments which will be scanned and sent in, so I will leave it be for now.

Keep me updated on any public scoping hearing, and in regards to all other aspects of the proposed development on the 41st and Alameda site -- now increasingly called the 4051 South Alameda Street Project.

Thank you for your consideration of this input and guidance.

Sincerely yours,

Bruce Campbell