HomeMy WebLinkAbout1994-04-26 - AGENDA REPORTS - VALENCIA CO MGMT US ARMY COE (2)AGENDA REPORT
NEW BUSINESS City Manager Approval
Item to be presented y:
Lynn M. Harris
DATE: April 26, 1994
SUBJECT: VALENCIA COMPANY'S NATURAL RIVER MANAGEMENT CONCEPT
PREPARED FOR A SECTION 404 GENERAL PERMIT APPLICATION TO THE
U.S. ARMY CORPS OF ENGINEERS (COE)
DEPARTMENT: Community Development
BACKGROUND
The Valencia Company has submitted an application to the COE fora Section 404 General Permit.
('404 Permit"). The Valencia Company's Natural River Management Concept (NRMC) has been
developed by the Valencia Company as a long-range development strategy for forty-nine projects
associated with its land holdings along the Santa Clara River floodplain, and is the basis for the
Section 404 General Permit application. (A full description of the project, and maps of project area,
are included in the Special Scoping Notice, attached.)
Project build -out is expected over an approximately 20 year period, and includes levees, bridges,
side drains, and utility crossings. These improvements have been proposed by the Valencia
Company to satisfy river conservation, flood protection, water quality management, and traffic
circulation needs. The NRMC approach considers all of these projects and their cumulative effects
on the River as a dynamic system.
We are appreciative and supportive of the applicant's efforts toward comprehensive planning as
it pertains to the long-term development and preservation of the Santa Clara River. Based on our
review, the NRMC may help the Valencia Company, the City, the COE, the Federal Wildlife Service,
the California Department of Fish and Game, and many others to realize mutual goals and the
ultimate potential of the River. Of especial note, the NRMC proposes that the River and its main
tributaries will remain as "soft -bottom channels", and that bank stabilization will be done with
ungrouted rip -rap material, not concrete and gunite.
While the primary purpose of the NRMC is to attain a comprehensive 404 Permit, the document also
addresses the concerns of the County Department of Public Works (DPW) regarding flood control
design standards and system maintenance, while incorporating wildlife and habitat conservation
standards (mostly streambed avoidance) to respond to Issues raised by local, state, and federal
agencies. In doing so, the NRMC utilizes the natural floodplain wherever habitat conservation, land
development, and transportation objectives can be met.
The Addendum to the Draft NRMC includes a Draft Environmental Assessment (EA) prepared for
the Valencia Company by a consultant, and includes biological reports for flora and fauna, a
drainage concept, and the General Section 404 Permit. Valencia Company representatives believe
that this approach provides adequate environmental analysis and mitigation and project alternatives
to satisfy federal and state environmental requirements, and have requested that the COE adopt
the document in lieu of preparing an Environmental Impact Statement (EIS).
APPROVED Agai-3Item:
According to the Draft EA, of the 1290 acres in the project area, an estimated 46 acres defined as
"Waters of the United States" would be impacted. Additionally, In the riparian corridor, negative
impacts to 62.4 acres and positive impacts to 67.2 acres would result. The Draft EA analysis is
partly based on assumptions of certain roadway alignments being developed, which have not been
reviewed by the City for consistency with the General Plan Circulation Element. These assumptions
appear logical, however, the impacts associated with road construction may differ with each
alternative alignment and may not be compatible with the City's overall circulation plan. The NRMC
appears to be consistent with most City General Plan policies concerning river development.
While staff generally supports this approach to development along the River, there are several
concerns to be worked out with the Valencia Company and the COE as follows:
1) This project may conflict with the Santa Clara River Trail project approved by the City in
January of 1994. Coordination with the Valencia Company staff must occur to avoid this
conflict.
2) This project should be coordinated with the Santa Clara River Management and Enhancement
Plan, currently under preparation, which includes the entire reach of the River.
3) The NRMC addresses 49 known projects, in and adjacent to the River, most of which are
proposed by the Valencia Company, but a few of which are proposed by the City and/or private
developers. Staff is concerned that other projects, which may not have been included, may
require unforeseen changes to the NRMC because they have not been included in this review.
