Critical Analysis by Topic Area

What the IS/MND says: The facility will consume 434 GWh annually, which represents only 0.64% of SCE's projected 2026 demand. The study concludes this is "less than significant impact."

What this actually means: This single facility would use roughly twice Monterey Park's entire municipal electricity consumption and as much power as would be demanded by 40,000 homes annually.

Why this deserves scrutiny:

• The "small percentage" framing is misleading. Saying the project is "only 0.64% of SCE demand" sounds minor – but that's like saying one new factory is a small percentage of California's entire economy. A single facility using twice Monterey Park's electricity is regionally significant, regardless of how it compares to the utility's total load.

• No clean energy is required. Despite consuming massive amounts of electricity, the project includes no requirement to use renewable energy, install solar panels, or purchase power from clean sources. The electricity will come from whatever mix SCE provides – which is currently about ⅔ fossil fuels.

• No obligation to reduce usage during emergencies. When California's grid is strained (like during heat waves), utilities ask large users to cut back. This project has no commitment to participate in such "demand response" programs, meaning it could keep running at full power while residents are asked to conserve.

• No alternative scenarios were tested. The IS/MND didn't analyze what would happen under different conditions—such as if the facility expanded, if grid capacity tightened, or if electricity prices spiked.

Who bears the burden: All SCE ratepayers share grid strain; Monterey Park residents experience localized impacts without proportional benefits.

What's missing: No options provided like battery storage or shifting energy use to off-peak hours; no analysis of how this facility would affect grid reliability during heat waves or other high-demand periods; no study of what happens if more data centers follow; no analysis or estimate on how much rate payers' costs would increase.

What the IS/MND says: The facility will use 12 million gallons annually, but the closed-loop cooling system is a "water-efficient" design and creates “less than significant impact.”

What this actually means: While more efficient than cooling systems that use and discard water, the facility will still demand 32,876 gallons/day – a net increase of 3,962 gallons / day above existing demands from Monterey Park – which alone presents a 1% increase in water demand in a region already facing chronic water scarcity.

Why this deserves scrutiny:

• "Water-efficient" is relative, not absolute. The cooling system recirculates water instead of using it once and dumping it. That's better than the alternative, but key details are missing, like the initial fill volume for the 23 industrial chillers. There is no analysis of the impact on the environment or people of extracting what is almost certainly a lot of water all at once.

• Ongoing water needs are unclear. Closed-loop systems still lose water and require regular replenishment. The annual top-off rate for the cooling system is not broken out in the IS/MND.

• No plan for system flushes. Cooling systems eventually require full draining due to corrosion, mineral buildup, or contamination. The IS/MND does not address flush frequency, water volume required, or disposal protocols for contaminated water.

• No analysis of real-world variation. Water use will likely increase on hotter days when cooling demands spike. The IS/MND doesn't model how consumption changes with temperature or during heat waves.

• No drought plan. During severe droughts, California mandates water restrictions for residents and businesses. The IS/MND doesn't address whether this facility would comply with restrictions, seek an exemption, or keep operating while neighbors cut back.

Who bears the burden: Local water ratepayers; regional water supplies during droughts.

What's missing: The IS/MND lacks a drought contingency plan, industry benchmarks for water efficiency, initial fill and replenishment volumes for the cooling system, flush frequency and disposal protocols, and water demand analysis that combines demand with other large users in the area.

What the IS/MND says: Construction Greenhouse Gas Emissions (GHG) exceed SCAQMD thresholds, but amortized over 30 years, the annual amount is “less than significant.” Operational emissions from the 24 backup generators are calculated at 2.44 tons/year of NOx and 0.68 tons/year of VOCs – well below Title V permitting threshold, so the document also concludes these are “less than significant impact.”

What this actually means: For two years, while the facility is being built, this project will emit emissions linked to respiratory illness at levels the regional air agency considers significant. Once operational, 24 diesel generators will be permitted to run up to 50 hours each annually for testing, plus unlimited additional hours during power outages.

Why this deserves scrutiny:

• Exceeding thresholds should trigger more review. The IS/MND attempts to avoid a full EIR by amortizing construction emissions over 30 years, but residents breathe the air now, not over decades.

• Generator emissions assume best-case conditions. Calculations are based on 50 hours/year of testing. Power outages aren't counted. If generators run 100+ hours during blackouts, emissions could double.

• Annual averages hide pollution spikes. 24 diesel generators running during an extended outage would create a concentrated burst of neighborhood pollution that yearly totals don't capture.

• This region already fails air quality standards. The South Coast Air Basin already doesn't meet federal limits. New pollution sources make a bad situation worse.

Who bears the burden: Nearest residents face the highest exposure, but GHG emissions contribute to regional ozone and smog across the South Coast Air Basin which is an area already failing to meet federal air quality standards. New emission sources make a regional problem worse.

