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HomeMy WebLinkAbout1996-11-05 - AGENDA REPORTS - NEWHALL RANCH PLAN (2)CITY OF SANTA CLARITA INTEROFFICE MEMORANDUM TO: Mayor Boyer and City Councilmembers Chairman Brathwaite and Members of the Planning Commission FROM: George Caravalho, City ManagfCH DATE: November 5, 1996 SUBJECT: REVIEW OF THE NEWHALLECIFIC PLAN AND DRAFT ENVIRONMENTAL IMPACT REPORT The Newhall Ranch project, located generally south of State Route 126 and west of Interstate 5, proposes a Specific Plan to develop 25,218 residential units over a 19 square mile area (11,963 acres). The project, as proposed, also includes: • Nine square miles of open area (5,852 acres)' • 19,323 permanent jobs • Five elementary schools, one junior high, and one high school • Three fire stations • One public library • Construction of a 7.7 million gallon per day Water Reclamation Plant • 30 miles of new roadways • 12 local parks (60 acres total) and 3 community parks (274 acres total) • 50 miles of trails (including 5 miles of Santa Clara Regional River Trail) • One 18 hole golf course and a 15 acre community lake • Reservation of Metrolink right-of-way and future station site • Surplus tax revenue to the City of $27.9 million over the development period, and $1.8 million annually thereafter. The Draft Environmental Impact Report (DEIR) for the Newhall Ranch project was received by the City's Planning Division on August 8, 1996. The DEIR had originally been released with a 90 day public review period. However, due to the size and scope of the project, the City and other local groups involved with the review of the DEIR urged the Los Angeles County Regional Planning Commission to extend the public review period to a total of 180 days. On September 18, 1996, the Regional Planning Commission extended the public review period to a total of 120 days, resulting in a closing date for comments on the DEIR of December 5, 1996. Staff has completed their review of the Newhall Ranch DEIR and Specific Plan, and has forwarded a letter outlining comments/concerns regarding the project to the Los Angeles County Regional Planning Commission. Attached for your reference is the City's letter forwarded to the Regional Planning Commission. The statements in the letter reflect staffs issues with the DEIR and Specific Plan, and do not represent a policy determination regarding the project. MKIMMOR•� Staff recommends that the City Council: 1) review the attached letter; 2) discuss the project; and 3) provide staff direction regarding a policy determination on the Newhall Ranch project. GAC:JL:JDR:lep council\mstdysn.mem City of Santa Clarita 23920 Valencia Blvd. Phone Suite 300 (805) 259-2489 Santa Clarita Fax Califomia 91355-2196 (805) 259.8125 October 28, 1996 Mr. James Hard Director of Regional Planning County of Los Angeles 320 West Temple Street Los Angeles, CA 90012 RE: CITY RESPONSE TO THE DRAFT ENVIRONMENTAL IMPACT REPORT (`DEMI) AND SPECIFIC PLAN FOR THE NEWHALL RANCH PROJECT Attention: Kerwin Chih, Impact Analysis Section Dear Mr. Hard: Thank you for the opportunity to participate in the County of Los Angeles's environmental review of this project. The City of Santa Clarita has reviewed the DEIR and Specific Plan for Project No. 94087 (Newhall Ranch), and offers the following responses and suggested mitigation regarding areas and issues germane to the City's interests. The comments which follow are technical comments only, and do not reflect any policy determinations or direction by the City Council of the City of Santa Clarita. The following comments are intended solely to comply with the City's responsibility to respond to the DEIR as required by CEQA. SPECIFIC PLAN REVIEW The City of Santa Clarita has reviewed the Specific Plan for the Newhall Ranch project on two different levels: one level incorporated a review in very broad context terms, and one level involved the review of the Plan in specific detail. In a broad context, the City has reviewed the Specific Plan with consideration to future annexation proceedings. While the developer has stated that the incorporation of Newhall Ranch into the City is unlikely, one can never predict what the future may hold. One of the City's most immediate goals is to annex property located on the west. side of Interstate -5. Fifty years from now, we may have incorporated the Valencia Commerce Center, the Marketplace, and/or the Magic Mountain Theme Park. We also feel that the possibility exists that future residents of Newhall Ranch may wish to be a part of our City. As such, we have looked at the project as if future annexation of the community of Newhall Ranch is a possibility. PRINTED ON RECYCLED PAPER Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 2 . The City of Santa Clarita suggests that the Newhall Ranch Specific Plan be built according to the development standards currently established by the City. Examples of such standards include integration of our standard street widths throughout the project, grading activities consistent with our Hillside Ordinance and Subdivision Ordinance, protection of the native oak trees according to our Oak Tree Ordinance, and residential, commercial, and industrial developments which would meet our Unified Development Code standards. While these examples are not all-inclusive, and while designating specific standards at this time may seem premature in light of the generalized nature of the current project under review, the City would encourage the use of such standards for all projects at future