SWAT comments on South Merced Specific Plan DEIR
Merced SWAT
The Merced Stop Wal-Mart Action Team
Attn: Bill King
City of Merced Planning Division
678 W. 18th St.
Merced, CA 95340
The Merced Stop Wal-Mart Action Team (SWAT) is writing to comment on South Merced Specific Plan Draft EIR. We are a grassroots organization of over 2,000 Merced teachers, health professionals, business owners, parents, students, community leaders and residents working to protect the quality of life in Merced. Many of our leadership live in or near South Merced, and would be directly affected by this Plan.
Over the past year, SWAT has conducted research into air quality issues and its effect on community health. What we have found has concerned us and has raised our awareness to the impact that planning decisions can have on air quality in our community.
It is with this heightened attention and concern for proper air quality control measures that we submit the following comments on the South Merced EIR:
1) AIR QUALITY MANAGEMENT STANDARDS
We would suggest that the South Merced Specific Plan include more mitigation and air pollution reduction measures that go above and beyond the basic requirements set forth by the San Joaquin Valley Air Pollution Control District (SJVAPCD). Merced is the 6th most ozone polluted area in the United States according to the American Lung Association’s 2007 “State of the Air” report. We should be setting the bar for air pollution reduction efforts, not meeting the minimum requirements set out by one of the State’s least effective air districts. On April 30, the San Joaquin Valley Air Pollution Control District approved an 8-hour ozone state implementation plan that moves the Valley into “extreme non-attainment,” putting us on par with Los Angeles as having the worst air quality in the U.S. and delays clean air attainment in the Valley until 2024. As our air quality public health crisis worsens, it is incumbent on local elected representatives to make responsible land use decisions that protect the health of vulnerable populations, especially children, the elderly, and low-income residents with little or no access to health insurance.
We request that you include some analysis of the potential impact of using stricter air quality standards such as those set forward by the South Coast Air Quality Management District, which has been very effective at moving communities towards cleaner air planning.
Additionally, the SJVAPCD has entered into a number of agreements with developers in the Bakersfield area in the South Valley, where concentrations of ozone and PM pollutants are even higher. These agreements would mitigate emissions to zero, meaning that through a combination of onsite measures and offsite pollution reduction projects, emissions associated with each development are effectively offset.
We are concerned that the proximity of new industrial development and construction projects to schools and residential areas as proposed in the South Merced Specific Plan will lead to increased respiratory illness, absenteeism from school and work, and a deterioration of family and social life. Through proactive leadership beginning at these earliest stages of planning, we can craft a vision of South Merced that creates jobs and fosters community without sacrificing the health of our children.
2) LAND USE AND SENSITIVE RECEPTORS
An ongoing concern of ours is the proximity of “sensitive receptors” as defined on page IV-A-12 of the Draft EIR to high pollution sources, both mobile and static. The South Merced will include residential areas and schools (both considered sensitive receptors) along with industrial and commercial uses. Since the Specific Plan document will be used to guide healthy planning decisions, we request that the EIR include additional information about safe and recommended distances that should be maintained between various types and sizes of land uses (including major roads) and sensitive receptors.
Additionally, we applaud SP Policies T-1.1 and T-1.2 (pg IV-A-15) for their attempt to develop alternative routes for heavy-duty vehicles to reduce localized concentrations of criteria pollutants (particularly diesel) around sensitive receptors. We hope, however, that the additional information and recommendations requested above can help decision makers approve healthier projects and adequately balance SP Policy CE-1.1 that aims to reduce the distance residents need to travel for retail and employment opportunities. In some circumstances these two policies may be at odds and require additional guidance from these planning documents.
Additionally, we find it confusing that the South Merced Specific Plan has been drafted concurrent to the Citywide General Plan Update process and without apparent coordination.
Thank you for your attention to these issues.
Sincerely,
The Merced Stop Wal-Mart Action Team