We suggest further discussion between the Valencia Company, the City, and the COE to
Identify the potential for such problems and a methodology for handling such changes.
The original public review period deadline for this project was April 16, 1994, but has been extended
by the COE to April 30, 1994, to allow more time for review by the public, private concerns, and
agencies. This extension also allows for comments by the City Council to be forwarded to the COE
for use in their deliberations over Issuance of the 404 Permit. Finally, the COE has indicated that
it may hold a local public scoping meeting -- in response to the City's request -- after the closure
of the public comment period. We will keep the Council apprised.
RECOMMENDATION:
1) Express general support for the proposed concept;
2) Direct staff to prepare and submit comments stating the City's position on the Valencia
Company's Natural River Management Proposal to the U.S. Army Corps of Engineers, and
continue to monitor this permit process;
3) Direct staff to continue working with the Valencia Company on this proposal to help achieve
the General Plan goals and objectives applicable to the project site.
ATTACHMENTS:
1) March 16, 1994, Special Scoping Notice from COE;
2) April 6, 1994, letter to Colonel R.L. Vanantwerp;
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LOS ANGELES DISTRICT
U.S. ARMY CORPS OF E
`SPECIAL SCOPING NOTICE
to consider a
GENERAL PERMIT
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VALENCIA COMPANY'S PROPOSED SANTA CLARA RIVER MANAGEMENT PLAN
("Natural River Management Concept")
Public Notice No. 94 -504 -CC
Comment Period: March 16, 1994 through April 16, 1994
Applicant
Valencia Company
23823 Valencia Boulevard
Santa Clarita, California 91355
Contact
Mr. Mark Subbotin
Valencia Company
(same as Applicant address)
Project Location (Proposed General Permit Area),
The Santa Clara River from Castaic Creek east to one-half mile above the
Los Angeles Aqueduct, which is upstream of Bouquet Canyon Road; San
Francisquito Creek from the Santa Clara River to a point 2.9 miles
upstream; and the Santa Clara River -South Fork from the Santa Clara River
to a point 2.9 miles upstream. other tributaries are not covered by this
proposed General Permit. Some reaches (sections of streams or river)
within the General Permit Areas are within the authority of the City of
Santa Clarita, Los Angeles County, California and other reaches are
solely within the authority of the County of Los Angeles, California.
(See Figure 1 for details.)
ACtivity
At the request of the Valencia Company (the Applicant) and after
considerable evaluation, the Los Angeles District, U. S. Army Corps of
Engineers (Corps) is requesting input from the public on the
appropriateness of a General Permit for 49 specific activities,
including levee linings, bridges, side drains and utility crossings,
within the project location (Figures 1-6). For a description the General
Permit, the Applicant proposed alternative permitting procedure for
individual projects, project history, and additional project details see
below under Additional Information and Applicant Verbatim Submittal.
Additionally, the Proposed General Permit with biota reports, and the
Applicant's Draft Environmental Assessment are available for review.
Comments:
Interested parties are invited to provide their views on the public
interest in, and the appropriateness of, the proposed General Permit; the
adequacy of the Applicants draft Environmental Assessment and proposed
mitigation measures; the need for an Environmental Impact Statement based
on the current proposal and mitigation; the proposed Scope of Analysis
for the environmental documentation; etc.. Also, 1) include any impacts
resulting from issuance of the Proposed General Permit that might result
in more than minimal impacts if the General Permit is issued, and 2)
wherever possible, include actions the Applicant could take to reduce
those impacts to minimal. (Note, under NEPA, impacts can be reduced
through the use of mitigation. For example significant impacts can be
reduced to less than significant, or to minimal.)