subdivision stages. The City is proud of the development that has occurred since our incorporation, and a simple drive through the Santa Clarita Valley demonstrates the progress and improvements that we, as a city, have made since December of 1987. If the project is developed, the City suggests that the County of Los Angeles and the project proponent continue to include the City of Santa Clarita in the planning process. The Joint City -County Planning Program Background Report (prepared jointly by the County of Los Angeles Regional Planning Department and the City of Santa Clarita Community Development Department) ' was accepted as a policy document in December of 1992. The Planning Program states that, "While the City of Santa Clarita was formed so that planning from a local perspective could take place, the City shares the SCV with land governed by Los Angeles County. As the City has grown, so has its awareness of the need to work together with the County. Ultimately, the quality of life in the Santa Clarita Valley will depend heavily on how this happens." The Planning Program specifies goals which lead to this higher quality of life, including: The promotion of compatible and sound planning and the enhancement of the quality of life in both the incorporated and unincorporated areas of the Santa Clarity Valley; The promotion of compatible land use policy and development standards in the Santa Clarity Valley-, The enhancement of infrastructure planning, design, and installation in incorporated and unincorporated areas; The coordination of development fees for infrastructure and other public facilities; The utilization of locally -generated fees locally, both in the City and in the unincorporated areas; The maximization of opportunities for review and input on discretionary projects; and, The opportunity to provide fair and equitable means for public representation and participation. Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 3 The implementation of these goals, with respect to the Newhall Ranch Specific Plan, is imperative if the Santa Clarita Valley is to be developed in a consistent, comprehensive and compatible manner. On a specific level, the City suggests that the following changes be incorporated into the Specific Plan. Section 2: Development Plan • The designation of Special Management Area ("SMA"). should be an overlay covering the Significant Ecological Area ("SEA") portions of the property. However, the SEA designations should not be removed from the Santa Clara River or the Santa Susana Mountains. The designation of Significant Ecological Area more closely resembles the sensitivity of these environments, as compared to a "Special Management Area" designation. While an SMA designation could still govern management of these areas, the SEA designation should be kept consistent throughout the Santa Clarita Valley, and should remain. A land use overlay for public service facilities is considered appropriate, in lieu of establishing specific building locations for these facilities at this time. Consideration should be given to possibly relocating the proposed library to the mixed use village at the intersection of State Route -126 and proposed Long Canyon Road. This would provide for greater accessibility to the general. public and the citizens of the community of Val Verde. No development of residential housing units should be permitted within the High Country Special Management Area ("SMA"). This area is still considered to be a significant ecological area, and the proposed 15 estate lots should be eliminated from the Specific Plan. This would provide for a better topographical buffer between the High Country and the project's residential units. • Proposed roadway(s) and / or designated right-of-way areas near the Salt Creek Corridor should be eliminated. This is a major wildlife corridor which should not be disturbed by any future construction.or any occupation within the corridor's immediate vicinity. While the Specific Plan states that the Regional River Trail will serve as a transition area (between the proposed developments and the River Corridor), the applicant should also incorporate language into the Specific Plan ensuring a second transition area between the edge of the River Corridor and the Regional River Trail. While this transition would be more limited in nature, it would aid in the preservation of an area containing sensitive habitat. It is imperative that residential and commercial development within the project area provide good pedestrian access to future transit stops that will be established as a result of the proposed project. Particularly with land uses which are prime transit trip generators, such as the four mixed-use villages, Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 3 and the business park areas, pedestrian-, bicycle-, and transit -friendly design should be incorporated. For example, within the mixed-use villages, design should deviate from the typical parking -in -front, building -in -back model, which does not promote pedestrian activity. In the business park areas, sidewalks should be provided throughout, so that commuters can travel easily between bus stops and their offices. Furthermore, if the business park is comprised of oversized "superblocks", pedestrian paths that cut through the blocks should be provided. Further comments regarding these and other design issues will be provided at the subdivision map stage of the project. Section 3: Development Regulations • As stated above, the City of Santa Clarita