Northwest San Pedro Neighborhood Council

January 23, 2007

Ms. Anita Bizell

Assistant Planner

Los Angeles City Planning Department

200 North Spring St.

Los Angeles, CA  90012

Subject:           Draft Mitigated Negative Declaration Environmental Document

                        Enviro-2006-4640-MND

                        Proposed Target Retail Store

                        1605-1701 North Gaffey Street

                        San Pedro, California

Dear Ms. Bizell:

The Northwest San Pedro Neighborhood Council (NWSPNC) provides the following comments to the Draft Mitigated Negative Declaration (MND) for the proposed Target Retail Store at 1605-1701 North Gaffey Street, San Pedro, California.    Members of our Council met with Target and reviewed the draft MND for the proposed project.   At our meeting on January 22, 2007 the Council adopted the enclosed comments.

Our primary concerns since the inception of this proposed project have been concentrated in the areas of general aesthetics, traffic, and concern for residents in adjacent housing.  We are also concerned about the 5000 sq. ft. pad designated for retail purposes unrelated to the proposed Target Store.

Having studied the draft document, we have found the MND inadequate and insufficient in its evaluation of impacts and presentation of data.  Basic mitigation for loss of community open space, construction emissions, and other impacts from the project were not evaluated or were glossed over to meet the criteria of a MND. MND is wholly deficient, and either needs to be redone or a complete Environmental Impact Statement should be prepared.  Our specific comments on the MND are attached hereto.

Thank you for this opportunity to submit our comments and concerns.  Please feel free to contact Dan Dixon, the chair of our Land Use Committee, at 310-259-2928 if you have any questions.

Very truly yours,

Diana Nave, President

ATTACHMENT BELOW:

Northwest San Pedro Neighborhood Council

Draft Mitigated Negative Declaration Environmental Document

Enviro-2006-4640-MND

Proposed Target Retail Store

1605-1701 North Gaffey Street

General Comments on the Proposed Project

The project proponent is requesting variances or conditional use permits for the following items we find unacceptable:

1)      Sale of beer and wine.

2)      Reduction of ground floor exterior walls and doors containing only 30% transparent windows

3)      Trash storage that is not gated, enclosed and covered.

4)      Truck deliveries between 4:00pm and 10:00pm Monday through Sunday

5)      Store operations hours as late as 12:00pm and as early as 7:00am

In general the MND has failed to show that these, and other items discussed below, can be mitigated through revisions to the project.  Frankly it is hard to see where any revisions to the project have been made to support any mitigation.  As a general observation it appears that the project proponent has offered only the minimum mitigations for a project which will have tremendous impacts on the neighboring community and on San Pedro as a whole.

Additionally, the City should require that Target use union labor with local hiring provisions, local contractors, and local vendors.

Aesthetics—General

We applaud the improvement in the façade of the building between the Pre-application Submittal and the Planning Application, but as this project is a multi-generation addition to the neighborhood. Community input on the final design of the building is essential for community support of the project.

The same input is needed for the landscape design of the project.  The boxed trees indicated in the Initial Study and Checklist submitted to the City may not be sufficiently large to mitigate the mass of the building in a timely manner, meaning two to three years.  Landscaped berms reducing the view of the parking lot from Capitol and Gaffey would be highly desirable, and are in fact essential on the Capitol Dr. side of the property, which is primarily an entrance to a residential neighborhood.

The community does not want a repeat of the sterile, uninviting Home Depot Store at the corner of Westmont Dr. and Gaffey St. 

A 30 ft. pylon sign on the Gaffey St. side is unacceptable aesthetically, and would not enjoy particular visibility in the area surrounding the store, or on Gaffey St.  There would be no visibility from the freeway.  A sign no more than two-thirds the height of the roofline of the building would be acceptable.  The 10 foot sign proposed on the Capitol Dr. side is acceptable.                             

The blank side of the Target building fronting on Gaffey St. is unpalatable, and not in concert with improving the community.  An artscape should be required on the Gaffey side of the building as aesthetic mitigation. The community should be involved in the selection of an appropriate artscape.

Aesthetic mitigation should also include a firm commitment by Target Corp. to “police” its own property, not only in terms of physical security, but with respect to litter and graffiti occurring on the property,  both of which are common in the greater Harbor area,  “Large box retailers” present an easy opportunity for both problems to proliferate.  Target should work diligently and daily to keep its property neat and, it is hoped, beautiful.

A system to deter removal of shopping carts from the Target property is essential, however knowing that no system will prevent the removal of all carts, retrieval of carts from the surrounding neighborhood should be performed on a daily basis.

