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HomeMy WebLinkAbout1994-04-26 - AGENDA REPORTS - COUNTY MONITORING VALENCIA EIR (2)AGENDA REPORT NEW BUSINESS City Manag er Item to be pr sente y: L nn . Harris y Lot DATE: April 26, 1994 SUBJECT: COUNTY MONITORING: VALENCIA MARKETPLACE PROJECT AND DRAFT ENVIRONMENTAL IMPACT REPORT DEPARTMENT: Community Development BACKGROUND On April 6, 1994, the City of Santa Clarita submitted an appeal to the Board of Supervisors. The appeal will allow the Board to review all components of the Marketplace proposal as a whole. This will afford the Board the opportunity to consider the City's technical and policy concerns, an option the Supervisors might not otherwise have without this action.. On March 31, 1994, the project applicant also submitted an appeal of the project conditions of approval. Since December of 1993, staff and the City Council have participated in the County's review of this project with letters, a resolution, and public testimony on the proposal. The City reviewed the project and DEIR, and identified several areas of concern regarding environmental impacts, land use, and infrastructure services and facilities. In addition to identifying project impacts, the City's comments included recommended revisions and mitigation measures to eliminate these impacts or reduce them to an acceptable level. Specific detail of these concerns and recommended solutions are included in the City's letter of December 14, 1993 (attached). The Regional Planning Commission approved the project on March 30, 1994, and recommended that the Board of Supervisors adopt the requested general plan amendment and zone change to allow the project. The City has appealed the RPC action for the reason stated above. While the City's original concerns with the project included the areas of land use, riparian habitat and oak tree removal, traffic, noise, aesthetics, the City has worked with the project applicant to resolve most of these concerns. However, we remain concerned with the following areas: 1) Revenue sharing and long-term commitment to overcoming the existing infrastructure deficit; 2) Development Monitoring System (DMS) analysis and compliance; and 3) Preservation of an additional 25% of the 141 oak trees on-site. Regarding the first two issues, the City has requested that an evaluation of this project's impacts on the DMS be prepared to specifically and comprehensively identify areas of deficiency or adequacy. The County has indicated that service and facility impacts will be off -set by revenues generated by the project if such revenues are used to fund added services. This proposed mitigation is inadequate because it makes no actual provision for this to occur. Staff continues to recommend that a Community Services District, or some similar mechanism, be formed to allocate />!f Adopted: q-,11- 9y t -- ao camp Age��� Item: 80% the tax revenues to the Santa Clarita Valley to overcome the existing infrastructure deficit. Preservation of an additional 25% of the on-site oaks could be accomplished with a minor modification of the site plan to avoid a portion of the HM area. This would also coincide with the desires of Stevenson Ranch residents who have requested a similar project modifications. Prior to the Board of Supervisors meeting on May 5, 1994, it may be advisable for a City Council representative to meet with a member or members of the Board to discuss the City's position. Representatives of the Stevenson Ranch Town Council have suggested this approach and would also like to attend such a meeting. City staff has prepared a resolution which recounts the City's participation in the planning process, and sets forth both the City's technical and policy concerns regarding this proposal. It should be noted that the resolution contains many of the issues related above, and has been written as comprehensively as possible to give the City maximum flexibility in pursuing this issue with the applicant and the County. RECOMMENDATION 1. Adopt Resolution No. 94-51 setting forth the City's position on the Valencia Marketplace proposal, and setting forth the reasons of the appeal of the Regional Planning Commission's actions to the Board of Supervisors. 2. Authorize a member or members of the City Council to meet with the Board of Supervisors or representatives thereof, and/or to represent the City and present testimony to the Board of Supervisors at its May 5, 1994, meeting regarding the positive resolution of this matter. 3. Direct staff to continue working with County staff and the applicant to reach equitable solutions to all areas of concern. ATTACHMENTS 1. Resolution No. 94-51 2. City letters to the County dated December 14, 1993; December 15, 1993; January 5, 1994; March 24, 1994; March 28, 1994. DMW:MJC advance,mrktplt 6.mlc RESOLUTION NO. 94-51 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CLARITA, CALIFORNIA, TO THE COUNTY OF LOS ANGELES APPEALING THE LOS ANGELES COUNTY REGIONAL PLANNING COMMISSION'S CONDITIONAL APPROVAL OF THE PROPOSED VALENCIA MARKETPLACE REGIONAL AND COMMUNITY COMMERCIAL PROJECT (LOS ANGELES COUNTY PROJECT NO. 92-075) WHEREAS, the proposed Valencia Marketplace project includes 859,740 square feet of retail commercial uses and restaurants, located on 83.7 acres immediately west of the Golden State (I-5) Freeway, south of McBean Parkway, and north of Pico Canyon Road, to provide community and regional commercial retail outlets, and will require a total of 1.7 million cubic yards of grading, to be balanced on-site; and WHEREAS, the project applicant has requested the following entitlements: a General Plan Amendment; a Zone Change; a Vesting Tentative Parcel Map; a Conditional Use Permit; and an Oak Tree Permit; and WHEREAS, the Draft Environmental Impact Report (DEIR) prepared for this project identifies areas of substantial environmental impact, including impacts to the following areas: geotechnical, flood hazards, Sheriff and Fire protection, noise, biology, aesthetics, traffic, sewage disposal, water availability and quality, and air quality; and WHEREAS, the proposed project would result in the loss of 105 of 141 native oaks (75% of all on-site oaks)and the loss of 2.8 acres of riparian habitat (Pico Canyon Creek) and therefore, as now designed, would have a substantial negative impact on the site's biological resources; and WHEREAS, the proposed project is not consistent with the existing land use designations of the project site, a General Plan Amendment is being requested by the project applicant to change the land use designations of the project site from Hillside Management, Open Space, Floodplain/Floodway, Commercial, and Non- urban to Commercial for the entire 83.7 acre project site; and WHEREAS, the DEIR does not adequately address or discuss potential conflicts with adjacent land uses, nor does it contain adequate mitigation measures to reduce such impacts; and WHEREAS, this proposed project would likely have community -wide land use impacts relating to regional mobility, air quality, economics, and the jobs to housing balance in the Santa Clarita Valley; and WHEREAS, the proposed project would generate 26,333 average daily vehicle trips to and from the site, and the DEIR indicates that seven intersections within the City of Santa Clarita would be significantly impacted by this project, and includes mitigation measures to reduce these impacts; and WHEREAS, the primary noise source affecting the project site is the I-5 Freeway, and the DEIR does not include discussion of potential long-term noise impacts to the project site, patrons, or employees; and WHEREAS, the aesthetics analysis of the DEIR does not provide adequate detail to illustrate the exterior elevations of proposed structures and signs, and the potential impact as viewed from residential areas to the west or from the Interstate 5 Freeway to the east; and WHEREAS, the proposed 1.7 million cubic yards of grading will significantly alter the topography over ninety-five percent (95%) of the project site, and the DEIR does not provide cross- sections of the proposed grading to illustrate the potential aesthetic impacts to views as observed from the residential areas to the west or from the Interstate 5 Freeway to the east; and WHEREAS, the project may be inconsistent with the goals and policies of the Regional Comprehensive Plan (RCP) as its present design (location, access, circulation, and parking layout) promote traditional use of the single -passenger vehicle and does not adequately promote the use of public transit; and WHEREAS, the DEIR does not adequately evaluate or address impacts to those facilities, systems, and services monitored by the County Development Monitoring System (DMS), nor does it include a comprehensive presentation of existing deficiencies or adequacies in those facilities, systems, or services monitored by the DMS which will be impacted by the proposed project; and WHEREAS, there exist infrastructure deficits and service deficiencies in the Santa Clarita Valley due to past development practices, the proposed project will create additional demands upon the existing infrastructure and services in the Santa Clarita Valley and within the incorporated area of the City of Santa Clarita; and WHEREAS, the proposed project would have a substantial impact upon the City of Santa Clarita, its circulation network, infrastructure, and levels of service, and would not mitigate or otherwise compensate the City for said impacts; and WHEREAS, the DEIR does not adequately address or discuss potential conflicts with adjacent land uses, nor does it contain R.... No. 91-51 adequate mitigation measures to reduce such impacts; and WHEREAS, the residents and Town Council of the Stevenson Ranch development, located to the west of the project site, have met with the City and have previously