recommends that the community of Newhall Ranch be developed in compliance with the City's development standards. This would be the most desirable situation for the City, as a possible future annexation would result in less complication if the community were built to City standards. However, if this is not accomplished, the Specific Plan should be the governing document, and should be compared to existing Los Angeles County zoning and development regulations. The Specific Plan states that in areas of discrepancy, the Specific Plan would be the governing document. Language should be incorporated into the Specific Plan that states that the community is subject to regulations of the Specific Plan and the Los Angeles County Subdivision Ordinance, and that in areas of discrepancy, the most restrictive document shall prevail. • Below is a list of recommended changes to the permitted use matrix in the Specific Plan. The recommendations provided by the City result from the experiences of the City's Planning Division staff, and would be beneficial to the community of Newhall Ranch, and the Santa Clarita Valley in general, upon implementation. -All mechanical repair, boat, car or otherwise, should be required to be performed within a structure. -Maintenance yards and storage yards should be required to be screened from public view with a block masonry wall. -Rifle ranges should be subject to residential compatibility, unless the range is specified as an indoor shooting range- -Concrete batch plants should be subject to the approval of a conditional use permit. -Bars and microbreweries should be subject lo compatibility of surrounding uses, including residences, schools, churches, hospitals, public playgrounds, and youth facilities. -The developer should add provisions regarding recycling facilities to the 'permitted use matrix. Such provisions should include standards for Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 5 portable recycling containers in commercial and industrial zones, manned recycling bins in commercial and industrial zones, recycling yards, composting yards, and wormiculture operations. -Explosives should be governed by the number of pounds of materials being stored (e.g. gunpowder stored in excess of 750 lbs., other explosives stored in excess of 100 lbs.). Section 5: Specific Plan Implementation • Adjustment / Transfer/ Conversion provisions are sensible and acceptable for a project of this size and scope. However, public participation procedures should be incorporated into certain "conversions" related to the Specific Plan. In particular, public participation should be included within procedures for the conversion(s) of land use(s) throughout the project site.. As proposed, the Specific Plan is basically administering the right to process zone changes without public participation. At a minimum, property owners who abut land(s) being converted from residential to commercial, should be notified in writing of the intent to change boundary lines separating land uses. Furthermore, the property owners should be given a certain number of days to respond with comments/concerns regarding such conversions. If property owners voice concern about proposed land use conversions within the specified time frame, then the decision to convert acreage should be subject to Regional Planning Commission approval. A provision could be added that, in the case of land use conversions, the Planning Commission is the final acting authority, and that appeal of the Commission's determination to the Board of Supervisors is not possible. Obviously future residents buy property/houses in particular locations based upon many factors, one of which is often adjacent property designations and permitted .uses on neighboring lands. The- City is in agreement that the "non-specific" Specific Plan should allow for flexibility, but not at the expense of future residents. Director -approved changes to all administrative actions should be subject to the same public notification process as stated above. The Director should be responsible for implementing a system in which all property owners originally notified of a public hearing for an administrative action are informed that specific changes (to an action that has been approved by the Commission) are occurring regarding the previous action. Director -approved changes should be subject to a 15 day appeal,period,with appellants being subject to an appeal fee. Stated conflicts could then be addressed by the Regional Planning Commission, with the Commission, once again, being the final acting authority. As a point.of clarification, the Specific Plan should incorporate examples of what constitutes a "minor" change in roadways which are subject to Director review. Do minor changes address roadway widths, alignment, or designation changes from secondary to collector? Stating examples in the Specific Plan could provide clarification for developers who wish to make what they consider minor changes, but which the Director may consider to be major changes. Newhall Ranch DEIR and Speciftc Plan October 28, 1996 Page 6 The aforementioned items should be considered prior to the Regional Planning Commission forwarding a recommendation to the Los Angeles County Board of Supervisors. If such recommendations are implemented, then the EIR should address the changes made to the Specific Plan. The following information contains a review of the Draft Environmental Impact Report ("DEIR") for the Newhall Ranch project. Such information consists of areas to be studied