The height of the retaining wall on the west side of the property should be determined in consultation with homeowners on the east side of Barrywood Ave.

The same consultation should be undertaken with respect to the location of the building on the property.  It is unfair to impose a 26 ft. structure so close to the neighbors’ property as to present a massive blank wall as their only rear facing view.  “Stepping” or tiering the height of the building along the west side should be studied.

Section I. c. Aesthetics

The aesthetic loss of three baseball fields and the open space available to the community is not discussed or evaluated.  The loss of this open space is to be mitigated by landscaping in a parking lot for 549 cars, a buffer required by city code, and anti-graffiti measures.  The loss of the three baseball fields is a significant impact that cannot be mitigated through the inadequate measures listed above.  The evaluation needs to include a discussion of the how the character of the site will change, and how its impact on the surrounding residential area will change.  Measures that include the construction and support of a similar amount of open space at another location in San Pedro should be included.  In addition, as a mitigation to the loss of open space the project should be required to install a curb, gutter and sidewalk on the east side of Gaffey  Street the complete length of the property.

Section I. d. Aesthetics

The site of the proposed project, both during operation of the bakery and currently, has a limited number of lights in the area of the existing 110,000 square foot building., and there are no lights in the area of the baseball fields.  This current situation contrasts starkly to the 24 hour lighting proposed throughout the 549 space parking lot proposed by Target. This is a significant impact that is not mitigated through the use of light shields. 

The MND says that the lighting shall “be designed and installed with shielding, so that the light source cannot be seen from adjacent properties.”   The adjacent neighbors should see a test demonstration of such lighting on the property before any exterior lighting is installed.  Dark Skies International, Tucson, AZ, is a possible reference for non-intrusive lighting.  This project imposes new and significant night light pollution in a harbor area already approaching twilight light conditions throughout the night due to container terminal operations east of the adjacent 110 Freeway.  This issue demands serious mitigation efforts.

Section IV.B Air Quality (Earthwork/Grading/Short-Term Construction)

The developer did not evaluate construction emissions including, PM₁₀, and PM_2.5, emissions as part of the MND.

• The MND needs to include a discussion of PM₁₀, and PM_2.5 emissions from construction.   The South Coast Air Quality Management District has evaluated and proposed adoption of a PM_2.5 threshold, and has thresholds for emission from construction equipment.  These proposed thresholds need to be evaluated and included as part of the MND, along with appropriate mitigations.

• The MND does not include mitigations from construction equipment that include use of late model equipment, use of “low-emission diesel fuel”, and utilization of alternative fuel powered construction equipment.   The MND needs to include a provision that construction equipment will use diesel fuel that containing no more that 15 parts per million of Sulfur by weight.  This requirement should extend to all equipment used during construction so that diesel particulate filters can be used during construction.  The inclusion of diesel particulate filters as a mitigation measure needs to be part of the MND.  The MND should not have any caveats that allow the project proponent to utilize equipment that does meet emission reduction goals outlined above and below.

•  The MND needs require all subcontractors using diesel powered equipment to:
• Use ultra low sulfur diesel fuel for all equipment used on site
• Use of ultra low sulfur diesel for all on road equipment (trucks)
• Use diesel particulate filters on all construction equipment                                       
• Use of alternative fuel construction equipment for all equipment including fork lifts, scissor lifts, and other small duty equipment.  
• Use of temporary electrical power throughout the construction area to reduce the use of generators.
• Use late model heavy duty diesel powered equipment
• Use equipment that meets or exceeds the 2001 CARB adopted emission standards for 2007+ on road heavy duty vehicles (USEPA emission standards)
• The DEIR needs to discuss in greater detail the USEPA Emission standards for 2007+ on road heavy duty vehicles and how the project will work to comply with this requirement.  At a minimum the project should comply with the USEPA 2004 Emission standards for on road heavy duty equipment. 

