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HomeMy WebLinkAbout1991-05-14 - AGENDA REPORTS - VALENCIA COMMERCE CENTER (2)AGENDA REPORT City Manager Appro ,a 7l Item to be presented NEW BUSINESS Lynn M. Harris2 /Vance f�VJ DATE: May 14, 1991 SUBJECT: County Monitoring: Valencia Commerce Center (Valencia Co., Project 86-106, Tentative Parcel Map 19784) Resolution Number: 91=79 DEPARTMENT: Community Development BACKGROUND On Thursday, May 23, the Los Angeles County Board of Supervisors will conduct a public hearing regarding the Valencia Company's proposed Commerce Center. The project was approved by the Regional Planning Commission on October 24, 1990; a citizen's group will be appealing the Commission's decision on the. 23rd. Public hearings were conducted by the Regional Planning Commission on this project on June 13, August 8, 1990, and October 25, 1990; the City participated in the public hearing process by submitting two letters (attached) requesting that the County mitigate impacts to the City. circulation and infrastructure systems. We have been generally supportive of the project because of the new job creation for the Valley. The Valencia Company plans to develop an approximately 1,436 acre property as a major industrial/commercial park, northwest of the intersection of I-5 and ' California State Highway 126. Primary access to the site is proposed to be , from Highway 126, along a southerly extension of Backer Road, from its present terminus approximately one mile west of Interstate 5. Backer Road is(' also proposed to be used as a secondary access from I-5. The project includes approximately 12,624,000 square feet of building space for mixed industrial/commercial uses. The applicant proposes approximately 19.1 million cubic yards of grading. Fifty-one oak trees, including four heritage trees, may be impacted by grading; the number of oak trees to be removed has not been identified. The applicant is requesting the following entitlements: General Plan Amendment, Zone Change, Tentative Parcel Map, Conditional Use Permit, and an Oak Tree Permit. The Draft Environmental Impact Report (EIR) prepared for this project identifies areas of substantialenvironmental impact, including traffic and.. circulation, air quality, cultural resources, biota, scenic. qualities, sewage disposal, water service, fire and police protection, environmental safety, and noise, as well as .impacts related to flood hazard and geology. The impacts of primary concern to the City, as expressed in the attached letters, are those to traffic and circulation. —.0007 Adopted: i Agenda Item:,,, 6 The Final EIR, prepared for the Board hearing, contains responses to the City's. comments regarding traffic and infrastructure impact analysis and mitigation (as well as other comments). City traffic engineering staff reviewed the responses and remained dissatisfied with the level of analysis and impact mitigation. For example, the City's June 12 letter requested that the County identify and address impacted City streets and intersections; the traffic analysis and subsequent project conditions of approval/mitigation program apply to only County streets and intersections adjacent to the project. The response to this comment (also attached) refers to these mitigation measures, and fails to acknowledge that any City streets or intersections might be affected by this project. Additionally, levels of service for streets adjacent to the property were estimated assuming completion of the local Los Angeles Master Plan of Highways by the year 2010, including construction of Newhall Ranch Road (State Highway 126) to eight lanes. The lack of an adopted alignment for this State highway was not discussed, nor`were funding mechanisms for its completion explored. Because of this and other deficiencies, staff considers the traffic impact analysis portion of the EIR to be inadequate. RECOMMENDATION Review attachments, adopt Resolution No. 91-79, and direct staff to transmit the attached letter and Resolution,to Los Angeles County. LMH:CMK: ID:CMK:492 , . RESOLUTION NO. 91-79 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CLARITA, CALIFORNIA, TO LOS ANGELES COUNTY IN SUPPORT OF THE PROPOSED VALENCIA COMMERCE CENTER, PROJECT NO. 86-106, INCLUDING GENERAL PLAN AMENDMENT 88-435, ZONE CHANGE 86-106, TENTATIVE PARCEL MAP 19784, CONDITIONAL USE PERMIT 87-360, AND OAK TREE PERMIT 88-221 IN THE UNINCORPORATED AREA OF THE SANTA CLARITA VALLEY AND REQUESTING THE COUNTY TO IDENTIFY AND MITIGATE TRAFFIC IMPACTS TO THE CITY OF SANTA CLARITA, AND TO ENSURE THAT ADEQUATE PUBLIC SERVICES ARE PROVIDED TO SERVE THIS PROJECT. WHEREAS, the County of Los Angeles Regional Planning Commission and Board of Supervisors will be considering the- approval of the proposed Valencia Commerce Center, which is located on a 1,436 acre parcel northwest of the intersection of Interstate 5 and California State Highway 126, and northwest of the City's northwestern boundary; and WHEREAS, the prott ct includes approximately 12,624,000 .square feet of office, industrial and commercial building space; and WHEREAS, the project applicant has requested the following entitlements: approval of Tentative Parcel Map 19784, Zone Change 86-106, General Plan Amendment 88-435, Conditional Use Permit 87-360, and Oak Tree Permit 88-221; and . WHEREAS, the Draft Environmental Impact Report (EIR) prepared for this project identifies areas of substantial environmental