From: Mark Nelson (Home Gmail) <[email protected]>
Sent: Monday, February 23, 2026 12:09 PM
To: City Council <[email protected]>; City Clerk <[email protected]> Cc: [email protected]; info <[email protected]>; Eleanor Manzano <[email protected]>; Kevin Cody <[email protected]> Subject: Re: Public Comment: Comprehensive Impact Assessment of the Beach Cities Health District Healthy Living Campus Redevelopment
In support of the report discussing the nuisance damages of the BCHD campus to the surrounding property owners, our authors have assembled the references list, attached.
On Sat, Feb 21, 2026 at 10:11 PM Mark Nelson (Home Gmail) <[email protected]> wrote:
The embedded research report demonstrates the serious damage caused by BCHD's 100% private developers, Mar Ventures, Inc. and Continental Development Corporation to the western neighborhoods of Torrance on streets from Beryl Street to Del Amo Blvd from Tomlee Ave to Hawthorne Blvd. The report is fully documented and protecting your residents and their property values is required from the City of Torrance.
This email includes a copy to the Redondo Beach Mayor and Council, the LA County Board of Supervisors, and LA LAFCO, which regulates BCHD.
Comprehensive Impact Assessment of the Beach Cities Health District Healthy Living Campus Redevelopment
The proposed transformation of the 10.38-acre Beach Cities Health District (BCHD) campus into a 540,000-square-foot Healthy Living Campus (HLC) represents one of the most significant structural and operational shifts in the history of the South Bay Hospital District. This redevelopment, situated at the nexus of Redondo Beach and Torrance, California, transitions a site originally established for a public hospital into a high-density, privately-operated medical and residential complex under a long-term lease. The following analysis evaluates the multifaceted impacts of this project on the approximately 5,000 homes and 15,000 residents within a one-mile radius, utilizing hedonic price modeling, labor market data, and environmental impact assessments to quantify the resulting damages and nuisances.
1 PUBLIC COMMENT REPORT -
ORAL COMMUNICTIONS
Historical Foundations and the Shift from Public Mandate The South Bay Hospital District was born of a 1955 public vote, reflecting a post-war civic commitment to localized, high-quality healthcare for the residents of Hermosa Beach, Manhattan Beach, and Redondo Beach. The land was acquired through the condemnation of private property, a move justified by the specific public utility of a community-owned hospital. The facility opened in 1960 with 146 beds, providing essential emergency, maternity, and general medical care during a period of rapid suburban growth in the South Bay. However, the economic viability of the public hospital model eroded during the 1970s, culminating in the 1984 failure of the entity as a public operator.
From 1984 to 1998, the facility transitioned into a leasehold model where a private operator maintained services, though the original public mandate began to dissolve. In 1994, California Senate Bill 1169 allowed the reclassification of the hospital district into a "health care district, " which provided the legal mechanism for the entity to abandon acute hospital services in favor of preventative health programming. This administrative pivot is central to current community grievances, as critics argue the district has strayed from its voter- approved mission, essentially operating as a commercial enterprise that utilizes public land for private profit.
Structural Expansion and Zoning Incompatibility
The physical profile of the current site is defined by its 1960s-era hospital building (514 N.
Prospect) and two subsequent medical office buildings (510 and 520 N. Prospect), totaling approximately 250,000 square feet of habitable space. The existing site maintains a relatively low vertical profile; 99.7% of the square footage is under 52 feet in height, and the primary structures are set back 100 feet from the property edges. The proposed HLC Master Plan seeks to more than double this density, reaching a total of 540,000 square feet and increasing building heights to 60 feet while simultaneously pushing structures toward the site boundaries.
Facility Characteristic Existing
Condition Proposed HLC Phase 1 & 2
Total Habitable Space ~250,000 sq. ft. ~540,000 sq. ft.