resolved some issues with the project applicant but have several issues which remain outstanding, including project redesign, a number of residents will likely stand in opposition to this project as presently designed; and WHEREAS, the DEIR contains many assessments of potential environmental impacts which do not adhere to the California Environmental Quality Act (CEQA) criteria for determining significant environmental effects per CEQA Section 15064; and WHEREAS, the City of Santa Clarita submitted a technical comment letter on the DEIR dated December 14, 1993, and oral testimony on December 15, 1993, and January 2, 1994, to the County Regional Planning Commission regarding the Valencia Marketplace proposal; and WHEREAS, the City of Santa Clarita provided formal comment to the Los Angeles County Regional Planning Commission in correspondence dated December 14, 1993, on the proposed project and DEIR, all to be part of the official record; and WHEREAS, the Los Angeles County Regional Planning Department staff's March 17, 1994 responses do not adequately address several of the specific questions raised in the City's December 14, 1993 comment letter, and did not address the testimony presented by the City on the project and DEIR to the Los Angeles County Regional Planning Commission on December 15, 1994 and January 2, 1994, nor did the responses reference the City of Santa Clarita and impacts to City services and facilities; and WHEREAS, the County's response to the City's comments indicate that the sales -related travel statistics from the DEIR air quality assumptions are reasonable for use in projecting the geographic source of project sales dollars; and WHEREAS, the County's response to the City's comments indicate that the project is only obligated to mitigate project impacts, not to overcome existing infrastructure deficits; and WHEREAS, the County indicates that, based upon project DEIR air quality and traffic statistics, 650 of project sales will come from within five miles of the project; another 220 of project sales will come from up to 17.5 miles away along the I-5 and SR 14 freeway corridors; and that 13% of sales will come from the San Fernando Valley; and WHEREAS, on March 30, 1994, the Los Angeles County Ree.. N.. 99-51 Regional Planning Commission considered and approved the tentative parcel map (TPM 8676), conditional use permit (CUP 92-075), and oak tree permit (OTP 92-075), for the proposed Valencia Marketplace project; and WHEREAS, the Los Angeles County Regional Planning Commission forwarded the Valencia Marketplace project to the Los Angeles County Board of Supervisors with a recommendation to approve the requested zone change and sub -plan amendment to allow the project; and WHEREAS, the City Manager's office authorized Community Development Department Staff to prepare the appropriate application materials to appeal the Los Angeles County Regional Planning Commission's action; and WHEREAS, Community Development Department Staff prepared an appeal of this project to the Los Angeles County Board of Supervisors to allow the Board an opportunity to review the project as a whole, and to address the fiscal policy issuesassociatedwith the Valencia Marketplace proposal; and WHEREAS, on April 6, 1994, the City filed an appeal to the Los Angeles County Board of Supervisors of the Los Angeles County Regional Planning Commission's conditional approval of the requested tentative parcel map, conditional use permit, oak tree permit, and recommended granting of a zone change and general plan amendment to allow the proposed Valencia Marketplace project. THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA CLARITA DOES HEREBY RESOLVE, DETERMINE AND FIND AS FOLLOWS: SECTION 1. The City finds that the DEIR is deficient and should be expanded to further analyze the impacts to biological resources, traffic and circulation (including Congestion Management Plan {CMP) issues), land use, aesthetics, noise, and the adequate provision of long-term infrastructure and service needs in the Santa Clarita Valley. SECTION 2. The DEIR should indicate the location of off- site restoration recommended as mitigation for the loss of wetlands and oak trees, and the time -frame and monitoring for these mitigation efforts. To preserve the majority of the site's oak trees, development should not occur within the 25.1 acre area designated by the County as Hillside Management. SECTION 3. The City of Santa Clarita generally does not support additional amendments to the County's Santa Clarita Valley Area -wide Plan, which was updated and adopted in 1990. The City's xeeo. No, 96-51. General Plan Land Use Element Policy 5.4 specifically discourages the removal of the Hillside Management designation in unincorporated areas when urbanization proposals are made for such areas. The DEIR should examine an alternative to the project which preserves the area designated as Hillside Management. SECTION 4. The traffic analysis in the DEIR should be expanded to address potential impacts upon McBean Parkway from the project site to Valencia Boulevard, and on Lyons Avenue from the Interstate 5 Freeway to San Fernando Road. This analysis should also be expanded to address the impacts of a no parking zone, and restriping to six lanes, on Lyons Avenue. Further expansion of this analysis should also include recommended mitigation measures for any additional impacts which are identified. SECTION 5. In addition to roadway and intersection improvements recommended in the DEIR, the following recommendations should also be implemented with the project: Restripe McBean Parkway to six lanes; provide necessary traffic signal modifications to McBean Parkway and all impacted side streets; direct the County Traffic Engineer to work with the City Traffic Engineer to formulate appropriate traffic mitigation measures as needed. SECTION 6.. The noise analysis in the DEIR should be expanded to address potential long-term impacts upon employees and patrons at the project site. SECTION 7. The aesthetic analysis in the DEIR should be expanded to include architectural details as viewed from the Interstate 5 Freeway, a scenic corridor. Cross-sections of the proposed grading should be included to illustrate the change in the site's topography from all inhabited areas and public roadways. Contour grading should be required per the County's Hillside Design Guidelines. Earth -colored dye should be used in all visible concrete drainage facilities to reduce the contrast between such structures and adjacent slopes. A project sign plan should be provided to the City for review prior to final approval and issuance of construction permits. SECTION 8. Under Goal 1 of the City of Santa Clarita General Plan Land Use Element, we seek to preserve the character of the communities and the integrity of the Santa Clarita Valley by permitting orderly growth through the synchronization of development with the availability of public facilities such as roads, sewers, water service and schools needed to support it. SECTION 9. Under Goal 2 of the City of Santa Clarita General Plan Land Use Element, we seek to achieve the development of a well-balanced, financially sound, and functional mix of residential, commercial, industrial, open space, recreational, Aeco. No. 96-51 institutional and educational land uses. SECTION 10. The City requests that further environmental assessment be conducted on this proposed project, including a good faith effort to evaluate potentially significant individual and cumulative impacts, feasible alternatives, and mitigation measures which would reduce the significant environmental impacts of the project. This evaluation, together with a response and full assessment of the environmental impacts identified in the City's comments should be included in the Final Environmental Impact Report (FEIR) prior to certification and be carefully considered prior to any approvals being granted for this project. SECTION 11. A public transit facility should be provided at the project site. The County and/or developer should enter into an agreement with Santa Clarita Transit to fund transit services to the project site and adjacent areas. SECTION 12. The County's response to the City's comments do not clarify the relation between infrastructure, sales revenues, and the residential location of patrons, and does not provide an analysis to determine compliance with the County's Development Monitoring System to overcome the existing infrastructure deficit created by past development practices. SECTION 13. The City strongly disagrees with the County's assumption that "...the project is only obligated to mitigate project impacts, not to overcome existing infrastructure deficits." This project would clearly exacerbate the problems associated with the existing infrastructure deficit. Adequate mitigation requires facility improvements which also address the effects of secondary consequences related to the effects of primary consequences, not just directly from the project itself, even if those effects are several steps removed from the project in the chain of cause and effect. SECTION 14. Should the Los Angeles County Board of Supervisors approve this project, the City's position is that allocation of tax funds for capital improvements should be appropriated into a capital improvement program based upon a ratio commensurate with the initial and on-going impact which this project would have on those portions of the City and County experiencing those impacts. SECTION 15. Based upon the County's use of project air quality and traffic statistics to determine potential infrastructure impacts, the City takes the position that it is reasonable and consistent to use these statistics to determine the appropriate allocation of project generated tax revenues which should be committed to the City of Santa