further and/or addressed in the DEIR, and suggested mitigation measures which will lessen the impact of the project on the City of Santa Clarita. Section 4.1- Geotechnical and Soil Resources The DEIR should address the use of alternative design concepts that might better mitigate the common problems created by typical grading practices. The major concerns regarding such are aesthetics and. long term slope maintenance. Aesthetic concerns should be addressed by incorporating landform grading techniques in all hillside areas. Along with this proposed grading technique, areas that are to be revegetated should be planted with native slope materials to minimize the contrast between developed and natural areas. Landform grading will result in a much more natural looking area than standard grading practices, which create stark, contrasting angular hillside formations that appear as abrupt changes to the adjacent natural areas. After standard grading practices are completed, the angular slopes are often planted with non-native materials that create glaring coloration changes from the adjacent natural areas. These non-native materials often have difficulty surviving, their maintenance can create a financial burden on residents, and large quantities of water and other resources are needed to help them survive. In nature, native plants help prevent the erosion of slopes. Wind, rain, and gravity constantly work to erode natural hillside slope areas. This is a never- ending process that had been continuing for millions of years: the steeper the slope, the more susceptible it is to erosion and instability. Therefore, a look at past standard grading practices tells us that changes in these practices should be made if the long-term maintenance of the slopes is considered. Although the Soils Engineer or Geologist may state that the slopes will be stable at certain maximum gradients, in the long run, constant maintenance of the slopes may prove too costly, and deferred of discontinued maintenance may result in conditions that will allow failures to occur. The DEIR should address whether the Newhall Ranch Specific Plan will incorporate such landform grading techniques, and if not, should state the manner in which the aforementioned problems with standard grading practices will be handled by future developers. Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 7 Section 4.2 - Flood In -the Summary portion of the DEIR (Section 4.2 - Flood) Section b.(3), Potential Impacts, is misleading because the DEIR compares the new proposed impervious areas to the entire watershed, but not to the proposed project developed area alone. In this case, the impervious area would be 58% of the developed area. This section is also misleading because the statement, "...construction of Newhall Ranch would not increase site runoff during a Capital storm.." is based on theoretical calculations, not what occurs in reality. Actually, since the design requirements make the engineer calculate runoff for undeveloped areas by including huge unrealistic burn and bulk factors, and these same factors are not included in calculations for developed areas, the numbers may be lower. However, as stated later in Section 3.a.(2), Method of Drainage Analysis, "Buildings, driveways, patios, and roads all create new impervious covers to the natural ground which prevents the ground from absorbing rain water. This overcovering of the natural ground not only results in small storms creating a higher amount, or volume, of runoff, but also a higher flow rate of runoff (identified as the "Q") in developed areas than in undeveloped areas." The increased volume and flow rates created by the increase in impervious areas.result in shorter concentration times for runoff flows. As a result; runoff leaves the site faster and has less opportunity to get into the ground: As a cumulative effect, the peak flow rates in the river increase and the flow durations decrease. The river remains dry more of the year and the water flows for less of the year. Because the revised municipal stormwater NPDES permit is now available (NPDES Permit No. CAS614001), it should be addressed and incorporated into the evaluation of potential water quality impacts for this project. The revised permit has established prohibitions and limitations, and requirements for the following. connection and discharge; development planning and construction; public .agency program requirements; public information and participation; monitoring; and program reporting and evaluation. The revised NPDES permit was adopted on July 15, 1996, a date which coincides with the release of the Newhall Ranch DEIR for public review. We acknowledge that the requirements of the revised Permit were not available to be addressed during the preparation of the DEER, but feelthat the revised Permit should be addressed prior to certification of the final EIR. The evaluation of the project's compliance with the NPDES permit should include: how the project does or does not comply with the Permit; to what extent the proposal meets the requirements for surface runoff water quality and control of non -point source pollutants in an urban area; compliance of erosion and sedimentation control measures with the Permit (for grading and other construction activities); and an ,expansion upon the water quality requirements to address Permit requirements, including prohibitions and limitations, County Stormwater Management Program requirements, and standard provisions. The DEIR analysis of NPDES Permit compliance must