These comments will become part of the record and will be considered in
the decision as to whether to proceed with a Public Notice for the
General Permit. Within the comment period noted above, written comments
should be mailed to:
U.S. Army Corps of Engineers
ATTN: CESPL-CO-R-CC
P.O. BOX 2711
Los Angeles, California 90053-2325
ADDITIONAL INFORMATION
General Permit Criteria
A general permit is an authorization by the Department of the Army issued
on a nationwide or regional basis for 1) category(s) of activities when
those activities are substantially similar in nature and 2) when those
activities cause only minimal individual and cumulative environmental
impacts (33 CFR Part 323.2(h)). Under the Applicant's proposal, prior to
implementation, the details of each of the 49 specific projects proposed
for the General Permit would be reviewed by the Corps for conformance
with the General Permit. The Corps has made a preliminary determination
that the activities proposed are substantially similar in nature insofar
as they are located within a contiguous area, are part of,a single
management plan, and are normal activities necessary for access and flood
management in a large drainage. General permits are valid for a maximum
of five years. However, it is expected that if the activities occuring
during the five years meet general permit criteria above, the General
Permit, if issued, will be reissued.
Project History
On March 30, 1987 the Corps issued an after -the -fact permit Number 86-
255-RH to the Valencia Company to resolve an enforcement case. Special
Condition a. of that permit stated:
"The permittee shall develop a long-range management plan for the
biological resources associated with the Santa Clara River within the
reach under the ownership of the permittee, east of the confluence
with Castaic Creek. This plan shall provide for the management,
2
conservation, and enhancement of those resources which may
potentially be affected by future development projects proposed by
the permittee. This plan shall retroactively include the reach of
the Santa Clara River affected by this permit. Consideration of any
future permit applications within the subject planning area shall be
contingent upon reasonable progress by the permittee towards
completion of the management plan."
To this end, a Notice of Intent to Prepare a Draft Programmatic
Environmental Impact Statement (DPEIS) was published by the Corps in the
Federal Register on October 10, 1990. Comments were received by the
Corps. Valencia Company initiated preparation of the DPEIS. However,
during preparation of the DPEIS, the Valencia Company decided that an
PEIS would not meet their permitting needs.
As a result, the Valencia Company is proposing an Alternative Permitting
Process (see below) and a project that they believe meets the criteria
for a General Permit while at the same time meeting the requirements of
permit 86-255-RH, Condition a..
To meet the general permit requirement for minimal individual and
cumulative environmental impacts, the Valencia Company has submitted a
"Natural River Management Concept" (NRMC) for the Proposed General Permit
area which reduces the acreage of impacts within the banks of the
proposed General Permit area from over 700 acres, as originally proposed
at the time of the DPEIS, to approximately 62 acres. In addition, the
Valencia Company is proposing to convert approximately 67 acres of
adjacent uplands (primarily agricultural) to river bottom and include
this acreage in the NRMC area. The acreage to be added to the NRMC area
in this manner exceeds the proposed River bottom loss by a few acres. In
addition, Valencia Company and John M. Tettemer and Associates are in the
process of negotiating a minimum maintenance agreement with L.A. County
Department of Public Works.
Scope of Analysis - The Federal action for this project would be the
issuance of a General Permit. Impacts that would not be a result of the
Federal action, either directly, indirectly, or cumulatively, would not
be within the scope of impact analysis. The Corps is requesting comments
on the preliminary Scope of Analysis, and on the impacts within the
preliminary Scope of Analysis.
Figures 2-6 show the location of the existing banks and proposed levees,
as well as the within -banks areas delineated by the Applicant. (Within -
banks areas are not necessarily coincident with Corps jurisdiction.)
In addition, the Valencia Company commissioned an independent delineation
of the Corps' jurisdiction. (See Figures 7 and 8, for sections of the
delineation in the vicinity of Bouquet Canyon Road and at the Proposed
Commerce Center Drive.) Tributaries outside the NRMC drainages are not
included in the delineation.
The physical area of direct impact from this project is any area within
the Corps' jurisdiction, i.e. "waters of the United States" including
wetlands and other special aquatic sites as defined in 33 CFR 328.3. The
Corps is in the process of evaluating the boundaries of Corps
jurisdiction along the General Permit area.