Clarita and the unincorporated area of the Santa Clarita Valley for the services, Ree.. N.. 94-51 utilities, and facilities needed to mitigate the potential impacts associated with this project, and to help overcome the existing infrastructure deficit. SECTION 16. The City of Santa Clarita has requested that, should this project be implemented, the County of Los Angeles make a commitment to allocate at least 80% of this project's future tax revenues to help eliminate the existing deficits and inadequacies to infrastructure, facilities, ongoing law enforcment and other services in the Santa Clarita Valley. SECTION 17. The City of Santa Clarita requests that in the event of an annexation to the City of Santa Clarita, said annexation would be based upon an agreement between the City and the County providing for sharing of sales tax and other revenue sources generated in the area, consistent with a formula providing to the City a share of such revenue at a minimum to be commensurate with the cost of providing municipal services, including the necessary supporting infrastructure attributable to the area. The determination of the cost of municipal services attributable to the area shall be fixed by mutual agreement between the City and County, using the County's Development Monitoring System and any other documentation supporting the cost of providing services to the area. SECTION 18. Based upon the Air Quality statistics used in the DEIR to assess the infrastructure impacts, it would be reasonable to use these statistics to determine the appropriate allocation of future project generated tax revenues which should be committed to the City of Santa Clarita and the Santa Clarita Valley. SECTION 19. The proportional allocation of project generated taxes, consistent with project DEIR air quality and traffic statistics, would justify a commitment of all project generated tax revenues to infrastructure improvements and services in the following proportions: 65% within five miles of the project; 22% to those areas along the Golden State Freeway and Antelope Valley Freeway corridors up to 17.5 miles away (exclusively north of the San Fernando Valley); and 13% to the unincorporated areas of the San Fernando Valley. Based upon the these statistics, it appears appropriate that both the incorporated and unincorporated areas of the Santa Clarita Valley should receive 87% (65% plus 220) of all taxes generated by this project. The City has requested 80% of these revenues. SECTION 20. The City supports the efforts of the residents and Town Council of Stevenson Ranch to ensure that the proposed Valencia Marketplace development does not result in impacts detrimental to their community, and the City therefore requests that the County work closely with the residents and Town .... ... 91-51 Council of Stevenson Ranch to resolve outstanding major issues of importance to that community. SECTION 21. The City Clerk shall certify to the adoption of this Resolution and certify this record to be a full and correct copy of the action taken. PASSED, APPROVED AND ADOPTED THIS day of , 1994. Mayor ATTEST: City Clerk STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES ) ss CITY OF SANTA CLARITA ) I, DONNA M. GRINDEY, CITY CLERK, DO HEREBY CERTIFY the above and 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 , 1994 by the following vote of Council: AYES: COUNCILMEMBERS: NOES: COUNCILMEMBERS: ABSENT: COUNCILMEMBERS: City Clerk city councl1\ree94-51.mjc Raco. N.. 91-51 o L -D RESOLUTION N0. 94-51 tso A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CLARITA, CALIFORNIA, TO THE COUNTY OF LOS ANGELES APPEALING THE LOS ANGELES COUNTY REGIONAL PLANNING COMMISSION'S CONDITIONAL APPROVAL OF THE PROPOSED VALENCIA MARKETPLACE REGIONAL AND COMMUNITY COMMERCIAL PROJECT (LOS ANGELES COUNTY PROJECT NO. 92-075) WHEREAS, the proposed Valencia Marketplace project includes 859,740 square feet of retail commercial uses and restaurants, located on 83.7 acres immediately west of the Golden State (I-5) Freeway, south of McBean Parkway, and north of Pico Canyon Road, to provide community and regional commercial retail outlets, and will require a total of 1.7 million cubic yards of grading, to be balanced on-site; and WHEREAS, the project applicant has requested the following entitlements: a General Plan Amendment; a Zone Change; a Vesting Tentative Parcel Map; a Conditional Use Permit; and an Oak Tree Permit; and WHEREAS, the Draft Environmental Impact Report (DEIR) prepared for this project identifies areas of substantial environmental impact, including impacts to the following areas: geotechnical, flood hazards, Sheriff and Fire protection, noise, biology, aesthetics, traffic, sewage disposal, water availability and quality, and air quality; and WHEREAS, the proposed project would result in the loss of 105 of 141 native oaks (75% of all on-site oaks)and the loss of 2.8 acres of riparian habitat (Pico Canyon Creek) and therefore, as now designed, would have a substantial negative impact on the site's biological resources; and WHEREAS, the proposed project is not consistent with the existing land use designations of the project site, a General Plan Amendment is being requested by the project applicant to change the land use designations of the project site from Hillside Management, Open Space, Floodplain/Floodway, Commercial, and Non- urban to Commercial for the entire 83.7 acre project site; and WHEREAS, the DEIR does not adequately address or discuss potential conflicts with adjacent land uses, nor does it contain adequate mitigation measures to reduce such impacts; and WHEREAS, this proposed project would likely have community -wide land use impacts relating to regional mobility, air quality, economics, and the jobs to housing balance in the Santa Clarita Valley; and WHEREAS, the proposed project would generate 26,333 average daily vehicle trips to and from the site, and the DEIR indicates that seven intersections within the City of Santa Clarita would be significantly impacted by this project, and includes mitigation measures to reduce these impacts; and WHEREAS, the primary noise source affecting the project site is the I-5 Freeway, and the DEIR does not include discussion of potential long -.term noise impacts to the project site, patrons, or employees; and WHEREAS, the aesthetics analysis of the DEIR does not provide adequate detail to illustrate the exterior elevations of proposed structures and signs, and the potential impact as viewed from residential areas to the west or from the Interstate 5 Freeway to the east; and WHEREAS, the proposed 1.7 million cubic yards of grading will significantly alter the topography over ninety-five percent (95%) of the project site, and the DEIR does not provide cross- sections of the proposed grading to illustrate the potential aesthetic impacts to views as observed from the residential areas to the west or from the Interstate 5 Freeway to the east; and WHEREAS, the project may be inconsistent with the goals and policies of the Regional Comprehensive Plan (RCP) as its present design (location, access, circulation, and parking layout) promote traditional use of the single -passenger vehicle and does not adequately promote the use of public transit; and WHEREAS, the DEIR does not adequately evaluate or address impacts to those facilities, systems, and services monitored by the County Development Monitoring System (DMS), nor does it include a comprehensive presentation of existing deficiencies or adequacies in those facilities, systems, or services monitored by the DMS which will be impacted by the proposed project; and WHEREAS, there exist infrastructure deficits and service deficiencies in the Santa Clarita Valley due to past development practices, the proposed project will create additional demands upon the existing infrastructure and services in the Santa Clarita Valley and within the incorporated area of the City of Santa Clarita; and WHEREAS, the proposed project would have a substantial impact upon the City of Santa Clarita, its circulation network, infrastructure, and levels of service, and would not mitigate or otherwise compensate the City for said impacts; and WHEREAS, the DEIR does not adequately address or discuss potential conflicts with adjacent land uses, nor does it contain adequate mitigation measures to reduce such impacts; and WHEREAS, the residents and Town Council of the Stevenson Ranch development, located to the west of the project site, have met with the City and have previously resolved some issues with the project applicant but have several issues which remain outstanding, including project redesign, a number of residents will likely stand in opposition to this project as presently designed; and WHEREAS, the DEIR contains many assessments of potential environmental impacts which do not adhere to the California Environmental Quality Act (CEQA) criteria for determining significant environmental effects per CEQA Section 15064; and WHEREAS, the City of Santa Clarita submitted a technical comment letter on the DEIR dated December 14, 1993, and oral testimony on December 15, 1993, and January 2, 1994, to the County Regional Planning Commission regarding the Valencia Marketplace proposal; and WHEREAS, the City of Santa Clarita provided formal comment to the Los Angeles County Regional Planning Commission in correspondence dated December 14, 1993, on the proposed project and DEIR, all to be part of the official record; and WHEREAS, the Los Angeles County Regional Planning Department staff's March 17, 1994 responses do not adequately address several of the specific questions raised in the City's December 14, 1993 comment letter, and did not address the testimony presented by the City on the project and DEIR to the Los Angeles County Regional Planning Commission on December 15, 1994 and January 2, 1994, nor did the responses reference the City of Santa Clarita and impacts to City services and facilities; and WHEREAS, the County's response to the City's comments indicate that the sales -related travel statistics from the DEIR air quality assumptions are reasonable for use in projecting the geographic source of project sales dollars; and WHEREAS, the County's response to the City's comments indicate that the project is only obligated to mitigate project impacts, not to overcome existing infrastructure deficits; and WHEREAS, the County indicates that, based upon project DEIR air quality and traffic statistics, 65% of project sales will come from within five miles of the project; another 22% of project sales will come from up to 17.5 miles away along the I-5 and SR 14 freeway corridors; and that 13% of sales will come from the San Fernando Valley; and WHEREAS, on March 30, 1994, the Los Angeles County Rea.. 90. 