impact, including traffic and circulation, air` quality, cultural resources, biota, scenic qualities, sewage disposal, water service, fire and police protection, environmental safety, and noise, as well as impacts related to flood hazard and geology; and WHEREAS,, the traffic analysis and project conditions of approval and mitigation measures apply only to County streets and adjacent intersections, despite the City's request that project -generated and cumulative traffic impacts on the City be addressed and mitigated; and WHEREAS, the traffic study prepared for this project assumed completion of the local Los Angeles County Master Plan of Highways by the year 2010, including construction of arterials within the City such as Newhall Ranch Road to eight lanes, but did not provide mechanisms for its installation, or for other City street improvements -east of the project in the City as mitigation measures; and WHEREAS, although the proposed development may create substantial new job opportunities for residents of the Santa Clarita Valley and environs, it also may have a substantial impact upon the City of Santa Clarita, and its circulation network, infrastructure and levels of service; and . WHEREAS, the City of Santa Clarita has provided technical comments to the County of Los Angeles on June 12, 1990, and October 24, 1990; and Reso No. 91-79 . WHEREAS, the City of Santa Clarita desires to provide formal comment and testimony to the County of Los Angeles on the proposed project and the related Environmental Impact Report, all to be a part of the official record; NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA CLARITA DOES HEREBY RESOLVE, DETERMINE AND FIND AS FOLLOWS: SECTION 1. The City finds that although some of the impacts of this project may be adequately mitigated by measures in the mitigation monitoring program included in the Final EIR, project impacts on the City circulation network, infrastructure and levels of service have not been adequately addressed nor appropriate mitigation measures proposed, as addressed in the City's comments on the Draft EIR and project, dated June 12, 1990, and October 24, 1990, incorporated herein by reference as Attachment 1. The City requests that the County accept the responsibility for the identification and mitigation of the impacts of this project, and the cumulative project impacts on the City circulation network, infrastructure, and levels of service. SECTION 2. The City is concerned that the responses to City comments in the Final EIR did not recognize the City's concerns regarding traffic impacts to City. streets and intersections. The City requests that further assessment be conducted on this project, including a good faith effort to evaluate potentially significant individual and cumulative impacts to traffic and circulation within the City, feasible mitigation measures which would lessen the significant environmental effects of the project; and that this evaluation, together with a response and full assessment of the environmental impacts identified in the City's comments be included in the Final EIR prior to certification and carefully considered prior to any approvals being granted for this project. SECTION 3. In 1igRt of the County's recent approval of a comprehensive amendment to the Santa Clarita Valley Areawide Plan, the City is concerned that this project requests further amendments to said plan. The City requests that no further plan amendments be granted at this time unless substantial community benefits are realized. SECTION 4. The City Clerk shall, certify to the adoption of this Resolution and certify this record to be a full true correct copy of the action taken. PASSED, APPROVED, AND ADOPTED this_ day of , 1991. Carl Boyer, Mayor ATTEST: • DONNA GRINDEY, CITY CLERK Reso No. 91-79 i I HEREBY CERTIFY that the foregoing Resolution was duly adopted by the City Council of the City of Santa Clarita, at a regular meeting thereof, held on the day of 1991, by the following vote of the Council: AYES: COUNCILMEMBERS NOES: COUNCILMEMBERS ABSENT: COUNCILMEMBERS ID:CMK:491 Reso No. 91.79 DONNA GRINDEY, CITY CLERK It • I0 TO LAKE HUGHES 1po 7 t x n 0 PROJECT a r LOCATION TO Vicinity Map NOT TO SCALE ,..(� M1GIi.0u. fAIX '0o Y�� 1 _ _ l �r" r •1^� w- w TO LOS ANGELES. LEGEND Q CITY OF SANTA CLARITA Source: DRAFT EIR# Valencia Commerce Centere Los Angeles County Project 86-1061 April 1990 Y 23920 Valencia Blvd. Phone Suite 300 (805) 259.2489 City of Santa Clarita Fax California 91355 (805) 259-8125 City of Santa Clarita October 24,1990 Courtesy Copy of FAX Transmittal To: Members of the Regional Planning Commission Department of Regional Planning Hall of Records Room 1382 320 West Temple Street Jo Anne Darcy Los Angeles, CA 90012 Mayor Carl Boyer, 3rd RE: City Comments.and Recommended Mitigation Measures/Conditions of Mayor Pro -Tem Approval Project 88-435:'LPA 88-435, ZC 86-106 (5), CP 87-360 (5), TPM Jan Heidt 19784 Councilmember (Valencia Commerce Center) Jill Klalc Councilmember Dear Members of the Regional Planning Commission; Howard "Buck" McKeon Counctlmember In our letter to the Department of Regional Planning of June 12, 1990, the City of Santa Clarita raised several issues regarding the proposed Valencia Commerce Center, as referenced above. At this time, the City would liketosubmit additional comments regarding these issues of concern. While we are supportive of the creation of new jobs in the Santa Clarita Valley, we have concerns regarding impacts identified in the Draft Environmental Impact Report (DEIR) that are anticipated to be caused by traffic and noise generation, impacts to biotic resources, and impacts to public services, including fire, sheriff, and sanitation services. Furthermore, if the Commission proposes to recommend to the Board of Supervisors that the project be approved, the City recommends that the incorporated conditions be applied to the project. 