Page 5 - northlake_appeal_20180423

Jodie Sackett, County of Los Angeles
June 16, 2017
Page 3

Again, with regard to putting a school in the middle of "Light Industrial" development, you
should specify what "Light Industrial" uses are permitted under the zoning code in the DEIR in
order to comply with CEQA's mandates of full disclosure, and this is not good planning.

At 4-23, under "Sustainable Features," as to "Water Conservation," you claim that you are going
to use "gray water systems." Where? Gray water systems are for the use of water previously
used in the home by for example a dishwasher or clothes washer, and they are not the same as
using recycled water.

Under "Construction Waste Reduction, Disposal and Recycling," you indicate that there will be
75% reuse or recycling of all waste by 2020. How does the Project propose to implement this?
There are no specifics to give the public confidence that this will occur.

Under "Additional Project Design Features," you state the Project will install "the equivalent of'
3 kW solar panel systems for 50% of the residential dwelling units. Is this also for Phase 2?
What does "the equivalent of' mean?

You also assert that the Project will install at least 135 EV chargers at nonresidential parking
spaces, "Assumed to be Level 2." Level 2 should be required.

As to "Project TDM Features," you assert "Expanding the local transit network by adding to the
existing transit service to enhance the service near the Project sites." The applicant and the
County do not directly have authority to do this. What have you done to implement it? You also
promise "Providing shuttles to major employment centers." On what basis? Is the developer
going to pay for this? For how long? Which "major employment centers?" Until credible
details are provided, this is a hollow promise which does not provide substantial evidence for any
reduced impacts on traffic or air quality.

Air Quality

As a preliminary matter, while you assert that you have done a health risk assessment with
respect to diesel particulate matter from construction on the site for adjacent residents, you have
not conducted a health risk assessment from the existing school site from exposure to industrial
pollutants from the 13 .9 acres of industrial use that are to surround it. It is our position that the
DEIR should have been circulated to all parents or potential future parents of students of the
Elementary School under Health & Safety Code § 42301.6(a); while specific uses are at this time
unspecified it is entirely within our anticipation, and it should be within yours, that logistics
centers emitting diesel particulate matter ("DPM") or other hazardous air pollutants or toxic air
contaminants will be sited within 1,000 feet of the school since you have zoned the entire area
industrial. The fact that industrial uses "would be required to meet all applicable air emission
standards" does not absolve you of evaluating the risk factors to present or future students.