What's missing: Specific construction pollution-reduction measures, historical outage data to estimate real generator usage, health risk assessments for nearby residents, and analysis of combined pollution from other industrial sources in the area.

What the IS/MND says: Operational noise from chillers will be 50–55 dBA at property lines, within City limits. The document concludes “less than significant impact.”

What this actually means: The facility meets legal limits, but with margins as narrow as 1 decibel—essentially no room for error.

Why this deserves scrutiny:

• 1 decibel is within measurement error. Noise readings fluctuate naturally. Actual operations could easily exceed limits without anyone technically being wrong.

• Emergency generators aren't counted. Generators are exempt from noise limits. During extended outages, 24 diesel generators running at once would be far louder – but this scenario isn't analyzed.

• 24/7 mechanical hum affects quality of life. Low-frequency noise (rumble, vibration) can disrupt sleep even at lower decibel levels. The IS/MND doesn't study this.

Who bears the burden: Residents in nearby homes who will hear continuous mechanical noise 24/7, sometimes varying in loudness or intensity, impacting their health and mental well-being.

What's missing: Doesn't analyze low-frequency noise, combined sound from all equipment operating together, or realistic scenarios where generators run during outages.

What the IS/MND says: The facility will emit 77,034 metric tons of CO₂e in 2027, declining to 2,204 by 2045 as SCE decarbonizes. The document claims this is consistent with the City's Climate Action Plan and that there is “less than significant impact.”

What this actually means: For the next 20 years, this facility will be a major source of climate pollution – equivalent to roughly 17,000 cars on the road annually. The projected decline depends entirely on the utility cleaning up its power mix; the project itself commits to nothing.

Why this deserves scrutiny:

• Generator emissions assume perfect conditions. The IS/MND calculates 1,616 metric tons of CO₂e/year from generators based on 50 hours of annual testing. Actual outages would increase this.

• The project takes no responsibility for electricity emissions. The bulk of emissions (75,181 metric tons of CO₂e) come from grid power generated offsite. The IS/MND assumes these will decline as SCE adds renewables, but the project doesn't commit to clean energy, renewable contracts, or carbon offsets. The emissions are real despite being out-of-sight; they're just experienced by communities near power plants rather than in Monterey Park.

• Manufacturing and construction emissions are ignored. The carbon footprint of building the facility, manufacturing servers, and transporting materials is never mentioned, which is a significant omission for a project of this size.

• The "less than significant" finding is circular. The IS/MND concludes emissions are acceptable because they're "consistent with the City's Climate Action Plan" – but doesn't make any effort to explain how it could even be possible for a project that creates 77,034 metric tons of CO₂e annually to advance the City’s climate goals since it would actually seem to undermine them.

Who bears the burden: Everyone affected by climate change—but especially local communities around the SoCal Edison power plants, plus future generations locked into decades of emissions from infrastructure approved today.

What's missing: Manufacturing and construction emissions, offers no project-level clean energy commitments, and doesn't explain what level of emissions would be considered significant if 77,034 metric tons/year doesn't qualify.

What the IS/MND says: Six biofiltration systems will treat stormwater. The impact is “less than significant.”

What this actually means: The project will cover nearly two-thirds of the site with hard surfaces that prevent natural water absorption. Stormwater (a.k.a. rain water) runoff – potentially carrying diesel residue, coolant leaks, and other pollutants from 24/7 industrial operations – will flow through treatment systems and into the city's storm drains, ultimately reaching local waterways.

Why this deserves scrutiny:

• Treatment effectiveness is unspecified. The IS/MND says biofiltration systems will treat stormwater but provides no pollutant removal rates. How much diesel, coolant, or industrial residue actually gets filtered out is unknown.

• No long-term maintenance plan. Biofiltration systems require regular upkeep to function properly. The IS/MND does not specify who is responsible for maintenance, what the maintenance schedule is, or what happens if systems fail or clog.

• Design is based on historical weather, not future conditions. Climate change is bringing more intense rainfall to Southern California. The IS/MND uses historical storm data only, so the systems may be undersized for increasingly severe weather events.

• Spill protocols are not addressed. A facility with 24 diesel generators and industrial cooling equipment poses contamination risks. The IS/MND does not include spill response protocols or containment measures for diesel or coolant leaks.

Who bears the burden: Downstream communities and ecosystems. Filtration doesn’t mean purification. Stormwater from this site drains to the city system and ultimately to regional waterways. If biofiltration systems underperform or fail, pollutants enter shared water resources that serve communities beyond Monterey Park. 

What's missing: Baseline water quality data, spill response protocols for diesel and coolants, and climate-adjusted design standards.