The Corps will review impacts to any aquatic -related or other resources
including willow -cottonwood stands, alluvial scrub, or coastal sage scrub
3
nabitat that could be impacted as a result of the proposed General
Permit. However, the Applicant has indicated that while the No Action
(no General Permit) alternative would require them to stabilize the
river/stream outside of the Corps' jurisdiction, it would not preclude
development except within the Corps' jurisdiction. Under this scenario,
impacts that are expected to occur from development or other activities
without the need for Federal action would not be considered within the
Corps' scope of analysis. For example, impacts to alluvial scrub habitat
that would be impacted regardless of whether a General Permit is issued,
would not be within the scope of analysis.
Evaluation Factors
The decision whether to proceed with the General Permit process (i.e.
issuing a Public Notice for the General Permit) will be based on comments
on this Special Scoping Notice of the probable impacts .including
cumulative impacts of the proposed activity on the public interest.
All factors relevant to the proposal will be considered including the
cumulative effects thereof. Factors that will be considered include
conservation, economics, aesthetics, general environmental concerns,
wetlands, cultural values, fish and wildlife values, flood hazards, flood
plain values, 'land use, navigation, shoreline erosion and accretion,
recreation, water supply and conservation, water quality, energy needs,
safety, food production and, in general, the needs and welfare of the
people. In addition, the evaluation will include consideration of the
EPA Guidelines (40 CFR 230) as required by Section 404 (b)(1) of the
Clean Water Act.
APPLICANT VERBATIM SUBMITTAL
THE FOLLOWING PROJECT INFORMATION AND DISCUSSION OF THE PROPOSED
PERMITTING PROCESS IS PROVIDED VERBATIM AS SUPPLIED BY THE APPLICANT AND
DESCRIBES THEIR PROPOSED PROJECT. EDITORIAL COMMENTS NOTED ARE PROVIDED
BY THE CORPS. THE CORPS DOES NOT NECESSARILY CONCUR WITH THE APPLICANTS
SPECIFIC PROPOSAL. HOWEVER, THE CORPS, CALIFORNIA DEPARTMENT OF FISH AND
GAME, U.S. FISH AND WILDLIFE SERVICE, AND THE LOS ANGELES COUNTY
DEPARTMENT OF PUBLIC WORKS, GENERALLY SUPPORT THE LONG TERM PLANNING OF
THIS AREA AND THE NO MAINTENANCE CONCEPT.
General Permit: The General Permit includes all of the
impacts to the River within the General Permit area that
are expected over the next 15 to 20 years. These impacts
can be identified now since they have been masterplanned
by their current owner. The projects identified may be
built by various applicants. (Editors Note: an applicant
may be Valencia Company (the Applicant) or another entity
such as a contract developer, public agency, etc..) All
applicants will be required to comply with the terms and
conditions of the proposed General Permit. The General
Permit projects include 31 levee linings, 15 of which
will not impact waters of the United States, 7 bridges,
9 side drains, and 2 utility crossings. Detailed
descriptions of the projects and their impacts are
included in the General Permit documentation.
4
The General Permit river reaches contain approximately
1,290 acres of river bottom. Through avoidance
minimization and alternative project design, the General
Permit projects impact approximately 62.37 acres of the
River and add approximately 67.20 acres to the River
which results in the addition of 4.83 acres of open river
bottom. Through the use of advance mitigation procedures
including mitigation banks, no net loss of wetland
habitat is expected to occur. The River will remain as
a soft -bottom river to allow natural functions to
continue. In addition, the levee linings will be
constructed with ungrouted riprap to allow vegetation to
reestablish itself.
The amount of open river bottom will be increased because
a Natural River Management Concept has been developed for
the General Permit area. This concept led to a river
design with no bank stabilization in some areas and,
where necessary, the lining of levees along or near
existing banks. The result is that major portions of the
River and its sensitive habitat areas are undisturbed.
The River's natural processes including stream braiding,
plant growth, and river dynamics remain essentially
unchanged.