94-51 Regional Planning Commission considered and approved the tentative parcel map (TPM 8676), conditional use permit (CUP 92-075), and oak tree permit (OTP 92-075), for the proposed Valencia Marketplace project; and WHEREAS, the Los Angeles County Regional Planning Commission forwarded the Valencia Marketplace project to the Los Angeles County Board of Supervisors with a recommendation to approve the requested zone change and sub -plan amendment to allow the project; and WHEREAS, the City Manager's office authorized Community Development Department Staff to prepare the appropriate application materials to appeal the Los Angeles County Regional Planning Commission's action; and WHEREAS, Community Development Department Staff prepared an appeal of this project to the Los Angeles County Board of Supervisors to allow the Board an opportunity to review the project as a whole, and to address the fiscal policy issues associated with the Valencia Marketplace proposal; and WHEREAS, on April 6, 1994, the City filed an appeal to the Los Angeles County Board of Supervisors of the Los Angeles County Regional Planning Commission's conditional approval of the requested tentative parcel map, conditional use permit, oak tree permit, and recommended granting of a zone change and general plan amendment to allow the proposed Valencia Marketplace project. THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA CLARITA DOES HEREBY RESOLVE, DETERMINE AND FIND AS FOLLOWS: SECTION 1. The City finds that the DEIR is deficient and should be expanded to further analyze the impacts to biological resources, traffic and circulation (including Congestion Management Plan (CMP) issues), land use, aesthetics, noise, and the adequate provision of long-term infrastructure and service needs in the Santa Clarita Valley. SECTION 2. The DEIR should indicate the location of off- site restoration recommended as mitigation for the loss of wetlands and oak trees, and the time -frame and monitoring for these mitigation efforts. To preserve the majority of the site's oak trees, development should not occur within the 25.1 acre area designated by the County as Hillside Management. SECTION 3. The City of Santa Clarita generally does not support additional amendments to the County's Santa Clarita Valley Area -wide Plan, which was updated and adopted in 1990, The City's R.... N.. 94-51 General Plan Land Use Element Policy 5.4 specifically discourages the removal of the Hillside Management designation in unincorporated areas when urbanization proposals are made for such areas. The DEIR should examine an alternative to the project which preserves the area designated as Hillside Management. SECTION 4. The traffic analysis in the DEIR should be expanded to address potential impacts upon McBean Parkway from the project site to Valencia Boulevard, and on Lyons Avenue from the Interstate 5 Freeway to San Fernando Road. This analysis should also be expanded to address the impacts of a no parking zone, and restriping to six lanes, on Lyons Avenue. Further expansion of this analysis should also include recommended mitigation measures for any additional impacts which are identified. SECTION 5. In addition to roadway and intersection improvements recommended in the DEIR, the following recommendations should also be implemented with the project: Restripe McBean Parkway to six lanes; provide necessary traffic signal modifications to McBean Parkway and all impacted side streets; direct the County Traffic Engineer to work with the City Traffic Engineer to formulate appropriate traffic mitigation measures as needed. SECTION 6. The noise analysis in the DEIR should be expanded to address potential long-term impacts upon employees and patrons at the project site. SECTION 7. The aesthetic analysis in the DEIR should be expanded to include architectural details as viewed from the Interstate 5 Freeway, a scenic corridor. Cross-sections of the proposed grading should be included to illustrate the change in the site's topography from all inhabited areas and public roadways. Contour grading should be required per the County's Hillside Design Guidelines. Earth -colored dye should be used in all visible concrete drainage facilities to reduce the contrast between such structures and adjacent slopes. A project sign plan should be provided to the City for review prior to final approval and issuance of construction permits. SECTION 8. Under Goal 1 of the City of Santa Clarita General Plan Land Use Element, we seek to preserve the character of the communities and the integrity of the Santa Clarita Valley by permitting orderly growth through the synchronization of development with the availability of public facilities such as roads, sewers, water service and schools needed to support it. SECTION 9. Under Goal 2 of the City of Santa Clarita General Plan Land Use Element, we seek to achieve the development of a well-balanced, financially sound, and functional mix of residential, commercial, industrial, open space, recreational, institutional and educational land uses. SECTION 10. The City requests that further environmental assessment be conducted on this proposed project, including a good faith effort to evaluate potentially significant individual and cumulative impacts, feasible alternatives, and mitigation measures which would reduce the significant environmental impacts of the project. This evaluation, together with a response and full assessment of the environmental impacts identified in the City's comments should be included in the Final Environmental impact Report (FEIR) prior to certification and be carefully considered prior to any approvals being granted for this project. SECTION 11. A public transit facility should be provided at the project site. The County and/or developer should enter into an agreement with Santa Clarita Transit to fund transit services to the project site and adjacent areas. SECTION 12. The County's response to the City's comments do not clarify the relation between infrastructure, sales revenues, and the residential location of patrons, and does not provide an analysis to determine compliance with the County's Development Monitoring System to overcome the existing infrastructure deficit created by past development practices. SECTION 13. The City strongly disagrees with the County's assumption that ...the project is only obligated to mitigate project impacts, not to overcome existing infrastructure deficits." This project would clearly exacerbate the problems associated with the existing infrastructure deficit. Adequate mitigation requires facility improvements which also address the effects of secondary consequences related to the effects of primary consequences, not just directly from the project itself, even if those effects are several steps removed from the project in the chain of cause and effect. SECTION 14. Should the Los Angeles County Board of Supervisors approve this project, the City's position is that allocation of tax funds for capital improvements should be appropriated into a capital improvement program based upon a ratio commensurate with the initial and on-going impact which this project would have on those portions of the City and County experiencing those impacts. SECTION 15. Based upon the County's use of project air quality and traffic statistics to determine potential infrastructure impacts, the City takes the position that it is reasonable and consistent to use these statistics to determine the appropriate allocation of project generated tax revenues which should be committed to the City of Santa Clarita and the unincorporated area of the Santa Clarita Valley for the services, Rae.. N.: 94-51 utilities, and facilities needed to mitigate the potential impacts associated with this project, and to help overcome the existing infrastructure deficit. SECTION 16. The City of Santa Clarita has requested that, should this project be implemented, the County of Los Angeles make a commitment in perpetuity to allocate at least 800 of this project's future tax revenues to help eliminate the existing deficits and inadequacies to infrastructure, facilities, systems in the Santa Clarita Valley. SECTION 17. Based upon the Air Quality statistics used in the DEIR to assess the infrastructure impacts, it would be reasonable to use these statistics to determine the appropriate allocation of future project generated tax revenues which should be committed to the City of Santa Clarita and the Santa Clarita Valley. SECTION 18. The proportional allocation of project generated taxes, consistent with project DEIR air quality and traffic statistics, would justify a commitment of all project generated tax revenues to infrastructure improvements and services in the following proportions: 65% within five miles of the project; 22% to those areas along the Golden State Freeway and Antelope Valley Freeway corridors up to 17.5miles away (exclusively north of the San Fernando Valley); and 13% to the unincorporated areas of the San Fernando Valley. Based upon the these statistics, it appears appropriate that both the incorporated and unincorporated areas of the Santa Clarita Valley should receive 87% (65% plus 22%) of all taxes generated by this project. The City has requested 80% of these revenues. SECTION 19. The City supports the efforts of the residents and Town Council of Stevenson Ranch to ensure that the proposed Valencia Marketplace development does not result in impacts detrimental to their community, and the City therefore requests that the County work closely with the residents and Town Council of Stevenson Ranch to resolve outstanding major issues of importance to that community. SECTION 20. The City Clerk shall certify to the adoption of this Resolution and certify this record to be a full and correct copy of the action taken. PASSED, APPROVED AND ADOPTED THIS � day of , 1994. Mayor Reeo. No. 91-51. ATTEST: City Clerk STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES ) ss CITY OF SANTA CLARITA ) I, DONNA M. GRINDEY, CITY CLERK, DO HEREBY CERTIFY the above and 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 , 1993 by the following vote of Council: AYES: COUNCILMEMBERS: NOES: COUNCILMEMBERS: ABSENT: COUNCILMEMBERS: City Clerk ley council\r-94-51.mjc .... .. 