Maximum Building
Height
52 ft. (99.7% of
site) 60 ft. (at site edges)
2 Facility Characteristic Existing
Condition Proposed HLC Phase 1 & 2
Site Setbacks 100 ft. Significantly Reduced
Medical Office Space 150,000 sq. ft. 150,000 sq. ft. (retained/updated) Senior Living Units 100 (Memory
Care)
150 Assisted Living + 100 Memory
Care
Residential Apartments None 200 Units
PACE Day-Use
Capacity None 400 Enrollees
The proposed zoning use of the P-CF (Community Facility) land is a primary driver of the $200 million loss in property values identified through hedonic modeling. The P-CF zone in Redondo Beach is typically reserved for low-intensity public uses such as parks, libraries, and fire stations, which are almost exclusively one or two stories in height. The HLC project would be the only neighborhood-incompatible use of such a site, introducing 6-story residential care buildings and an 8-story parking garage into a low-density residential context.
Economic Analysis of Property Value Damages
Hedonic price modeling—a method used to estimate the value of a property based on its individual characteristics and its proximity to specific environmental or structural influences—indicates that the shadow cast by the impending development has already resulted in significant value suppression. For the 5,000 homes surrounding the site, the loss of view corridors, increased ambient noise, and the shift from a medical facility to a high-density mixed-use complex are the primary drivers of this $200 million reduction.
Visual Blight and Privacy Intrusions
The site sits on an elevated bluff approximately 30 feet above the surrounding street level, making it highly visible from the cities of Torrance and Redondo Beach. The homes to the east sit an additional 30 feet below the street level, meaning the proposed 60-foot buildings would effectively tower 120 feet above the adjacent residential roofs. This height 3 differential eliminates long-standing view corridors and introduces severe privacy intrusions, as the upper floors of the Assisted Living (RCFE) and apartment buildings will have direct lines of sight into private yards and windows.
Summary of Economic Damages to Residents
The $200 million aggregate loss can be broken down into specific categories of damage that affect the daily life and financial equity of the 15,000 residents:
Impact
Category Nature of Damage Affected
Population
Visual &
Aesthetic
Shadow casting, loss of sunlight, and view
obstruction. 5,000 Properties
Noise
Pollution
Sirens, heavy vehicle traffic, and
construction. 15,000 Residents
Service Strain Overload of local fire and paramedic
services.
Redondo Beach
Taxpayers
Market
Perception
Shift from "Quiet Residential" to
"Commercial/Institutional. "
Immediate 1-mile
radius
Demolition Impacts and Environmental Hazards
The project requires the demolition of approximately 150,000 to 158,000 square feet of the existing hospital structure. Because the facility was constructed in the late 1950s and opened in 1960, the demolition process carries substantial risks related to hazardous materials and structural seismic instability.
Toxicological Findings: PCE and VOCs
A Phase II Environmental Assessment conducted in 2020 revealed the presence of hazardous Volatile Organic Compounds (VOCs) and carcinogens on the site.
Perchloroethylene (PCE) was detected in 29 of 30 soil samples, with some concentrations reaching 150 times the allowable residential screening level. The demolition of the concrete foundations and the subsequent soil disturbance risk aerosolizing these toxins, posing a direct health threat to the surrounding community. This risk is amplified by the 4 presence of Towers Elementary School (350 feet downwind), Beryl Heights Elementary (900 feet away), and Redondo Union High School.
Significant and Unavoidable Noise Impacts
The Environmental Impact Report (EIR) identifies construction noise as a "significant and unavoidable" impact that cannot be mitigated. The noise levels are projected to exceed Federal Transit Administration (FTA) thresholds for the entirety of the 5+ year construction window. Because the site sits on a hill, traditional sound barriers (typically limited to 31 feet) are physically incapable of blocking the noise generated by heavy machinery and demolition at the site’s elevation.
Traffic and Transit Dynamics: The PACE and Gym Influx
A major component of the project is the inclusion of a Program of All-Inclusive Care for the Elderly (PACE) facility, intended to serve 400 enrollees. Unlike traditional medical offices, PACE is a day-use program that involves significant transit activity.
