How International Industrial Park Traded a Thriving Ecosystem for Industrial Concrete

International Industrial Park, Inc., the owner of a 135-acre property, and its developer, SD Commercial, set out to build a massive industrial park. Standing in their way were 1.474 acres of public waters and 3.01 acres of adjacent wetlands—living ecosystems crucial for water filtration, flood control, and wildlife habitat.

Rather than navigate the legal process designed to protect these public resources, the corporations chose a different path: deceit.

For months, from late 2022 into 2023, earthmoving equipment, acting as “point sources” of pollution, descended on the site.

They ripped through the land, discharging rock, sand, and dirt into the waterways. This act of destruction, which filled approximately 0.529 acres of waters and 0.253 acres of wetlands, was not an accident. It was enabled by an act of fraud. An employee of SD Commercial, LLC submitted a falsified Clean Water Act permit and a falsified water quality certification to San Diego County to secure a grading permit.

The action was deliberate, planned, and executed to bypass the laws that protect our shared environment for the sake of constructing five industrial pads and associated infrastructure.

A Cascade of Consequences: The Real-World Impact

The consequences of filling a waterway extend far beyond a muddy construction site. It is an act of profound and lasting violence against a community and its ecosystem.

Environmental Degradation

When International Industrial Park and SD Commercial dumped fill into Drainages A and B of Johnson Canyon Creek, they effectively choked a vital artery of the local watershed. Wetlands act as the kidneys of an ecosystem, filtering pollutants and nurturing biodiversity. By burying them under industrial fill, the companies destroyed a natural public utility.

The damage cascades downstream, affecting the health of the Otay River and, eventually, the San Diego Bay, a major coastal embayment. The required mitigation plan, which involves removing trash and invasive species from a separate 5.59-acre parcel and attempting to restore 1.28 acres of habitat, is an admission of the extensive damage done. But ecological restoration is a fraught process; a rebuilt wetland rarely matches the complexity of the one that was destroyed.

Erosion of Community

This was a profound breach of public trust. The entire system of environmental protection rests on the assumption of good-faith participation. By using falsified documents, the evil corporations demonstrated contempt not just for the law, but for the very idea of civic responsibility. They lied to the County of San Diego, and in doing so, they undermined the public’s faith in the regulatory process that is supposed to keep them safe. This act sends a chilling message: that rules are for the powerless, while the powerful can simply write their own.

A System Designed for This: Profit, Deregulation, and Power

This is an analysis.

The actions of International Industrial Park and SD Commercial are not an anomaly. They are the logical, predictable outcome of a neoliberal capitalist system that relentlessly prioritizes private profit over public good. For decades, this ideology has championed deregulation, defunded enforcement agencies, and promoted the idea that corporations can and should police themselves.

In this environment (pun intended), a living wetland is not seen as an invaluable public resource but as an obstacle on a balance sheet.

The cost of obtaining a legitimate permit, which would involve time, oversight, and possibly scaling back the project, is weighed against the cost of getting caught. The system itself incentivizes the very behavior seen here.

When the penalty for knowingly destroying a public waterway is treated as a minor business expense, the law ceases to be a deterrent and becomes merely a line item in the budget of corporate expansion. This is the core logic of late-stage capitalism: the natural world and the communities that depend on it are raw materials to be exploited until nothing is left.

Dodging Accountability: How the Powerful Evade Justice

After being caught, the corporations did not face a trial where the full extent of their actions could be laid bare in public. Instead, they entered into a “Consent Agreement”. This is a common tool used by corporations to manage legal trouble with minimal public scrutiny and, most importantly, without admitting to the facts of their wrongdoing.

The agreement explicitly states that the respondents “neither admit nor deny the specific factual allegations“. This legal maneuver allows them to resolve the issue without ever taking public responsibility for their documented actions, including the use of fraudulent permits.

The penalty?

$85,000.

For a 135-acre industrial park development, this amount is not a punishment. It’s just a rounding error! It is the calculated cost of doing business. The agreement ensures that the penalty cannot be deducted from their federal taxes, but this does little to change the fundamental calculus. The system has affirmed that it is cheaper to beg for forgiveness (and pay a small fine) than to ask for permission. No executive at the top of the corporate ladder faced individual consequences; the corporation, an abstract entity, simply pays a fee and moves on.

Contrary to what the Supreme Court says, corporations are not people. Punishing corporations doesn’t punish the people.

Reclaiming Power: Pathways to Real Change

The story of International Industrial Park is a chilling reminder that our current economic system is failing to protect us. Meaningful change requires a fundamental shift in power.

True accountability would mean penalties that are existentially threatening to a corporation’s ability to operate. This includes fines calculated as a significant percentage of a project’s total value or a company’s annual profit. Individual accountability is also crucial. The executives who direct or tacitly approve of such actions must face legal consequences, not just the employees who carry them out.

I don’t know if I mentioned this earlier, but the employee who personally signed off on this environmental destruction ended up pleading guilty to doing so. But I don’t see any of the corporate leadership taking any responsibility! Why is it just the little grunts who need to take the brunt of this?

Furthermore, community empowerment is essential. Local communities must be given greater power to veto projects that threaten their environment and well-being. This requires strengthening, not weakening, regulations like the Clean Water Act and ensuring that enforcement agencies are fully funded and politically independent.

Conclusion: A Story of a System, Not an Exception

This document is more than a record of a single corporate misdemeanor. It is a window into the soul of our economic system.

The story of International Industrial Park and SD Commercial is not an exception to the rule; it is the rule. It reveals a system where the pursuit of profit justifies fraud, where the destruction of our shared natural heritage is a manageable expense, and where justice is a negotiation from which the public is largely excluded.

The ultimate villains are not just the individual actors who signed the documents, but the ideology of late-stage capitalism and neoliberalism themselves that created the conditions for this to happen—and to happen again and again.

All factual claims in this article were derived from the public document: EPA Docket No. CWA-09-2025-0049, In the Matter of International Industrial Park, Inc. and SD Commercial, LLC.

Believe it or not, this is the link to the EPA’s website on this case… even though they called SD Commercial “SF Commercial” for some reason: https://yosemite.epa.gov/oa/rhc/epaadmin.nsf/Filings/BE93EC02150B011885258CCC000AEE50?OpenDocument