94-51 City of Santa Clarita 23920 Valencia Blvd... Suite 300 City of Santa Clarita California 91355-2196 March 28, 1994 Phone (805)259-2489 Fax (805) 259-8125 Michael D. Antonovich, County of Los Angeles 500 West Temple Street Los Angeles, CA 90012 Fifth District Supervisor Room 869 SUBJECT: VALENCIA MARKETPLACE (COUNTY PROJECT NO. 92-075) Dear Supervisor Antonovich: The City of Santa Clarita appreciates the opportunity to participate in the County's project review and environmental assessment processes, and continues to thank you for assistance in this regard. As you know, we have provided written and verbal testimony to the Regional Planning Commission and County staff on the Valencia Marketplace proposal and the associated Environmental Impact Report (EIR), and have some unresolved concerns with the project. We anticipate that the Regional Planning Commission (RPC) will give final approval for the parcel map, conditional use permit, and oak tree permit associated with this project on March 30, 1994, and will also certify the project Final EIR at that time. Should the RPC take this action, it is our intent to appeal the decision to the Board of Supervisors. We understand that the Board of Supervisors will consider the General Plan Amendment and Zone Change required to implement the Valencia Marketplace project. We are requesting the appeal with an eye toward allowing the Board to obtain a comprehensive understanding of all aspects of the project by considering all of the entitlement requests together as a complete package. I hope that you will understand and appreciate that our approach to this project is in response to the uniqueness and special 'circumstances associated with the Valencia Marketplace proposal. We look forward to working with your office and the Board of Supervisors. Should you have any additional information or questions, please contact me at (805) 255-4905. Thank you. Sincerely, ✓Georg a Pederson Mayor cc: City Council Members George A. Caravalho, City Manager ad YlmrktpN O.mic PRINTED ON RECYCLED PAPER City of Santa Clarita 23920 Valencia Blvd. Suite 300 City of Santa Clarita California 91355-2196 March 24, 1994 Phone (805) 259-2489 Fax (805) 259-8125 James E. Hartl, Director of Regional Planning County of Los Angeles 320 West Temple Street Los Angeles, CA 90012 SUBJECT: VALENCIA MARKETPLACE PROJECT (PROJECT NO. 92-075) Dear Mr. Hartl: Thank you for the opportunity to review and comment on the Draft Environmental Impact Report (DEIR) prepared for this project. The City of Santa Clarita is a responsible agency under Section 21069 of the California Environmental Quality Act (CEQA). Our review of County staff's responses to our December 14, 1993, comment letter indicates that the majority of responses neither adequately address the specific questions raised in our letter, nor address the testimony presented on the DEIR to the Regional Planning Commission on December 15, 1993, and February 2, 1994. The responses also avoid reference to the City of Santa Clarita and the potential impacts to City services and facilities, as we had requested. CEQA requires that impacts and mitigation be discussed even if a project's effects cross jurisdictional boundaries. From a technical perspective, these responses do not comply with Sections 21092.5 and 21083 of CEQA. The DEIR contains many assessments of anticipated potential adverse impacts which do not adhere to the CEQA criteria for determining significant environmental effects. We are concerned that many of the responses imply that, because it is under County jurisdiction, the project will be made to comply with County codes through the acquisition of required permits. Simply acquiring a permit does not assure adequate mitigation of potential adverse impacts. Identification of impacts and viable measures to reduce those impacts, to the extent feasible, is a primary purpose of CEQA. Once again, we appreciate the opportunity to participate in the County's planning and CEQA processes. If you have any questions or additional information regarding this letter, please call Don Williams of my staff at (805) 255-4343. Sincerely, C� Lynn M. Harris Deputy City Manager - Community Development LMH:D MW: mj C:.h,trnrktplc9.mic cc: George A. Caravalho, City Manager Mayor George Pederson, and Santa Clarita City Council Los Angeles County Regional Planning Commission PRINTED ON RECYCLED PAPER City of Santa Clarita 23920 Valencia Blvd. Suite 300 City of Santa Clarita California 91355 January 5, 1994 Phone (805) 259-2489 Fax (805) 259-8125 Ms. Sally Reed Chief Administrative Officer County of Los Angeles Hall of Administration 500 West Temple Street Los Angeles, CA 90012 SUBJECT: VALENCIA MARKETPLACE PROJECT (County Master Case No. 92-075) Dear Ms. Reed: As you may be aware, the City of Santa Clarita City Council has recently taken a position of opposition to the Valencia Marketplace project proposed in the Santa Clarita Valley by the Riley, Pearlman, and Mitchell company on property owned by Newhall Land & Farming. The project site is located west of the 1-5 Freeway, immediately adjacent to the City. We are highly concerned over the impacts this 84 -acre urban scale regional commercial center will have on the City of Santa Clarita's ability to provide public services in both the incorporated and unincorporated areas of the Santa Clarita Valley. While we harbor some technical concerns over the project's impact to the environment, our primary point of opposition is the public policy issue raised by the development. This project will create new and substantial demands for urban/municipal services in the City and the Valley, and will generate new burdens on Santa Clarita's already inadequate infrastructure system. These new service demands must be met responsibly to prevent further deterioration of systems and service levels in the area, which in turn will require that new revenue sources be identified. This represents a direct impact to the City, and one that is currently not acknowledged or mitigated. Indirectly, the size and character of the commercial uses proposed will result in revenue loss to the City, as a percentage of existing sales tax revenues now coming to the City will be siphoned and captured immediately adjacent to -- but outside -- our corporate limits. In effect, the Valencia Marketplace represents a double -hit to the City: more infrastructure and higher service levels will be required, but less revenue will be available to do the job. , January 5, 1994 Valencia Marketplace Project Page 2 As only one example, an average of more than 26,300 new automobile trips a day are projected to be generated by the project. This added traffic volume will generate a direct need for a greater police presence and higher service levels in the City and Valley, both for traffic enforcement and public safety. Despite this fact, and despite information from the Sheriff's Department that police service levels in the Valley are already inadequate, no provision or mechanism for service expansion has been proposed by the applicant, nor has the Draft Environmental Impact Report prepared for the project mandated such mitigation. Again, this. is just one example, and there are many others. The infrastructure, facilities, systems, and service level deficiencies in the Santa Clarita Valley are well-known and well-documented by Los Angeles County. Roads, police services, park facilities and recreation programs, various forms of landscaping and other maintenance, and libraries, have all been inadequate in this area for years. Current fiscal problems experienced by all levels of government have not created these deficiencies, but have significantly exacerbated them. We now regularly hear about how "this park" or "that library" will be closed. In 1988, a study of many of these inadequacies was undertaken for the County of Los Angeles by Daniel, Mann, Johnson, & Mendenhall ("DMJM"). The final report ("An Analysis Of Infrastructure Needs", commonly called the "dimjim study") was completed in 1989, and concluded that the price tag to address infrastructure deficits in the Santa Clarita Valley alone would total over $911,800,000 (in 1988 dollars). Nor was the report exhaustive, as it did not address or include costs to bring police services or public schools up to adequate levels in the Valley. Additionally, many of these infrastructure deficiencies are comprehensively tracked by the Regional Planning Department through the computerized Development Monitoring System (DMS). This monitoring system, made apart of the County's General Plan as a result of litigation in 1985, continues to reflect serious system and infrastructure deficiencies in the Santa Clanta Valley, indicating that the findings and conclusions of the DMJM study have changed little over the last five years. I Based on the above, we believe that the Marketplace project presents the County with the opportunity to begin to address some of the historic deficiencies present in the incorporated and unincorporated areas of the Santa Clarita Valley. Toward that end, and with an eye toward the multi-million dollar costs involved to improve the infrastructure and service levels in this area, the City of Santa Clarita believes it reasonable that the County establish some method to allocate approximately eighty percent (80%) of the tax revenue projected to be generated by this proposal for use in the Santa Clarita Valley. This money, generated in the Valley, should remain here to help improve County services in the area, offset impacts to the City, and to reduce, as required of the January 5, 1994 Valencia Marketplace Project Page 3 County,, the existing service and facility deficits identified in the DMJM report and monitored by the DMS. If the County's own analysis of this issue shows that an amount less than 80% is reasonable or warranted, we would be happy to review that information. We would also request that this allocation be made to the Valley over and above current County expenditures in the area. I realize this is a complicated issue and I appreciate very much your time in reading this letter. If you have any questions regarding the City's position, or if you would like to meet to further discuss this issue, please call me at (805) 255- 4905. 1 look forward to hearing from you soon. GAC:dmw .Mr"d7.dm City of Santa Cjarita 23920 Valen, 31vd. Suite 300 City of Santa Clanta California 91355 December 15, 1993 Phone (805) 259-2489 Fax (805) 259.8125 Michael D. Antonovich, Fifth District Supervisor County of Los Angeles Hall of Administration 500 West Temple Street, Room 869 Los Angeles, CA 90012 SUBJECT: VALENCIA MARKETPLACE PROJECT (PROJECT NO. 92-075) Dear Supervisor Antonovich: I would like to take this opportunity to comment on the Valencia Marketplace project. We appreciate the continued cooperation of the County staff, the applicant, and the EIR consultant during our review of this project. We have provided technical comments on the Draft Environmental Impact Report (DEIR) prepared forthls project In our letter of December 14, 1993. Additionally, the City Council reviewed this project on a policy level at a public meeting on December 14, 1993, and while we share the technical concerns of our staff (in the areas of land use, oaks and biota, traffic, noise, aesthetics, and DMS compliance), we wish to also register our concern In the area of public policy as it relates to this development. Over the past several years, the Clry and the County have sought to work with each other in many ways to lessen the opportunities for divisiveness and promote partnerships for the betterment of all residents of the Santa Clarlta Valley. For several reasons, however, we feel this project may represent a setback to these efforts. We recognize that In the existing business climate, this project presents a Significant economic development opportunity for the County. We support economic development and have put forth significant resources In this area with some success. We further understand the need for government to work with applicants who provide such development. This appears to be a project deserving of serious consideration. At the same time, we find that we can not support the project as It currently stands. While we appreciate the County's need for the additional revenues to be generated by this project, we nevertheless feel this location Is Inappropriate for a project of this type and size. It Is o1 urban scale and nature, with concurrent urban service level needs. The project site Is located Immediately adjacent to, but outside of, the City. The applicant has indicated that this development will Include retail uses known as "category killers" which will deter similar types of development elsewhere In the City or Santa Clarita Valley. Impacts to City systems, services, and revenues will occur as a result of this project, yet nowhere (with the exception of traffic mitigation) has this been addressed. Frankly, this project will divert revenue from the City, have direct and Indirect Impacts on City service levels and facilities, and Valencia Marketplace Project December 15, 1993 Page 2 result in an overall detrimental effect on the community. The project will benefit the County general fund but, as a matter of public policy, we do not believe the actions of one jurisdiction should be deleterious to another jurisdiction, especially where the two have pledged cooperation We understand that the opportunity exists to provide infrastructure and service level Improvements to the area through the approval and development of this project. We feel this justifies a commitment, In perpetuity, to allocate at least 80% of the project's future sales tax revenues to the Santa Clarita Valley to eliminate existing infrastructure and service level deficits. The form of this allocation should be a matter of policy discussion, but could include establishment of a new or expanded B&T District in the SCV, some form of CIP fund, or some other mechanism to ensure that the revenues generated In the SCV remain in the SCV. Additionally, a Community Services District (CSD) should also be discussed, so as to fund the added services In the SCV — both City and County — that this project will necessitate. The identification of the services and facilities In need of such funding could be determined through analysis of the SCV's already deficient areas (and this project's added impact on them), as identified by the County's DMS. As just one example, we wish to discuss police service levels. The DEIR states that existing service levels in the area are less than desirable, and that the project will "Incrementally" increase response times and so on, meaning that already undesirable service levels will further deteriorate. The response letter from the Sheriffs Department (dated May 15, 1992), however, .Is -slightly stronger in its concern, stating that the project will significantly impact service ]ovals. The mitigation measure for this Impact states only that revenues from the project M" be used to increase services, but no requirement to do so is set forth. A CSD or similar mechanism appears appropriate to implement and guarantee that this mitigation actually occurs. In a related note, we also support the concerns set forth by the residents and Town Council of Stevenson Ranch. As you mayremember from a recent meeting, Stevenson Ranch residents are now discussing the possibility of annexing to the City. The potential Impacts of this project on those residents is fairly well documented In the DEIR, though the residents have raised several Issues not addressed In the DEIR: We understand that while the Stevenson Ranch Town Council has reached accord with the applicant in many areas, several outstanding Issues still remain, and a number of residents are stili opposed. We hope you will work with these residents, the Stevenson Ranch Town Council, and the City to address their Issues. This project will result in the removal of 105 of the 141 oak trees on-site, approximately 75% of the total on the property. This loss Is unacceptable in light of ordinances adopted by both the City and the County to preserve native oak trees In the Santa Ciarita Valley. The transplantation of existing trees Is not desirable due to the high mortality rate of this mitigation method. Consequently, all alternatives need to be explored, Including a reduction of project density In order to reduce this impact to an acceptable level. Valencia Marketplace Project December 15, 1993 Page 3 We are concerned with another amendment to the Santa Clarfta Valley Areawide General Plan, as this undermines the effectiveness of comprehensive planning. Careful consideration should be given to the potential conflicts this proposed project may have with adjacent land uses, and Its cumulative long-term Impacts. Traffic generated by this project will Impact several intersections and roadway segments In the City. We understand and appreciate that the applicant has worked with City staff In developing the traffic study, and hope this will continue so as to resolve all outstanding traffic issues. We fully expect mitigation of all Impacted Intersections and roadway segments within the City. In addition, and as Importantly, it should be noted that the project appears designed specifically for, and relies heavily on, the, continued use of traditional single - passenger vehicles for accessibility. (Site location, access, circulation, and parking all clearly point to this.) With regional efforts such as the Congestion Management Plan (CMP) underway to reduce this reliance, the project as designed may not be in compliance with regionally adopted goals and objectives to reduce vehicular congestion on the CMP network. Perhaps further refinement of the project to reflect this Is in order. In the spirit of the Clty-County Joint Planning program, we wish to ensure that this project minimizes environmental Impacts while providing the Santa Clarha Valley with maximum economic benefits. We seek to achieve balance and compatibility between land uses, Infrastructure, and quality of life -for Santa Clarlta Valley residents. Because of the nature and complexity of our concerns, we will be asking that the Regional Planning Commission continue the public hearing for this project pending receipt of additional information, and resolution