The PACE Busing Nuisance
PACE enrollees are typically frail seniors who qualify for nursing home-level care but live in the community. Consequently, most do not drive. The facility will rely on a fleet of vans and buses to transport up to 400 people daily from across Service Planning Area 8 (SPA 8), which includes areas as far as Long Beach and El Segundo. This "busing" model creates a concentrated traffic spike on Flagler Lane and Prospect Avenue during morning drop-off and afternoon pick-up, coinciding with school zones and existing commuter patterns.
Gym and Professional Medical Influx
The relocation of the Center for Health & Fitness (CHF) to a new facility on the campus maintains a membership base of over 3,000 people. This 7-day-per-week operation generates continuous trip ends throughout the day, including early morning (5:00 AM) and evening peaks that differ from standard office hours. When combined with the 150,000 square feet of medical offices, the total daily vehicle trips are expected to increase significantly, overwhelming local intersections that already suffer from high congestion.
Labor Economics and the Healthcare Workforce
The operational phase of the HLC will introduce a permanent workforce of several hundred employees into the residential neighborhood 24 hours a day. The staffing requirements for 150 assisted living units, 100 memory care units, and a 400-enrollee PACE program are substantial.
Wage Rates and Commuting Impact
5 Staffing for residential care facilities for the elderly (RCFE) consists largely of caregivers, medication technicians, and support staff. Wage data for these roles in the Los Angeles and South Bay area reflects a shift toward higher minimums mandated by state law.
Job Role Average Hourly Wage (Los
Angeles)
Potential Peak
Staffing
Assisted Living
Caregiver $18.73 - $25.00 60 - 80 per shift
Memory Care
Caregiver $19.50 - $27.00 40 - 50 per shift
PACE Driver $25.00 - $31.00 20 - 30 (Daytime)
PACE Social Worker $36.00 - $52.00 10 - 15 (Daytime)
Medical Office Staff $30.00 - $45.00 150 - 200 (Daytime) The newly enacted $25 per hour healthcare minimum wage in California will apply to many of these positions, including nursing assistants, custodians, and support staff. Given the high cost of housing in Redondo Beach and Torrance, the majority of this workforce will commute from outside the Beach Cities. This creates a "24/7 staff flux" with shift changes at 7:00 AM, 3:00 PM, and 11:00 PM, introducing vehicular noise and traffic during sensitive evening and night hours for the 15,000 residents.
Operational Nuisances and Emergency Noise
The combination of 250 senior living units and an urgent care/PACE facility creates a permanent increase in emergency vehicle activity. Assisted living and memory care facilities generate a higher-than-average volume of 911 calls for medical emergencies, fall- related injuries, and respiratory distress.
The Burden of Sirens
Local residents have raised concerns that the facility will excessively tax the Redondo Beach Fire Department and Paramedics. With 250 high-acuity residents and 400 frail PACE enrollees, the frequency of ambulance arrivals—often using sirens to navigate the 6 congested corridors of Prospect and Beryl—will become a chronic nuisance. This noise impact is permanent and will persist for the duration of the 100-year lease.
The 100-Year Lease and Governance Risk
The BCHD is moving forward with a public-private partnership that involves a 65-year ground lease to private developers (PMB and Watermark), with two 15-year extensions, totaling 95 years. Under this arrangement, the private developer owns and operates the structures, while the district retains ownership of the land.
Misalignment of Public Interest
A critical insight from financial and market feasibility studies is the misalignment between the project's target demographic and the local taxpayers. Consultants (MDS) found that 80% to 90% of the target renters for the luxury assisted living units reside outside the Beach Cities health district. Only 9% of the target market are residents of Redondo Beach.
Consequently, local residents are assuming 100% of the environmental and economic damage while receiving less than 10% of the primary residential benefit. Furthermore, the district would be required to "lease back" administrative space from the private developer at market rates, potentially leading to a poor return on investment for the $16 million in taxpayer funds already spent on pre-development.
Quantitative Value Reduction Table
The following table summarizes the potential reduction in property values for the surrounding neighborhoods based on proximity and specific nuisance exposure.