• The MND needs to evaluate emissions using CARB’s latest health risk estimates in conjunction with the Port of Los Angeles port wide health risk analysis currently underway.  The MND did not discuss the cumulative impact of the proposed projects emissions relative to the Port of Los Angeles baseline and SCAQMD MATES II study.
• The MND should include a description of how the project proponent will monitor and detail the use of the emission control technologies listed above.  This shall include written documentation of all equipment used, hours of operation, type fuel used, emissions control technologies used, alternative fuels used,  engine maintenance history, and engine and other equipment specifications.
• The Air Quality section does not appear to have evaluated impact from workers commuting to the site.  A discussion of the number of workers and the subsequent impact from traffic and air quality needs to occur within the MND.
• Workers at the site should be encouraged to car pool and use public transportation when commuting to the project site.
• During operation on-road trucks that meet the USEPA’s 2007 on road emission standards should be used. 
• Delivery trucks should not be allowed to idle during deliveries for longer than five minutes.
• Dust mitigation during construction is not described in enough detail.  The project proponent needs to include the following during grading, soil excavation, soil removal and delivery, and compaction.
• Compliance with all South Coast Air Quality Management District Requirements
• Monitoring for dust at the property line (using fixed stations on a set schedule) during all earthwork
• Covering of all soil stockpiles and working faces during periods of inactivity longer than 30 minutes
• Use of dust mitigation measures such as water misting to reduce dust during loading, grading, delivery and compaction as frequently as needed
• Collection of wind speed and wind direction data during all earthwork activity
• Stopping of all earthwork during wind gusts of 15 mph, and a sustained wind speed of 25 mph
• Submission of all dust monitoring data (dust concentrations, wind speed, wind direction, hours of activity, etc) to the SCAQMD to document compliance
• Stoppage of all earthwork should hydrocarbons or other contaminates in soil be detected or observed.
• Documentation that all soil imported to the project site is contaminate free
• All trucks shall be cleaned of any soil on the outside of vehicle before exiting the site

Air Quality (Stationary)

The project does not discuss the use of green building materials to reduce the use of electricity and other energy sources during operation.  The project should include a discussion of how the new building and area will use the most energy efficient materials.  The use of LEEDS certified materials should be required.

Hydrology and Water Quality (VIII.)

• The MND does not discuss the recently approved Integrated Resource Plan (IRP) adopted by the City of Los Angeles.  A discussion should be included of how the project will comply with the IRP during construction and after completion.

• The MND needs to expand its discussion of urban runoff.  This discussion needs to include an analysis of the two main sources of water into the storm drain system (dry weather urban runoff and wet weather runoff).

• To reduce the amount of dry weather urban runoff from the completed project the MND needs to include a discussion of how water originating from human activities, landscape irrigation, street washing, etc. entering the storm drain system will be reduced.  Dry weather urban runoff can contain high levels of pollutants that would enter the storm drain system and eventually marine waters.

• To reduce the volume of dry weather runoff the project should include the ability for dry weather diversion to the waste water collection system and eventual treatment at the Terminal Island Treatment Plant. 

• To MND did not evaluate or consider construction materials that could reduce the volume of wet weather urban runoff that would occur. 

• The MND should evaluate the use of porous concrete, cisterns, bio swales, and storm water reduction methods.  Cisterns should be considered as part the project to provide for storage of storm water for later use in landscape irrigation. 
  
  
• Storm water infiltration beneath the proposed parking lot could be stored for and possibly used by the nearby Harbor Highlands Park.  The evaluation of the storage for storm water beneath the parking lot area for later use should be evaluated as part of this project.

• Storm water entering Capitol Drive should be directed to a new subsurface culvert system not discharged to the street. During large storm events storm water from adjacent areas floods the two storm drain box culverts at Capitol and Gaffey.  The parking lot area will generate more storm water then the current baseball fields.  To ensure that the additional volume of water from the new parking lot does not contribute to flooding during large storm water events the discharge needs to done via subsurface piping and connections to the existing storm drain system. 

• Use of street sweeping and other measures on a regular basis to reduce trash and other debris from entering the storm drain system

• Installation of TMDL traps or other equipment to remove debris (trash, paper, plastic, bottles, etc.) within the two existing storm drain culverts in Capitol Dr. and Gaffey.

Land Use

Between Pre-Application Submittal and Planning Application, developer has added a 5,000 sq. ft. separate development, apparently intended to be sublet to a different retailer, at the corner of Gaffey St. and Capitol Dr.  We find this change unacceptable, because of a dramatic increase in traffic attempting to enter and exit close to that corner for access to the business.  We also object aesthetically because of additional signage, and a general disruption of the purpose of the Target property and the flow of landscaping which is needed to reduce the “warehouse” feel of the Target Store, and which works against our community’s desire to create a more, rather than less, coherent feel to N. Gaffey St.  ANY consideration of this usage as part of the development plan should require a separate CEQA study, and a separate traffic study, as this addition to the project plan and its attendant additional traffic burden on the community was not covered by the applicant’s initial traffic study.

The 5,000 sq. ft. should instead be distributed to add an additional five feet of berm depth between the sidewalk and the parking lot along the length of the property.

Increased Noise (XI a11)

The proposed landscape buffer, five feet, and 6-foot high solid decorative wall will be inadequate to reduce noise from air conditioning and other equipment placed on the roof. 