distinguish between the municipal stormwater NPDES Permit and other types of discharge permits (such as construction and industrial permits) required under the NPDES program. Newhall Ranch DEIR and Specific Plan October 28, 1996 - Page 8 The DEIR discusses proposed bank stabilization for the Santa Clara River on 30% of the southern side and 80% of the northern side of the River Corridor to protect adjacent development from erosion. The DEIR states that the bank stabilization is proposed to consist of ungrauted rock. The DEIR should discuss whether or not other alternatives to this type of bank stabilization have been discussed with the State Department of Fish and Game. If so, then the DEIR should discuss the alternatives, and should address the reasoning behind selecting ungrouted rock for bank stabilization efforts. If no alternatives have been discussed, then the project developer should initiate such discussions with the State Department of Fish and Game, and the EIR should incorporate alternatives prior to final certification. • Criteria for the "Santa Clara River Corridor Concept" should specify that good surface runoff water quality be maintained through prevention or minimization of non -point source pollutants. This should be applied to all proposed ongoing land uses (including residential, commercial and business park uses) as required by the County s current municipal stormwater permit (NPDES No. CAS614001). The proposed land uses will establish a new source of potential surface runoff pollutants which may adversely impact the biological resources of the Santa Clara River. Because the Santa Clara River has been identified as a Significant Ecological Area (SEA), the County's existing SEA requirements should also be incorporated as part of this criteria. • Figure 4.2-5 (map) shows sixteen water quality basins located throughout the specific plan area. The DEIR should describe their function(s) and how they will maintain good surface water quality, and if they will be used to provide data for program monitoring. ' • Reference is made to the implementation of Best Management Practices (BMP's) for the specific plan. This information should be updated and expanded in the DEIR. Pollution prevention / reduction activities should be incorporated in the specific plan as an ongoing community program. These programs and physical BMP's can be refined to a greater level of detail and incorporated into the design of each future subdivision map. • Mitigation Measure; The project developer should ensure the preparation and approval of a Stormwater Pollution Prevention Plan for the project. Section 4.6 - Biota The Biota Section of the DEIR is very thorough in its technical analysis of the project site. However, it tends to lose sight of the fact that CEQA requires an EER to present information in a format that is understandable to the lay person. While the vast majority of information presented in the Biota Section cannot be presented in non-technical terms, the DEIR should attempt to address the issue of eliminating area from the River Corridor SEA in a manner that would be understandable to the average reader. As it stands right now, one could assume that the elimination of area from SEA 23 is being pursued Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 9 in order to accommodate the developer's vision for the project. This may or may not be the case. Documents that the City and County currently possess depict the SEA areas inconsistently. If it is the case that the area being removed from SEA 23 is being eliminated because it does not contain the sensitive habitat that the true SEA contains, then that should. be clearly stated in the DEIR. Section 4.7 - Visual Qualities • As stated above, the City of Santa Clarita requests that the Specific Plan be built in compliance with development standards adopted by the City.. As such, we are requesting that the Newhall Ranch Specific Plan take the City's Ridgeline Preservation and Hillside Development Ordinance into consideration during development stages. The Visual Qualities section of the DEIR provides numerous viewshed analyses of the project at buildout, which show a disregard for the importance of protecting significant ridgelines in development. • The City's Ridgeline Preservation and Hillside Development Ordinance was developed in order to: Provide hillside development standards to maximize the positive impacts of site design, grading, landscape architecture and architecture, and provide development consistent with the goals and policies of the City of Santa Clarita's General Plan; Provide ridgeline preservation and development standards to protect certain ridges and minimize the adverse impacts of development; Maintain the essential natural characteristics of the area such as major landforms, vegetation and wildlife communities, hydrologic features, scenic qualities and open space that contribute to a sense of place; and, Retain the integrity of predominant off-site and on-site views in hillside areas in order to maintain the identity, image and environmental quality of the area. • Mi ieation M .asi3m. The Newhall Ranch Specific Plan should be built in accordance with the development standards listed in the City of Santa Clarita's Ridgeline Preservation and Hillside Development Ordinance, especially with respbct to grading design, landscape design, and perimeter ridgeline shielding design. Section 4.8 • Traffic • The traffic report in the DEIR indicates that the Specific Plan will generate an approximate average daily trip (ADT) of 387,000 trips. An internal / external summary of average daily trip -ends for the Specific Plan is as follows: Newhall Ranch DEIR and Specifc Plan October 28,1996 Page 10 Specific Plan Trip Components SPECIFIC PLAN ul• ► ► IY: 1• D ►11 Internal to Specific Plan 201,240 (52%) Within Santa Clarita Valley 147,060 (38%) Outside Santa Clarita Valley, 38.700 (10%) TOTAL 387,000 (100%) The report includes the following information which we feel needs to be expanded or modified to ensure that the project would not adversely impact the City of Santa Clarita: 1. The above "Specific Plan Trip Components" table needs to be expanded to show the percent of the Specific Plan trip -ends into the existing boundary of the City of Santa Clarita and also should depict fluctuations over the years. 