1. Traffic, Circulation and Noise. At the General Plan level, the City's Draft Land Use Plan, (90Z complete) has been testing proposed land uses in order to determine circulation impacts and needs. The Draft Plan designates the proposed Valencia Commerce Center area for Business Park use, generally consistent with the proposed project. Current circulation modeling and testing in this area for the draft General Plan, however, indicates volume to capacity in excess of 1002 on Backer Road between Interstate 5 and State Route (SR) 126; along future SR 126 from Interstate 5 and Bouquet Canyon Road; on The Old Road between Backer Road and McBean Parkway; and elsewhere in the vicinity of the proposed project. While all such traffic cannot be attributed to this one project, the proposed development must be considered a major generator, and its impacts properly mitigated to acceptable levels of service (including noise impacts associated with vehicular and truck traffic). The City Traffic Engineer has advised us that the DEIR did not address intersections and travel routes within the City which may be impacted by this project, and has recommended that a complete analysis of impacts be conducted, prior to project approvals. Any proposed mitigation measures (including traffic signals and road widening, both within the City and the unincorporated area) resulting from this subsequent study should be installed and operational prior to issuing Certificates of Occupancy for Phase 1. 2. Public Services The DEIR and Technical Appendix include comments from the Los Angeles County Sheriff's Department; Fire Department, and Sanitation Department. Each of these departments has indicated that personnel, vehicles, and facility capacity do not exist to serve this project at this time. In addition, funds are not anticipated to be available to increase capacity prior to completion of Phase 1. The proposed mitigation measures in the DEIR and the Mitigation Monitoring Program do not address the provision of new facilities. Good planning practice would suggest that provision for public safety (sheriff and fire) and waste treatment be made, requiring facilities to be operational prior to occupancy of Phase 1. The City strongly advises that conditions of approval:of the project address this deficiency, so that the entire Santa Clarita Valley may continue to be adequately served by these essential public services. 3. Biota We noted that the U.S. Fish and Wildlife, the Army Corps of Engineers, and the California Department of Fish and Game did not provide comments to the DEIR, and are concerned that they may not have been given adequate time for review. The DEIR and Technical Appendix indicate that the site contains significant riparian habitat, the potential for the presence of two Federally Endangered species, (the Unarmored Three-spined Stickleback and the Least Bell's Vireo) and 79 native oak trees. Impacts to these resources include clearing of the riparian vegetation, partial channelization of Castaic Creek (albeit with a material that can be revegetated, subject to the approval of the L.A. Co. Dept. of Public Works) and removal of up to 40 of 79 oak trees. The DEIR also indicates that other native vegetation, will be impacted by proposed grading activities. As was stated by the County Forester and Fire Warden in his letter of December 12, 1988, (included in the responses to the DEIR) the proposed mitigation measures do not adequately compensate for these impacted resources. In particular, the "replacement" riparian habitat will be significantly different in character and function from the vegetation proposed to be removed, and is not likely to be suitable for population by the Least Bell's Vireo, should any birds travel upstream from areas where they have been identified to occur in the Santa Clara River (as addressed in the Technical Appendix). Adequate setback and floodway width should be provided through conditions of approval for the project, so that existing riparian habitat can be preserved, maintaining the mature canopy of cottonwood and willow present on the site now. Mature oak trees are a disappearing resource in southern California. In the City of Santa Clarita, applicants are encouraged to retain native oaks on site, and are.strongly discouraged from removing them. The oaks on the project site have, for the most part, been identified as healthy, and their preservation is warranted. Every effort should be made to design phases of the project to incorporatethem in the project design. As a condition of approval, the applicant should be required to preserve all oaks on the project site, or as a last resort, to implement a transplanting program conducted by a qualified specialist. Confirmation of the presence or absence of the Unarmored Three-spined Stickleback should be conducted prior to stream alteration activities. Conditions of approval of the project should,address this.by setting the timing of the investigation so that it is required to occur prior to grading in the vicinity of the creek. In addition, issuance of grading permits should be contingent upon fulfilling requirements of the US Army Corps of Engineers and the Department of Fish and Wildlife, so that impacts to the riparian habitat may be minimized. 