A study entitled "Determination of Manning's `n' for the
Natural River Management Concept to be Applied to the
Santa Clara River from Castaic Creek to the Los Angeles
Aqueduct, San Francisquito Creek, and Santa Clara River,
South Fork," by John M. Tettemer & Associates, Ltd.,
dated June, 1993 has been approved by the Los Angeles
County Department of Public Works. This report
identifies a composite "n" value for a "no maintenance"
flood control facility design in the General Permit area.,
It is expected that flood control maintenance for future
projects will be limited to restoration of damaged levee
linings, removal of debris from bridge piers, and.
maintenance of side drains. (Editors Note: Although the
technical determination of the coefficient of friction
(Mannings "n" value) have been agreed upon, other issues
with the County remain to be resolved. However, Los
Angeles County Department of Public Works has indicated
that they hope to be able to approve such a plan.)
The Alternative Permitting Procedure: The proposed
alternative permitting procedure identified establishes
the requirements under which applicants may receive a
letter of approval authorizing fill in waters of the
United States for General Permit projects. If the
General Permit is approved, the District Engineer will
suspend the application of all Nationwide Permits within
the General Permit area, except for Nationwide Permit 3
(Maintenance), 4 (Fish & Wildlife Harvesting,
Enhancement, and Attraction Devices and Activities), 5
(Scientific Measurement Devices), 6 ( Survey Activities),
8 (Oil ,& Gas Structure), 21 (Surface Mining Activities),
27 (Wetland Restoration Activities), 32 (Completed
Enforcement Actions), 37 (Emergency Watershed Protection)
[.7
and 38 (Cleanup of Hazardous and Toxic Waste) (33 CFR
330.2 et Seg).
The process by which an applicant receives authorization
to fill waters of the United States pursuant to the
General Permit will be shortened and simplified. The
Corps' review time would be reduced to twenty days.
Substantive issues will have been satisfied at the time
of General Permit approval since they have been agreed to
in advance and identified in the Permit. Since the
regulatory agencies have had substantial involvement in
the development of the General Permit their participation
in the subsequent authorization deliberations will be
correspondingly less. Essentially, if an applicant
complies with the project and its impacts as described in
the Permit it can expect timely authorization to proceed.
The Corps will consider the following issues to have been
resolved if the General Permit is approved:
1) The banks of the rivers within the General Permit
area have been mapped and are considered the areas
of interest for the purpose of this General
Permit.
2) Mitigation will be required for impacts within the
areas of interest. The designation of mitigation
sites and a proposed mitigation plan ensures no
net loss of functions and values.
3) The public interest review will be considered
complete.
4) Under 40 CFR 230, the alternatives analysis is
divided into three steps: avoidance, minimization,
and mitigation. In approving the General Permit,
the Corps and the U. S. Environmental Protection
Agency agree that all three portions of the
alternatives analysis have been met (40 CFR
230.6(a)). That is, the General Permit has
established development needs through the existing
comprehensive plan; has established the degree to
which these can be satisfied without discharging
to waters of the United States; and has avoided
impacts to wetlands to the extent practicable,
taking into account the cost, logistics, and
comprehensive plan. (40 CFR 230.10(a), 33 CFR
320.4 (7) (2)) .
These issues will not be reopened when an
applicant submits an Authorization Request Letter
which is reviewed for compliance with the General
Permit.
Project Authorization and Administration
A. Authorization Request Letter (ARL): Authorization
to discharge fill or dredged material into waters
of the United States within the General Permit
area is initiated by the submittal of an ARL by
the applicant to the Corps.
12
B. Review Procedure
Application: The ARL shall include plans and
specifications, approved CEQA documentation, mitigation
information, Section 401, Section 7, and archaeological
data as applicable. If complete and in compliance with
the projects identified in the General Permit, the ARL
will be approved within 20 days.
Complete Submittal: An ARL will be returned to the
applicant if it is not complete and/or in compliance.
Once an ARL is reviewed and approved for conformance with
the General Permit, the ARL will be signed by the Corps
and returned to the applicant. Construction can begin
upon receipt of the signed ARL. If the ARL is not
returned within the 20 -day period, the applicant may move
forward in accordance with the conditions and
requirements of the General Permit.