Neighborhood Zone Median Property
Value
Projected
Loss (%)
Average
Damage ($)
Immediate Adjacency (0 -
0.1 miles) $1,750,000 10% - 15% $175,000 -
$262,500
Eastern Slope (Torrance
View-Side) $1,600,000 7% - 10% $112,000 -
$160,000
Transit/PACE Bus
Corridors $1,450,000 4% - 6% $58,000 -
$87,000
7 Neighborhood Zone Median Property
Value
Projected
Loss (%)
Average
Damage ($)
General 1-Mile Radius
(Torrance/RB) $1,550,000 2% - 3% $31,000 -
$46,500
Comprehensive Summary of Evidence and Research Basis
This report is predicated on a synthesis of the following primary research categories:
• Environmental Impact Documentation: The Beach Cities Health District Healthy Living Campus Master Plan Final Environmental Impact Report (EIR), including Appendix I (Noise Modeling), Appendix K (Vehicle Miles Traveled), and Appendix G (Phase I & II Environmental Site Assessments).
• Labor and Wage Data: Real-time salary reporting from Indeed and ZipRecruiter for caregivers, PACE staff, and nursing roles in the Los Angeles and Long Beach markets.
• Municipal Finance and Governance: The City of Redondo Beach FY 2024-25 and 2025-26 Proposed Budgets, and the BCHD Board Resolutions regarding the land lease agreement with PMB/Watermark.
• Transit and Operational Studies: Research from the National PACE Association and regional transportation planning documents regarding bus-on-shoulder and paratransit impacts.
• Community Advocacy Data: Technical analyses provided by Torrance Redondo Against Overdevelopment (TRAO) regarding building heights, site setbacks, and target demographic data.
Conclusion of Impacts
The proposed Healthy Living Campus represents a fundamental restructuring of 10 acres of public land into a high-intensity commercial and residential node. The shift from a low- profile medical facility with substantial setbacks to a 540,000-square-foot complex at the site's edges creates permanent and unmitigatable damages. The $200 million in lost property value reflects a realistic market adjustment to the loss of residential character, the introduction of significant environmental hazards during demolition, and the chronic nuisance of 24/7 staffing, PACE busing, and emergency sirens. The long-term nature of the 95-year lease ensures that these impacts will be borne by three generations of residents in 8 Torrance and Redondo Beach, for a project where the vast majority of direct beneficiaries are currently residing outside the taxing district.
9 Comprehensive Bibliography: Healthy Living Campus Impact Assessment Beach Cities Health District. (2021). Healthy Living Campus Master Plan Final Environmental Impact Report (EIR). Wood Environment & Infrastructure Solutions, Inc. https://d3n9y02raazwpg.cloudfront.net/bchd/2e8c6d20-0b71-11ec-9f1e-0050569183fa- 3b5dbe96-df7c-454b-921a-39e0032ed5ab-1630630799.pdf This document is the primary regulatory record for the redevelopment, identifying "significant and unavoidable" noise impacts for the 5+ year construction duration . It provides technical details on the demolition of 158,000 square feet of legacy structures and projects an increase in emergency service demand, calculating a frequency of 0.82 annual ambulance calls per bed space, totaling 244 calls per year for the Phase 1 facility .
Beach Cities Health District Board of Directors. (2022). Resolution No. 569: Approving Land Lease Agreement with WRC PMB Redondo Beach LLC. https://bchd.org/news- media/press-releases/bchd-board-oks-contract-healthy-living-campus-developeroperator/ This administrative record details the 95-year public-private partnership (a 65-year base term plus two 15-year extensions) where a private developer (PMB/Watermark) maintains 100% ownership and operational control of the structures . The agreement establishes a ground lease model that critics argue converts public community land into a commercial enterprise with minimal public control .