4. Landscaping/Revegetation Project grading will create substantial visual impacts; however, if a revegetation program is implemented, along with a requirement for 'contour grading, and other techniques consistent with the County's Hillside Guidelines, these impacts may be minimized. The City recommends that plant material used for all slope planting be plants native to this region, and that non-native materials be avoided. Revegetation of graded slopes should be conducted by a qualified landscape architect or other specialist in restoration of disturbed areas. As a condition of approval, the applicant should.be required to enter into a contract with a restoration specialist, and to provide the Department of Regional Planning with a revegetation program, including, but not to be limited to, the reservation of topsoil, seeding and installing container plant material at the density proposed by the specialist. We also encourage that a monitoring program be designed by the specialist of not less than five years following implementation of the restoration program. This program should be required to be submitted prior to the issuing of grading permits. 5. Visual Impacts The proposed project will change the appearance of the site from a semi -natural condition to a fully -developed industrial park. The City advises that project and individual building elevations,.footprints, and landscape plans be required to be'submitted for review by the Department of Regional Planning. The applicant should be required to demonstrate that all roof equipment will be screened so that it is not visible from both local arterial streets and adjacent freeways. Finally, the City of Santa Clarita recognizes that the Regional Planning Commission may find that the benefits of this project may outweigh the unavoidable adverse impacts generated by the project. The.City advises that CEQA Section 15093 requires that a Statement of Overriding Considerations, with required findings, should be filed with the Notice of Determination for the project, if the project is approved. The City of Santa Clarita appreciates the opportunity to comment on this significant project, and encourages the Regional Planning Commission to consider thoroughly its potential impacts before making a recommendation to the Board of Supervisors. Please notify us of the RPC findings as soon as they are available. Your cooperation in making draft conditions of approval and proposed mitigation measures available to us at least three days before a hearing such as this would be appreciated. Sincerely, /- LYNN M. HARRIS DIRECTOR OF COMMUNITY DEVELOPMENT LMH. CK CK:371 11. City of Santa Clarita - Lynn M. Harris, Director of Community Development Letter dated June 12, 1990 IV -125 11. City of Santa Clarita - Lynn M. Harris, Director of Community Development Comment Natural Hazard #1: The Environmental Impact Report indicated the site is bisected by Castaic Creek, a major tributary of the Santa Clara River. Please be advised that the downstream essential habitat of the Unarmored Threespine Stickleback fish, an endangered species, may be impacted negatively by this proposal. We suggest further consultation with the appropriate agencies and trustee agencies be pursued prior to approvals of this proposal. Response: One of the two known extant populations of the Unarmored Threespine Stickleback (UTS) occurs in the Upper Santa Clara River system in Los Angeles and Ventura Counties. The project site borders on the Del Valle Zone, one of three essential habitats for the UTS as defined by the U.S. Fish and Wildlife Service. As shown on Figure III -413 of the DEIR, this Zone encompasses a segment of the Santa Clara River downstream of the project site. The applicant has been involved in on-going consultations with the Army Corps of Engineers, U.S. Fish and Wildlife Service, and the Environmental Protection Agency as part of the process of obtaining a 404 Permit. On December 11th, 1990, a 404 Permit was issued by the Corps for the Commerce Center (see Response to Comments Appendix D). The permit includes: numerous measures for the protection of wildlife habitat. Among the features are the use of Armorflex along Castaic Creek; a widened channel and preservation of existing riparian habitat; annual Vireo surveys; cultural and paleontological surveys of, all drainages; and a weed eradication program. Comment EiM N2: The Environmental Impact Report's Initial Study concluded no significant impacts associated with fire services were associated with this project. The list of typically storedlused hazardous materials includes flammables which may impact existing fire service. IV -128 Response: As discussed in Section 12.2.2 (p 194), construction of buildings and facilities will follow all applicable environmental rules and regulations, applicable building standards, and other fire and life safety regulations. Once constructed, tenants of the Valencia Commerce Center will be required to comply with all appropriate regulations for storage, handling, and use of hazardous materials as identified in the latest Uniform Fire Code. (See Section 4.2, pg. 77 for a more detailed