Life of General Permit: It is intended that the
provisions of the General Permit remain in effect
throughout the buildout period of the projects which is
15 to 20 years. Therefore, the General Permit with its
alternative permitting procedure is expected to be
renewed in its original form every 5 years. It shall not
be modified without a public hearing.
PRELIMINARY REVIEW OF SELECTED FACTORS
EIS Determination - When the Notice of Intent to Prepare a Draft
Programmatic Environmental Impact Statement (DPEIS) was published by the
Corps in 1990, the Corps felt project impacts were potentially
significant. Since that time the Applicant has revised their proposed
project to 1) reduce impacts to a level that they believe meets the level
required for a General Permit, i.e. minimal and 2) avoids the need for an
EIS, i.e. potential impacts due to the Federal action are below the
significant level. The Applicant has prepared a draft Environmental
Assessment that they believe demonstrates that individual and cumulative
impacts will be avoided, minimized, and mitigated below a level of
significance thereby precluding the necessity of preparing an EIS as
described under 33 CFR 230.
Endangered Species: Preliminary determinations by the Applicant indicate
that implementation of the proposed projects in the General Permit area
may affect the following Federally listed and proposed endangered species
(Unarmored threespine stickleback (UTS), least Bell's vireo, Red -legged
frog, and the Willow flycatcher) or designated critical habitat.
Threespine stickleback and Critical Habitat for least Bell's vireo are
known to occur within the proposed General Permit area. The applicant
has informally coordinated -with the U. S. Fish and Wildlife Service on
these species. The Corps is responsible for initiating formal Section 7
consultation pursuant to the Endangered Species Act of 1973 for
threatened and endangered species that may be affected by the project.
As proposed by the Valencia Company, each applicant would be responsible
for seeking additional Section 7 consultations that may be required for
new species listed during the life of the General Permit.
Cultural Resources: A records search of the archaeological archives was
completed by Dr. Lewis Tartaglia on February 10, 1991. The records
search disclosed potential historical sites within the General Permit
area. Under the Applicant's proposal, for each specific project, an
applicant would be required to comply with Section 106 of the National
Historic Preservation Act. Each perspective permittee would be
responsible for notifying the district engineer if the activity might
affect any historic properties listed, determined to eligible, or which
the prospective permittee had reason to believe might be eligible for
listing on the National Register of Historic Places.
Rater Ouality: Under the Applicant's proposal, a Master Section 401 will
be "sought from the Regional Water Quality Control Board for the General
Permit projects.
Mitigation Proposed: Under the Applicant's proposal, each project would
insure no net loss of waters of the United States. Applicants would be
required to provide mitigation in advance to compensate for General
Permit project impacts. Mitigation would either be in the form of added
river bottom or an approved mitigation bank within the River. At this
time Valencia Company is proposing to plant a 5 -acre mitigation bank
immediately upon issuance of the General Permit to provide advance
mitigation.
Proposed Special Conditions: The Applicant's proposed special conditions
can be found in the General Permit document and are also discussed in the
Draft Environmental Assessment provided by the Applicant.
Scoping Meeting - At this time the Corps is not planning to hold a
scoping meeting, but requests for a Public Hearing will be considered if
and when a Public Notice is issued in conformance with the General Permit
process.
A copy of the General Permit application including biota reports, and a
draft Environmental Assessment provided to the Corp by the Applicant, may
be reviewed at the following offices (see attached sheet for addresses,
phone numbers and available hours):
U. s. Army Corps of Engineers Los Angeles District;
U. S Environmental Protection Agency, San Francisco Office;
U.S. Fish 6 Wildlife Service Ventura and Carlsbad. Offices;
California Department of Fish and Game Long Beach;
The Valencia Company;
The City of Santa Clarita;
Los Angeles County Regional Planning;
The Applicant's draft Environmental Assessment is also available on
request from this office. (The General Permit application cannot be
provided by the Corps due to color graphics and large foldout maps.)
For additional information please call Cheryl Conel of my staff at (213)
894-0348 or (213) 894-5606. This Special Scoping Notice is issued by the
Chief, Regulatory Branch.