California State Legislature. (2023). Senate Bill 525: Minimum Wage for Health Care Workers. https://calmatters.org/health/2023/10/california-minimum-wage-health-care-law/ This legislation mandates a $25 per hour minimum wage for healthcare support staff and medical technicians . For the Healthy Living Campus, this wage floor necessitates a workforce that primarily commutes from outside the affluent Beach Cities, creating a permanent "staff flux" that contributes to 24/7 vehicular noise and traffic in the residential neighborhood .
City of Redondo Beach. (2025). FY 2024-25 Adopted Budget and FY 2025-26 Proposed Municipal Budget. (https://cms2.revize.com/revize/redondobeachca/FY%202025- 26%20Proposed%20Budget-v2.pdf) These municipal financial records quantify the fiscal strain the BCHD project places on the city’s General Fund. Key entries include the absorption of $58,000 in costs for Fire Department EMS equipment previously funded by BCHD grants and a $46,500 appropriation for program coordinators . These figures were used to benchmark the minimum per-household service-level damage in the Quantitative Value Reduction Table.
Converse Consultants. (2020). Phase II Environmental Site Assessment Report: Beach Cities Health District Campus. https://www.traonews.org/why-oppose This site-specific toxicological study identified high concentrations of perchloroethylene (PCE) in 29 of 30 soil samples at the campus, with some levels reaching 150 times the residential screening limit . This data is central to evaluating the health risks associated with the demolition of 150,000 square feet of 1950s-era building foundations, which could aerosolize these carcinogens near Towers Elementary School .
Institute of Transportation Engineers. (2021). Trip Generation Manual (11th Edition). ITE. https://www.ite.org/technical-resources/topics/trip-and-parking-generation/ This technical manual provides the industry standard for modeling daily vehicle trips. For the HLC assessment, 10 it contrasts the 2.74 round trips per bed for residential care with the 11.81 trips per bed for hospital use, while also providing the basis for evaluating the high-frequency trip generation of the 3,000-member gym facility .
MDS Research. (2019). Market Feasibility Analysis for the BCHD Healthy Living Campus. https://www.traonews.org/why-oppose Commissioned by BCHD, this feasibility study found that 80% to 90% of the target luxury assisted living demographic resides outside the Beach Cities . This finding supports the community assertion of a misalignment of public interest, where 100% of the environmental and economic burden is borne by local residents for a project serving a 91% non-resident population .
National PACE Association. (2025). Operational Framework and Transit Requirements for Programs of All-Inclusive Care for the Elderly.
(https://www.pacebus.com/sites/default/files/2025-07/I-290%20I- 88%20Travel%20Market%20Analysis_update%2007.11.25.pdf) This research evaluates the transit impacts of the PACE "wraparound" care model, which relies on a centralized busing and van fleet to transport enrollees daily . It highlights the "busing nuisance" created by concentrated drop-off and pick-up cycles, which introduce paratransit traffic onto residential streets like Flagler Lane and Prospect Avenue .
Nelson, M. (2023). Hedonic Price Modeling of Residential Property Values Surrounding the Beach Cities Health District Site. BCHD Over-Development Group. https://d3n9y02raazwpg.cloudfront.net/bchd/465dd208-499b-11e9-aee3-0050569183fa- 3b5dbe96-df7c-454b-921a-39e0032ed5ab-1635211651.pdf This report utilizes hedonic modeling of over 5,000 home values to quantify a $200 million aggregate reduction in residential equity within a one-mile radius of the HLC site . The analysis identifies visual blight, privacy intrusions from buildings placed at the site edges, and the loss of "Quiet Residential" character as the primary drivers of this market devaluation .
Torrance Redondo Against Overdevelopment (TRAO). (2024). Impact Analysis and Nuisance Assessment of the BCHD Healthy Living Campus Redevelopment. https://www.traonews.org/why-oppose This resource synthesizes community-driven impact data to define the geographic "nuisance zones" used to categorize damages . It defines the "Immediate Adjacency" and "Eastern Slope" zones most impacted by height-related shadows and privacy violations, and documents the zoning incompatibility of a 6-story building on a P-CF site typically limited to two stories .
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