discussion of the Fire Code requirements.) Should an accident occur which involves flammable hazardous material, the engine company of Fire Station /76 would respond. The L.A. County Fire Department facility (Fire Station x76), located at Castaic Junction on Henry Mayo Drive, is one of three Hazardous Material squads in L.A. County. If the Haz Mat squad at Station 76 is responding to an event elsewhere, the responding engine company would contain and begin evaluation of the accident until the Haz Mat squad arrives. This Fire Station is well located to respond within five minutes to any type of emergency at the Valencia Commerce Center. As previously stated in the response to Comment letter g5, the applicant will participate in an appropriate financing mechanism to provide funds for fire protection facilities which are required by new commercial, industrial or residential development in an amount proportionate to the demand created by this project. Comment Traffic #3: The document indicates a capacity deficiency in the year 2010 circulation system .proposed by the Master Plan of Highways and identified improvements required to resolve these deficiencies. However, it does not state how these improvements would come to fruition. The City recommends specific road improvements be identified by the County's Department of Public Works and made a condition of approval. The document forecasts project generated peak -hour volumes of significant magnitude entering and leaving the City via (future) SR 126 IV -129 (Newhall Ranch Road). It does not address the potential impacts or proposed mitigation on affected City streets and/or intersections. The City recommends traffic studies be prepared at each phase for this development in order to assess impacts and that mitigation measures in the form of conditions to any approvals be imposed requiring the applicant to pay a fair share cost of roadway and/or signalization improvements that may be identified. Response: Specific road improvements to mitigate project impacts have been identified by the County of Los Angeles, Department of Public Works and made required conditions of approval. These improvements are identified in the mitigation monitoring plan (see II. Mitigation Monitoring Program in Response to Comments Volume I). Listed next to the specific roadway improvement is the monitoring action and agency responsible for monitoring the installation of the Improvements. Additional traffic studies will be prepared as individual tracts within the Center are filed. The applicant will comply with conditions of approval as they apply to each final map. For further details, see response to Comment #2 of the City of Santa Clarita letter dated October 24, 1990, below. Comment Environmental Safety #4: We feel that the EIR does not fully address environmental safety issues; the sensitive use associated with the elementary school, documented within the EIR to be both 750 and 1700 feet away from the project site; compatibility and clean-up closure requirements; response time from appropriate agencies; and identification for possible evacuation routes. The document alluded to a future time when mechanisms will be in place and responsibility will be allocated to numerous businesses located within the center. The City recommends a coordinating agency, and to identify an agency responsible for emergency equipment, maintenance and testing. Response: The concerns and recommendations of the City of Santa Clarita are noted. As a point of clarification, please note that the 750 foot IV -130 distance from the elementary school refers to the Valencia Commerce Center project site (see Section 12.1, Table III -12A on page 185 of the Draft EIR), while the 1700 foot distance refers specifically to the smaller TPM 18229 site as shown on Table III -12C, page 195. All industrial businesses located at either location which handle hazardous materials, and therefore pose a risk to nearby sensitive receptors, are required by law to comply with any relevant rules and regulations including the Risk Management and Prevention Program (RMPP) (see Section 12.2.1 of the DEIR for a discussion of pertinent legislation). As discussed in Sections 12.2.2 and 12.3 (pp 193-194) of the DEIR, impacts on environmental safety from the use, storage, and transport of hazardous materials by individual users will be mitigated by: 1. following all applicable environmental rules and regulations, building standards, fire and life safety regulations, and applicable Fire Codes; 2. obtaining all required permits; 3. preparing emergency plans, area evacuation plans, and designated transport routes. Further, Fire Station #76 on Henry Mayo Drive (discussed in Section 10.1 p. 176) of the DEIR contains one of the three hazardous material (Haz-Mat) squads in Los Angeles County. This Fire Station is well located to respond within five minutes to any type of emergency at the Valencia Commerce Center. The Fire Department has stated -that a majority of the Haz-Mat calls received are due to substances which are intentionally dumped on vacant property. Once occupied, the Valencia Commerce Center site will be less subject to such activity. Evacuation of local residents in the case of an emergency is the responsibility of the Fire Department in cooperation with the local Sherriffs Department. IV -131 12. City of Santa Clarita - Lynn M. Harris, Director of Community Development Letter dated October 24, 1990 