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City Of
Santa Clarita
23920 Valencia Blvd.
Suite 300
City of Santa Clarita
California 91355
April 6, 1994
Phone
(805)259-2489
Fax
(805)259-8125
Colonel R. L. Vanantwerp
U.S. Army Corps of Engineers, Regulatory Branch
300 North Los Angeles Street
Los Angeles, CA 90012
RE: PUBLIC NOTICE NO. 94 -504 -CC (GENERAL PERMIT FOR SANTA CLARA RIVER,
APPLICANT: VALENCIA COMPANY), REQUEST FOR A TIME EXTENSION OF
THE PUBLIC REVIEW PERIOD FROM APRIL 16, 1994, TO MAY 16, 1994, AND A
REQUEST FOR A PUBLIC SCOPING MEETING WITHIN THAT TIME FRAME.
Dear Colonel Vanantwerp:
Thank you for the notice on the above project and the opportunity to review the
Section 404 General Permit for the Valencia Company's proposed Santa Clara River
Management Plan. We welcome the opportunity to work with the Corps and the
applicant in this regard, and to be included in the consideration of this important,
precedent -setting proposal. We especially wish to thank Ms. Cheryl Conel of your
staff, who has taken time from her busy schedule to help us understand the Plan
and the Corps' 404 Permit process.
We are presently engaged In a mufti -disciplinary review of the 404 Permit documents
furnished to us by the applicant, and while our review of the proposal is not
complete, we are already appreciative and supportive of the applicant's efforts
toward comprehensive planning as it pertains to the long-term development and
preservation of the Santa Clara River. In many ways, the Valencia Company's
Management Plan will help us all -- the Corps, the City, the Federal Wildlife Service,
the California Department of Fish and Game, and many others -- to realize mutual
goals and the ultimate potential of the Santa Clara River.
We believe that, given time and understanding, this proposal will receive community
and regional support, and become a model for other planning and riparian
conservation efforts throughout the state. To allow this to occur, we would
respectfully ask that the Corps grant the City and the community a thirty (30) day
extension of the public comment period, from April 16, 1994, to May 16, 1994. We
ask this for the following reasons:
1) The extension would allow the Corps to hold a local scoping meeting on the
proposal, both to solicit information from the public, public agencies, and/or
impacted landowners, and to answer any questions from the same. We believe
this would be an excellent opportunity for the merits of the proposal to be
presented so that a broad-based consensus on the Valencia Company's River
Management Plan may be reached;
April 6, 1994
Letter to Colonel R. L. Vanantwerp
Public Notice No. 94.504 -CC
Page 2
2) The extension would allow the public, the City, and other interested entities to
complete a comprehensive and reasonable analysis of what is obviously an
intricate and complex proposal with far-reaching potential for all the parties
Involved. Given the many months invested in the Management Plan's
formulation, as well as the funds expended by the applicant for Its
development, we believe the proposal deserves this extra consideration; and
3) The extension would allow the Santa Clartta City Council the opportunity to
recleve a formal presentation on the proposal (on either April 26th or May 10th),
and to subsequently offer the applicant and the Corps the Council's Informed
opinion on the concept. For several reasons, this will likely not occur without
the Corps' assistance in extending the existing comment deadline to May 16th.
Given the positive approach forwarded by the applicant towards compatible
development and conservation of the Santa Clara River's many valuable resources,
we believe a community scoping meeting would go a long way towards achieving
recognition and support for the proposal, and would allow all parties to understand
how their respective and mutual goals will be attained under its auspices.
Thank you again for including the City in the review process for the Santa Clara
River Management Plan/404 Permit. We would be happy to assist you and your staff
in arranging a time, date, and venue for a scoping meeting in the Santa Clarita
Valley, or in providing you with any Information you may request. Should you have
questions or concerns regarding this letter, or if I may personally help you in any
way, please call me at (805) 255-4345.
Sincerely,
Lynn M. Harris
Deputy City Manager
Community Development
LMH:DMW:m(c
cc: Thomas Dierckman, Senior Vice President - Newhall Land and Farm
Jeff Kolin, Deputy City Manager - Public Works