of outstanding issues; we look for your support of this request. Your consideration of our concerns Is greatly appreciated, and we await your response to our comments. Sincerely, . . ,Ice H. Heldt V ayor JHH:MJC cc: Los Angeles County Board of Supervisors Members of the Santa Clarita City Council James E. Hartl, Director of Planning George A. Caravalho, City Manager City of Santa Clarita 23920 Valen, .Blvd.. Suite 300 City of Santa Clarita California 91355 December 14, 1993 Phone (805)259-2489 Fax (805) 259-8125 James E. Hani, AICP Director of Planning Los Angeles County Department of Regional Planning 320 West Temple Street Los Angeles, CA 90012 ATTN: Paul McCarthy, Assistant Section Head—Impact Analysis SUBJECT: COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR) FOR THE VALENCIA MARKETPLACE, PROJECT NO. 92-075; SCH NO.. 92061074 Dear Mr. Hartl: Thank you for the Notice of Completion and copy of the DEIR prepared for the above -referenced project. We appreciate the continued cooperation of the County the EIR consultant, and the applicant during our review of this project. The proposed Valencia Marketplace project SRO Is located Immediately adjacent to the City of Santa Clarita, south of Mc Bean Parkway, north of Pico Canyon Road, and east of the Old Road. As proposed by the Riley Pearlman Company, the applicant, the project would provide approximately 659,740 square feet of regional and community oriented retail commercial development on approximately 84 acres owned by the Newhall Land and Farm Company.. Project development would require 1.7 million cubic yards of grading, removal of 105 oak trees, and numerous Improvements to local Infrastructure, both In the County and the City. Required entitlements for this proposal Include a general plan amendment, a vesting tentative tract map, a zone change, a conditional use penult, and an oak tree permit. The City of Santa Clarita has reviewed the DEIR as a responsible agency pursuant to the California Environmental Quality Act, and has comments on the following environmental Impacts of this project: Land Use, Biology, Traffic, Noise, Aesthetics, and compliance with the Los Angeles County Development Monitoring System (DMS). LAND USE We acknowledge that an amendment to the County General Plan, along with rezoning of the property, Is required to allow this development. The proposed project land use Is Inconsistent with the County's five existing land use designations, and applicable general plan policies, for the project site. We are very concerned with the effects of another General Plan amendment for the Santa Clarlta Valley area. As the City has Indicated on previous projects (such as the Poe Company's proposals west of this project), we generally do not support General Plan amendments to the Santa Clartta Valley Areawide General Plan adopted In 1990, and we continue to emphasize the necessity for Valencia Marketplace DEIR Page 2 Integrated comprehensive planning In the Santa Clarlta Valley. As set forth by the City's General Plan, we discourage the removal of the Hillside Management (HM) land use designation in the Santa Clarita Valley, which would Include the northern 25 acres of the project site. The Valencia Marketplace project site is Immediately adjacent to, and within the planning area of, the City of Santa Clarita. It Is extremely likely that a project of this size and type will have valley -wide effects relating to regional and local mobility, air quality, economics, and the jobs/housing balance. Section II (Environmental Setting) of the DEIR briefly discusses existing and proposed land uses, along with plan consistency. A land use analysis should also be Included in Section III (Environmental Impacts) of the DEIR to specifically address the potential land use conflicts affecting the project site and adjacent property. The analysis should also Include recommended mitigation measures for all potential Impacts Identified, particularly on the already well-recognized service and infrastructure deficits In the Santa Clarita Valley (SCV). It is reasonable to anticipate, and is in fact expected by the applicant, that a large proportion of Valencia Marketplace customers will be attracted from outside the SCV, thereby Intensifying the demand on Infrastructure (particularly roadways) and services. To reduce this Impact, and overcome the existing infrastructure deficit, an on-going capital Improvement program should be funded and Implemented. This would justify a commitment, In perpetuity, to allocate a minimum of 80% of project generated sales tax revenuesto the SCV. This allocation would be used to eliminate the Infrastructure deficit which has existed In the SCV due to past development practices. To accomplish this, .these revenues could be placed In a specially created Capital Improvements Project fund, a newly created B&T District for the area, or Into some other funding mechanism which assures long-term benefit to the residents of the SCV. Additionally, some forth of Community Service District (CSD) should also be established and funded to provide for Increased service levels required by this project, both In the County and in the City. The CSD should cover both Incorporated and unincorporated areas, as the long-term service Impacts created by this project will likely occur without regard for political boundaries. These recommendations should be addressed In the Final EIR, and should be Implemented as conditions of project approval. Under any circumstance, conditions of project approval should assure timely implementation of mitigation measures relating to City services and facilities. BIOLOGY Implementation of the proposed project will require approximately 1.7 million cubic yards of grading, and the removal of vegetation over 95% of the site. According to the DEIR, there are four vegetative habitats occurring on-site: Southern Oak Woodland, Non-native Grassland, Coastal Sage Scrub -Chaparral, and Riparian -Southern Willow Scrub. Impacts to all four of these communities, Valencia Marketplace DEIR Page 3 summarized on page 94 of the DEIR, will be extensive and severe. Significant, potentially significant, and protected plant species on the site Include oak trees (Valley oaks, Coastal live oaks, and Valley/Blue oak hybrids) and native bunchgrasses. Additionally, Pearson's Morning Glory (a United States Fish and Wildlife "Candidate 2" species, and on the "watch list" of the California Native Plant Society), Is found on the site. Pico Creek traverses the project site west to east, and Is Identified as a "blue - line" stream on USGS quadrangle maps for the area. The DEIR Indicates that the portion of this drainage an the project site will be altered from the existing condition and conveyed through a box culvert to a subterranean drainage system. These Improvements will result in the loss of the existing Riparian - Southern Willow Scrub habitat. Proposed mltigatlon for the loss of riparian vegetation on-site Is contained within the streambed.alteration permit Issued by the California Department of Fish and Game (CDFG) In December of 1992. Under this permit, the applicant is required to restore/plant approximately 2.8 acres of riparian area In the Santa Clara River. The specific location of the proposed mitigation area(s) should be Idemifled in the DEIR. In addition to the off-site mitigation required by the CDFG, the open areas adjacent to the box culvert at either end should be rehabilitated for use as accessible open space. Proposed mitigation for the loss of native grasses on the site is to plant grasses of the same genus/species "off-site." Communication with the applicant Indicates that "off-site" is SEA 64. This should be Identified in the DEIR, and a general location and timeframe/monitbring program. specified as a condition of approval. The City of Santa Clartta has Identified oak trees as a rare and valuable resource In the Santa Clartta Valley. According to the DEIR, there are 141 oak trees on the site that are of sufficient size to be regulated by the LA County Oak Tree Ordinance. Of these, 105 are proposed to be removed, 36 for construction of The Old Road extension from Pico Canyon Road to Mc Bean Parkway, and 69 for the construction of the shopping center Itself. There are also three heritage oaks on the site, of which one Is proposed to be removed for the Old Road extension. As designed, this project will result in the removal of 105 of the 141 of the oaks at the project site. In light of the ordinances adopted by both the City and County to preserve native oak trees In the Santa Clartta Valley, staff has determined that this loss of oak trees is unacceptable, even with the recommended mitigation measures. Because much of the adjacent Southern Oak Woodland has been denuded, loss of these oak trees will create a significant cumulative biological Impact. Staff disagrees with the DEIR's assessment that this loss can be reduced to a level of insignificance, and Is opposed to any attempt by the applicant or property owner to Ignore the loss of these resources by adopting a Statement of Overriding Considerations. The project should be redesigned, and/or scaled down, to Incorporate more of the existing oak trees Into the project landscaping, and provide a larger open Valencia Marketplace DEIR Page 4 space area to preserve more oaks In a natural state. The DEIR Indicates that between 100 and 122 oak trees Occupy the 25.1 acre area designated as Hillside Management. Preserving this area would reduce the number of oak tree removals to 41 (or less). To reduce oak tree Impacts to an acceptable level, we recommend that the project be redesigned to preserve the Hillside Management area as undisturbed open space. TRAFFIC This project will generate approximately 26,333 average daily trips (ADTs) with 594 and 2,385 vehicles per a.m. and p.m. peak hours, respectively. It should be noted that, In the traffic study and supplements prepared for this project, the extension of McBean Parkway to The Old Road and The Old Road between McBean Parkway and Valencia Boulevard were not considered to be in place prior to project development. As part of the traffic: study, 22 Intersections were analyzed; twelve of these Intersections are within the City. The report Indicates that seven of the twelve Intersections within the City of Santa Clarlta will be significantly Impacted, and the recommended mitigation Is the sole responsibility of the developer. We request that these mitigation measures be required as project conditions of approval. The following Is a list of the Impacted Intersections and Indicated mitigation measures: Wiley Canyon Road and Lyons Avenue: Northbound - Constnuct/restripe for a separate right -tum, two through, and one left -tum lane. Eastbound - Construct/restripe a second left -tum and three through lanes. Westbound - Construct/restrlpe a separate right -tum, three through and one Teff -turn lane. The traffic signal Is to be modified. 