This equipment will be above the level of the 6-foot high wall and will directly impact the adjacent residents.  The MND needs to include a study of potential sound impacts from the operation of equipment on the roof of the proposed building.  At a minimum, mitigations should include limiting the hours of air condition operation and shielding to reduce the noise from store operations at night to less than 50 decibels.  Installation of insulated windows within the adjacent properties should be considered as a mitigation measure to reduce noise impacts.   

To further reduce impacts due to noise and general operation of the Target store, high oxygen producing trees should be placed between the store and adjacent residential homes.  If possible, high oxygen producing trees should be used throughout the project.

Solid Waste (XVI f.)

• The MND does not discuss in great enough detail how solid waste generated during construction will be recycled.  The reuse of concrete and other material from the site as aggregate was not discussed or evaluated.   The project should evaluate the use of a rock crusher to create aggregate for use within the development and to reduce the volume of material being disposed at Class III landfills.
• The solid waste section discusses the transport of solid waste to Class III landfills outside the area.  Given the distance of these landfills from the project site it is necessary for the project to ensure that all on-road vehicles meet the air quality standards discussed above, and to reduce the volume of material (and truck trips) through recycling.

Transportation/Circulation (Traffic)

The MND did not perform an adequate traffic analysis.  The use of the current site is not, nor was it ever, comparable to the proposed land use; therefore the impact to traffic along Gaffey and Capitol will be significant, and not easily mitigated.

The Target store will be the only “large box” retailer in the San Pedro/Wilmington area.  It is potentially a huge magnet for customers from not only San Pedro and Wilmington, but Harbor City, Lomita, Rancho Palos Verdes, and Rolling Hills Estates.  The developer’s traffic study includes only twelve local intersections, far fewer than other developers’ studies for projects generating many fewer day trips.  Although Target will attract many out-of-town vehicle trips, intersections in adjacent jurisdictions are not included, specifically Harbor City, Wilmington, Lomita, and Rancho Palos Verdes.  5,610 daily trips is a vast increase in usage on all the surrounding streets and connector streets to other customer-base living areas.  We question whether 5,610 trips per day are realistic and whether 549 parking spaces are adequate.  Both of these numbers require further study.

The traffic study does not include in its counts any consideration of Gatun St., south of Capitol Dr., a primary “stress reliever” alternate to the intersection of Capitol and Gaffey.  The Neighborhood Council has requested traffic calming measures on Gatun.  Any reduction of cut-through traffic on Gatun will immediately translate to more traffic at the Capitol/Gaffey intersection.  Based on a traffic study by another developer, the number of “cut-through” left turns on Gatun during p.m. peak hours is almost as great as the number of left turns from Gaffey onto Capitol.

The developer is relying primarily, if not entirely, on contributing to ATSAC/ATCS installations at intersections in the area.  We firmly assert that an ATSAC contribution is not at all sufficient to mitigate even partially the impact of 5,600 additional vehicle trips per day.  

Other traffic mitigation considerations should include: 

·        Installation of traffic control at the Gaffey St. entrance.  This entrance should include a traffic signal that includes the following:  

o        A double left turn lane from northbound Gaffey to the Target. 

o       Signalization to be coordinated or linked to the intersection of Capitol and Gaffey.

·        A double left turn lane northbound on Gaffey at Capitol.  

·        Addition of right turn lane into the Target Store from westbound Capital (this lane is in addition to the two west and two east lanes currently in use).

·        Pedestrian crosswalks on Gaffey at Capitol, and at any new light on Gaffey St.

·        Limiting of traffic exiting onto Capitol to right turns only.

·         “No parking” designations at curb on Capitol Dr. side of property.

·        A substantial contribution to capital improvements at “Five Points” and at Gaffey and Channel.

·        A substantial contribution to the extension of DASH service from downtown San Pedro to the new Target property.

As ATSAC/ATCS installations at affected intersections ARE a partial tool in traffic mitigation, construction of project should not begin until ATSAC/ATCS implementation is complete.

Developer should provide new curbs, gutters and sidewalks on east side of Gaffey St. contiguous with the length of the property.  Increased traffic flow will make the practice of large trucks parking on the east side of Gaffey unacceptably dangerous.  Only a marked curb will provide real mitigation, and a sidewalk is clearly in harmony with the neighborhood effort to make Gaffey more pedestrian-friendly.

Cc:       Mr. Jim Tokunaga, Senior City Planner

            Ms. Conni Pallini-Tipton, Associate Planner, San Pedro

            Councilwoman Janice Hahn

            Mr. Frank Hong, Office of Councilwoman Hahn