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Email Opposing the Industrialization of SCF Farm

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Christina Toy Lee
Associate Zoning Administrator

200 N. Main St. 7th Floor
Los Angeles, CA 90012

Via email:

Re: Comments on the Case No. AA-2012-919-PMLA/Construction of Four Industrial Buildings

Dear Ms. Lee,

I am writing to voice our concern over the proposed construction of four industrial buildings at the site of the displaced South Central Farmers urban farm in reference to Case No. AA-2012-919-PMLA as noted above.

The Project contemplates the construction of a approximately 565,796 square feet of industrial buildings on the 10.04 acres of vacant land that was historically used as a community garden for residents of south central Los Angeles. These residents, mostly racial and ethnic minorities, suffer from a scarcity of open space and other environmental amenities that most middle-class Angelenos take for granted.

The destruction by bulldozers of the world-acclaimed South Central Farm and eviction of the farmers in July of 2006 marks the most controversial episode in the entire history of urban planning and land use decision-making in the Los Angeles-area. The decision to proceed with the destruction of the farm met with widespread, indeed global, condemnation of an act that displaced a rare and precious cultural and agroecological site of singular importance to the non-governmental and governmental agencies concerned with the future of our local food systems and more sustainable forms of urban inhabitation and land use.

It is our reasoned and expert opinion that the CEQA requires the City of Los Angeles to analyze all projects that have the potential to cause significant environmental impacts and to mitigate all significant impacts to the maximum extent feasible. A Mitigated Negative Declaration (“MND”) may be adopted when “the initial study [“IS”] has identified potentially significant effects on the environment” that “would avoid the effects or mitigate the effects to a point where clearly no significant effect on the environment would occur…” (Pub. Res. Code § 21064.5). The minimal impact threshold has not been met and the current IS and MND fails to adequately identify the full range of significant impacts emanating from the Industrial Project and further fails to mitigate those impacts to below significance. The MND is improper and also violates the spirit and intent of the federal and California Principles of Environmental Justice since this is a community that already faces disparate adverse impacts from industrial facilities, hazardous sites, and a lack of public open space.

A CEQA review document “must include detail sufficient to enable those who did not participate in its preparation to understand and to consider meaningfully the issues raised by the proposed project.” Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 405. The Project’s MND fails to specify what the project actually is, which is a fatal flaw under CEQA. An “accurate, stable, and finite project description is the sine qua non of an informative and legally sufficient” environmental review document. San Joaquin Raptor Rescue Center v. County of Merced (2007) 149 Cal.App.4th 645, 655, quoting County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185, 193. Accordingly, the MND fails at this most basic level as an adequate informational disclosure document.


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