IV -132 12. City of Santa Clarita - Lynn M. Harris, Director of Community Development Comment In our letter to the Department of Regional Planning of June 12, 1990, #1: the City of Santa Clarita raised several issues regarding the proposed Valencia Commerce Center, as referenced above. At this time, the City would like to submit additional comments regarding these issues of concern. While we are supportive of the creation of new jobs in the Santa Clarita Valley, we have concerns regarding impacts identified in the Draft Environmental Impact Report (DEIR) that are anticipated to be caused by traffic and noise generation, impacts to biotic resources, and impacts to public services, including fire, sheriff and sanitation services. Furthermore, if the Commission proposes to recommend to the Board of Supervisors that the Project be approved, the City recommends that the incorporated conditions be applied to the project. Response: Comment noted. Comment 1. Traffic, Circulation and Noise. 1'2: At the General Plan level, the City's Draft Land Use Plan, (90% complete) has been testing proposed land uses in order to determine circulation impacts and needs. The Draft Plan designates the proposed Valencia Commerce Center area for Business Park use, generally consistent with the proposed project. Current circulation modeling and testing in this area for the draft General Plan, however, indicates volume to capacity in excess of 100% on Backer Road between Interstate S and State Route (SR) 126; along future SR 126 from Interstate S and Bouquet Canyon Road; on The Old Road between Backer Road and McBean Parkway; and elsewhere in the vicinity of the proposed project. While all such traffic cannot be attributed to this one project, the proposed development must be considered a major generator, and its impacts properly mitigated to acceptable levels of service (including noise impacts associated with vehicular and. truck traffic). The City Traffic Engineer has advised us that the DEIR did not address intersections and travel routes within the City which may IV -137 be impacted by this project, and has recommended that a complete analysis of impacts be conducted, prior to project approvals. Any proposed mitigation measures (including traffic signals and road widening, both within the City and the unincorporated area) resulting from this subsequent study should be installed and operational prior to issuing Certificates of Occupancy for Phase 1. Response: The traffic report was prepared for the project using the Valencia Area Traffic Model, a refined version of the Santa Clarita Valley Traffic Model developed by Los Angeles County Department of Public Works. The report is based upon the year 2010 build -out land use in the entire Santa Clarita Valley, assuming a population of over 270,000 people. The model distributes trips to and from the Commerce Center throughout the Santa Clarita Valley and distributes those trips on a road network which is the County Master Plan of Highways. This network includes intersections and travel routes within both the County and the City. The network is comprised of major highways which are capable of handling 50,000-60,000 vehicles per day, and secondary highways which have the capacity to accommodate 24,000-30,000 vehicles per day. Newhall Ranch Road is a limited access expressway with 8 -lanes and capacity for 80,000 vehicles per day. The 2010 model did not show any roadways with volume to capacity in excess of 100%. Backer Road and The Old Road are designed to major highway standards and show build -out volumes ranging from 13,000 to 49,000 vehicles per day, well below their capacity. The future SR -126 (Newhall Ranch Road) in the City east of I-5, shows build -out volumes ranging.from 55,000 to 67,000 vehicles per day, again below capacity. i The intersections along these routes were also operating at level of service D or better. The traffic reports for the Valencia Commerce Center have been reviewed and approved by the County of Los Angeles Department of Public Works. Specific mitigation measures and their timing are outlined in the mitigation monitoring plan, Section III -F of the DE1R. for Phase I, Backer Road must be extended from Hasley Creek south IV -138 to SR -126 prior to further occupancies. This also applies to the widening of 126 from Backer Road to I-5. As additional tracts are filed in the Commerce Center, supplemental traffic studies will be prepared to determine if additional roadway, signalization, or other intersection improvements are necessary. (See Section 13 of the DEIR for noise impacts associated with vehicular traffic.) Comment 2. Public Services #3: The DEIR and Technical Appendix include comments from the Los Angeles County Sheriffs Departments, Fire Department, and Sanitation Department. Each of these departments has indicated that personnel, vehicles, and facility capacity do not -exist to serve this project at this time. In addition, funds are not anticipated to be available to increase capacity prior to completion of Phase 1. The proposed mitigation measures in the DEIR and the Mitigation Monitoring Program do not address the provision of new facilities. Good planning practice would suggest that provision of public safety (sheriff and fire) and waste treatment be made, requiring facilities to be operational prior to occupancy of Phase 1. The City strongly advises that conditions of approval of the project address this