1.5 Northbound Ramps and McBean Parkway: Northbound - Construct a second lett-tum lane, and signalize the Intersection when warranted. Orchard Village Road and McBean Parkway: Eastbound - Constr ucVrestripe the 3rd through lane. McBean Parkway and Valencia Boulevard: Even though this Intersection Is significantly Impacted by this development, the Traffic Study and DEIR do. not recommend any physical mitigation to this intersection. This needs to be Investigated and discussed In more detail in the Final EIR. Orchard Village Road and Lyons Avenue: Valencia Marketplace DEIR Page 5_ Northbound - Construct/restrlpe for separate right -turn, two through and one left lane. Southbound - Construct/stripe for two left -turn, two through and one right• turn lane. Eastbound - Construct/stripe for three through and two lett-turn lanes. Westbound - Construct/stripe for one left, three through and one right -turn lane. The traffic signal Is to be modified to Include left -turn phasing for all directions. Rockwell Canyon Road and McBean Parkway: Southbound - Construct/restrlpe for two left -turn, two through and one right -turn lane. Eastbound Restripe for the third through lane, Westbound - Restripe for the third through lane. The traffic signal Is to be modified to Include left -turn phasing for all directions. Orchard Village Road and Wiley Canyon Road: The traffic signal Is to be modified to Include left -turn phasing for the north -south direction on Orchard Village Road when warranted. The developer is to pay a fair share cost of this Improvement. In addition to the above improvements and mitigation measures, our staff finds that this project would have a significant Impact on McBean Parkway from the project site to Valencia Boulevard, and on Lyons Avenue, from the 1-5 to San Fernando Road, which the traffic study and DEIR do not address. It would be staff's recommendation to have McBean Parkway striped for six lanes in this area as a condition on the project. This would include traffic signal modifications at all signalized Intersections along that segment, as well as on the Impacted side streets. On -street parking along Lyons Avenue has always been a crttical Issue with area businesses and the City Council, and therefore we do not concur that the six -lane striping Is appropriate. Alternative mitigation should be Identified. The City requests that the developer expand the traffic study to address the impact of a no parking zone upon City businesses. This should also Include recommended mitigation measures for Identified impacts. Because this project includes a community-orlented commercial component, the DEIR should be expanded to address the potential Impacts that this proposed project may have on public transit. Public transit facilities should be provided to reduce total vehicle trips and parking demand, and to help achieve conformance with the Regional Mobility Plan, Congestion Management Plan, and the Air Quality Management Plan. The County should Impose a condition of approval requiring the applicant to enter into an agreement with Santa Clartta Transit to fund transit services to the project site and adjacent areas. It should also be noted that the project appears designed specifically for, and Valencia Marketplace DEIR Page 6_ relies on, the single -passenger vehicle for accessibility. With regional efforts such as the CMP underway to reduce this reliance, this project may not be in compliance with regionally stated goals and objectives to reduce vehicular congestion on the CMP network. The Final EIR should Incorporate additional analysis of this component of the transportation and circulation Impacts generated directly and Indirectly by this project. NOISE The project site Is located within the 70 decibel Community Noise Equivalent Level identified In the City of Santa Clartta General Plan. The primary noise source effecting the project site is the Golden State Freeway (1.5). The DEIR addresses the potential noise Impacts of the project to the adjacent residential uses to the west of the project she, however, there is no discussion of potential long -tens Impacts to the project site employees and patrons. Existing noise levels along the 1-5 corridor may Impact the commercial uses proposed for the project site. These potential impacts should be discussed and appropriate mitigation recommended as part of this analysis. AESTHETICS This project Is located along the City's southwest boundary along the heavily travelled 1-5 corridor and constitutes a primary and essential "gateway" to the City and the Santa Clarha Valley. The illustrations of the building frontages show little detail to clearly illustrate the "Mediterranean" architectural design proposed for this project by the applicant. In particular, the building facades along 1-5 should be shown In greater detail to communicate to the decision - makers, area residents, the City of Santa Clartta, and the public, what the project will look like from 1-5 (a scenic corridor).. An 80 -foot cut slope Is referenced In the DEIR, but is not shown In elevation view. This should be illustrated. Again, we oppose the removal of the Hillside Management (HM) land use designation. If this cut slope encroaches Into the 25.1 acre HM area, then the project should be redesigned to preserve this area as open space to adequately reduce aesthetic Impacts. if this 80 -foot cut slope Is not within the HM area, then the project should be redesigned to conform with the County's Hillside Management Policies and Design Guidelines. The County should require, as a mitigation and condition of approval, that contour grading and landscaping be Implemented to minimize disruption to the hillsides not located within the HM designation. Concrete used for drainage swales should Incorporate an earth -colored dye to reduce contrast of the concrete color with that of the adjacent slope face. The EIR did not include a conceptual sign plan for the project. Because the project site is adjacent to a scenic corridor and an established residential area, the aesthetics analysis should address the potential Impacts which may result from signage. Specifically, pole signs should not be permitted for this development. (The applicant has Indicated In meetings with City staff that pole Valencia Marketplace DEIR Page 7 signs are not proposed as part of the she design, but the Issue Is not addressed Within the DEIR) We request that exterior elevations for buildings and signs be provided to the City for review prior to final approval and building permit Issuance. DEVELOPMENT MONITORING SYSTEM (DMS) COMPLIANCE The project DEIR makes several references to the Los Angeles County DMS, but falls to Incorporate a cumulative analysis or evaluation of the project's Impact on the services or facilities monitored under the DMS. The DEIR Indicates that the DMS data base, factors, criteria, and so on were used In analyzing project Impacts (except where project -specific factors are known), yet no cumulative information is available In the DEIR. The City requests that an evaluation of this project's Impacts on the DMS, specifically and comprehensively Identifying areas of deficiency or adequacy, be undertaken and Incorporated Into the DEIR. As one example, the DEIR Indicates that police services in the area are currently operating at a less than desirable level and will be further Impacted by this project. This will be off -set, according to the DEIR, by revenues generated by the project If such revenues are used to fund added services. The proposed mitigation, however, Is Inadequate as It states only that such revenues could be used In this manner, but makes no actual provision for this to occur. Consequently, this mitigation measure can not be Incorporated as a condition of project approval as It Is currently drafted. We find this to be a serious deficiency, and one example of why the requested DMS analysis should be Incorporated for all systems and services so monitored. Due to the nature and complexity of some of the additional information and analysis requested, the City respectfully requests that this project be continued to a future date to allow adequate time for the provision and review of new Information. Thank you again for the opportunity to review and comment on the DEIR for this proposed project We would appreciate being kept apprised of the project's status as It moves through the planning approval process, and look forward to reviewing the Final EIR In Its entirety once it becomes available. Should you have any questions regarding our comma , or if you would like clarification or additional Information, please call me at (8DW5' 255 4330. rC Sincerely, LYNN M. HARRIS DEPUTY CI MANAGER COMM;Ur. DEVEL PMENT M. Williams Planner DMW:MJC