deficiency, so that the entire Santa Clarita Valley may continue to be adequately served by these essential public services. Response: Fire: The County of Los Angeles Fire Department stated in a letter dated June 28, 1990, that additional manpower and equipment may be required as the need arises. Furthermore, the Board of Supervisors adopted a Report of a Developer Fee Plan and a Fire Station Plan on July 12, 1990 for the Santa Clarita Valley. The Report and Plan specify the number and location of fire stations, equipment and the costs to deliver needed fire protection services. This assessment was based on growth from this project and other cumulative developments in the urban expansion areas of the Valley. This project is conditioned to participate in the fire fee program to provide monies for personnel, vehicles and facility capacity when implemented. IV -139 Sheriff: No financing program currently exists for the expansion of Sheriff Services in the Santa Clarita Valley. As stated in Section 11.3 of the DEIR, mitigation measures include project related tax base expansion, the possible use of private security systems by some tenants of the Center, increased lighting and the use of landscaping to prevent or reduce concealment, and roadway improvements to alleviate congestion and reduce response times. It is the responsibility of the Sheriff's Department to identify additional measures which may be required to insure adequate service. Tenants of the Center will be required to comply with any measures identified by the Sheriffs Department and adopted by the Board of Supervisors. Sewer: Section 7.21 and 7.22 of the DEIR identify that the existing plus project Phase I sewage demand can be treated by the existing waste water treatment facilities. However, cumulative demand for Phase I and related projects require expansion of existing treatment facilities. The Sanitation District connection fee program provides the mechanism for constructing logical increments of expansion. As new users connect to the system, connection fees, equivalent to the cost of expanding the system, are assessed. These fees are accumulated and used to fund the next increment of expansion. (For a more detailed description of this process, see page 125 of the DEIR) In addition, occupancy permits shall not be granted until adequate sewage treatment plant and trunk line capacity is demonstrated. Comment 3. Biota xa: We noted that the U.S. Fish and Wildlife, the Army Corps of Engineers, and the California Department of Fish and Game did not provide comments to the DEIR and are concerned that they may not have been given adequate time for review. The DEIR and Technical Appendix indicate that the site contains significant riparian habitat, the potential for the presence of two Federally Iv -140 Endangered species, (the Unarmored Three-spined Stickleback and the Least Bell's Vireo) and 79 native oak trees. Impacts to these resources include clearing of the riparian vegetation, partial channelization of Castaic Creek (albeit with a material that can be revegetated, subject to the approval of the Los Angeles County Dept. of Public Works) and removal of up to 40 of 79 oak trees. The DEIR also indicates that other native vegetation will be impacted by proposed grading activities. As was stated by the County Forester and Fire Warden in his letter of December 12, 1988, (included in the responses to the DEIR) the proposed mitigation measures do not adequately compensate for these impacted resources. In particular, the "replacement" riparian habitat will be significantly different in character and function from the vegetation proposed to be removed, and is not likely to be suitable for population by the Least Bell's Vireo, should any birds travel upstream from areas where they have been identified to occur in the Santa Clara River ( as addressed in the Technical Appendix). Adequate setback and floodway width should be provided through conditions of approval for the -project, so that existing riparian habitat can be preserved, maintaining the mature canopy of cottonwood and willow present on the site now. Mature oak trees are a disappearing resource in Southern California. In the City of Santa Clarita, applicants are encouraged to retain native oaks on site, and are strongly discouraged from removing them. The oaks on the project site have, for the most part, been identified as healthy, and their preservation is warranted. Every effort should be made to design phases of the project to incorporate them in the project design. As a condition of approval, the applicant should be required to preserve all oaks on the project site, or as a last resort, to implement a transplanting program conducted by a qualified specialist. Confirmation of the presence or absence of the Unarmored Three- spined Stickleback should be conducted prior to stream alteration activities. Conditions of approval of the project should address this by setting the timing of the investigations so that it is required to occur prior to grading in the vicinity of the creek. In IV -141 addition, issuance of grading permits should be contingent upon fulfilling requirements of the US Army Corps of Engineers and the Department of Fish and Wildlife, so that impacts to the riparian habitat may be minimized. Response: The California Department of Fish and Game commented on the DEIR in their letter dated on June 5, 1990. The -Army Corps of Engineers, in consultation with the US Fish and. Wildlife Service has been. reviewing. the project since August, 1989. On December 11, 1990 the Corps issued an individual permit for the project which provides habitat mitigation measures for Castaic and Hasley Creeks (see Response to Comments Appendix D). The design and mitigation measures assure that there is no net loss in wetland acreage or habitat values. Among the features are the use of Armorflex along Castaic Creek; a widened channel and preservation of existing riparian habitat; annual Vireo surveys; cultural and paleontological surveys of all drainages; a weed eradication program and other mitigation measures. The applicant shall comply with the conditions of the Army Corps of Engineers Permit issued December 11, 1990. Impacts to oak trees will be mitigated through compliance with the County of Los Angeles Oak Tree Ordinance. Modifications in the project site design and grading plans have resulted in a change in the anticipated number of oak trees to be removed. More recent analyses indicate that a total 0 1 oaks including 4 heri�ta_¢e tire` are within areas of proposed grading. The proposed grading plans, however, are general. Oak tree permits will be filed with individual tentative maps when grading plans are more precise. As discussed in Section 4.3 (p. 78) and Section 5.3 (p. 101), removal of oak trees will comply with the Oak Tree Permit process. All removed oaks will be replaced, according to ordinance requirements, on a 2:1 basis with 15 gallon size trees (1 inch in diameter) under the supervision of a qualified arborist. Replacement trees will be maintained for a minimum of two. years. Compliance with the Oak Tree Ordinance is considered appropriate mitigation and will reduce the project impacts on oak trees to a level of insignificance. IV -142 Comment 4. Landscaping/Revegetation N5: Project grading will create substantial visual impacts; however, if a revegetation program is implemented along with a requirement for "contour grading' and other techniques consistent with the County's Hillside Guidelines, these impacts may be minimized. The City recommends that plant material used for all slope planting. be plants native to this region, and that non-native materials be avoided. Revegetation of graded slopes should be conducted by a qualified landscape architect or other specialist in restoration of disturbed areas. As a condition of approval, the applicant should be required to enter into a contract with a restoration specialist, and to provide the Department of Regional Planning with a revegetationprogram, including, but not to be limited to, the reservation of topsoil, seeding and installing container plant material at the density proposed by the specialist. We also encourage that a monitoring program be designed by the specialist of not less than five years following implementation of the restoration program. This program should be required to be submitted prior to the issuing of grading permits. Response: The mitigation monitoring program contains measures to assure that graded areas will be revegetated with native and non-native species. Contoured grading techniques will be employed and reviewed through the subdivision process as additional tentative maps are approved in the Commerce Center. Grading plans will be reviewed by the Department of Public Works and landscape plans will be reviewed by the Department of Regional Planning prior to issuance of permits. Landscaped slopes will be maintained by a landscape maintenance district funded by property owners within the project boundaries. Comment S. Visual Impacts X6: The proposed project will change the appearance of the site from a semi -natural condition to a fully -developed industrial park. The City advises that project and individual building elevations, footprints,. and landscape plans be required to be submitted for review by the Department of Regional Planning. The applicant IV -143 should be required to demonstrate that all roof equipment will be screened so that it is not visible from both local arterial streets and adjacent freeways. Response: Prior to the issuance of building permits, the Department of Regional Planning performs plot plan review of building within the project area. Building elevations, footprints, and landscape plans are reviewed to assure compliance with the approved conditions for the project. Screening of roof equipment has been made a condition of. approval in the Conditional Use Permit. Comment Finally, the City of Santa Clarita recognizes that the Regional k7: Planning Commission may find that the benefits of this project may outweigh the unavoidable adverse impacts generated by the project. The City advises that CEQA Section 15093 requires that a Statement of Overriding Considerations, with required findings, should be filed with the Notice of Determination for the project, if the project is approved. The City of Santa Clarita appreciates the opportunity to comment on this significant project, and encourages the Regional Planning Commission to consider thoroughly its potential impacts before making a recommendation to the Board of Supervisors. Please notify us of the RPC findings as soon as they are available. Your cooperation in making draft conditions of approval and proposed mitigation measures available to us at least three days before a hearing such as this would be appreciated. Response: Comments noted. No response necessary. IV -744