2. The project analysis includes the future ADTs of links within the site and the surrounding areas at buildout of the City and the Newhall Ranch project. This methodology has been used in numerous studies and is well - accepted. Due to the proximity of the proposed site and the City, and due to the fact that the travel patterns in the Valley will change by the time this project is completed and self -served, it is recommended that the report include other types of analysis in the study, such as link directional traffic in peak hours and even in every (x) number of years. It is suggested that the report be prepared to analyze the different phases of the project. It should be noted that the analysis of project phasing can also be done in later dates when more. specific portions of the project development are proposed, but that this later analysis may cause the City to state that the individual projects create significant impacts on other roads and links. 3. The Specific Plan is proposing the deletion of the extension of Pico Canyon Road to SR -126. Reviewing the discussion of this deletion in Appendix 4.8, it shows no traffic volume change on Lyons Avenue, McBean Parkway, Valencia Boulevard, Magic Mountain Parkway, or Newhall Ranch Road east of the I-5 within the City area. This needs to be revisited for accuracy and should also include a.m. / p.m. peaks. The City always recommends that sites / projects contain various access points, and discourages the deletion of such. 4. The Conceptual Alternative Highway Plan, as indicated in the study, could vary since the City is in the process of amending the General Plan / Circulation Element. There are significant deletions / changes in the proposed alternatives which we do not anticipate will take place. Some of the alternatives might be controversial, such as the deletion of the Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 11 extension of Avenue Tibbits to Tourney Road at Magic Mountain Parkway. This road is a major link to the industrial area, and its deletion has a significant impact on McBean Parkway: it causes McBean Parkway to carry over 70,000 cars per day. Another correction regards the connection of Magic Mountain Parkway to Via Princessa, which is a correction already in the design stages, and is part of the City's Capital Improvement Projects. 5. In the discussion of land use on Page 4.8-19, it should be noted that other recent City and County GPA's need to be included, such as Tesoro Del Valle, a new "conceptually approved" subdivision within the County. 6. All proposed roadways on-site, along with the connection links, should have adequate width to accommodate on -street bike lanes. 7. The DEIR should include the corrections and/or suggestions on the attached marked -up copies of Section 4.8 Traffic. • The City is not prepared at this time to request specific mitigation regarding the project's traffic impacts to our jurisdiction. Once the aforementioned issues have been addressed, the City could request the implementation of certain mitigation measures to lessen the impacts of the Newhall Ranch . project on City circulation. However, the possibility also exists that the additional information provided in the revised traffic report could satisfy the City that the project's impacts to the City may be less than significant. Transit Impacts • Although the proposed project area is not currently included in Santa Clarita Transit's service area, it is likely that any future transit service provided to and through the project site would be provided by Santa Clarita Transit under contract with Los Angeles County. There is likely to be a certain amount of interdependence, and therefore travel, between Santa Clarita and Newhall Ranch, particularly prior to full build -out. As stated in the DEIR, even at full' build -out, only 35% of the 387,000 average daily trips (ADT's) generated in the Specific Plan area will also terminate in the Specific Plan area (page 4.8-31). Although specific project phasing was not presented in the DEIR, it is common for residential development to occur prior to the construction of supporting community land uses. In the interim, Newhall Ranchresidentswill be dependent on schools, retailers, banks, churches, and other facilities located outside the new community. ,Accordingly, Newhall Ranch residents will need adequate means of transporting themselves between the two communities. Thus, roadways which connect the two communities, such as Magic Mountain Parkway, Pico Canyon Road, Valencia Boulevard, and SR -126 / Newhall Ranch Road will need to be adequately expanded to carry the passenger cars, service vehicles, and public transit buses generated by the proposed project. • It is understood that the initial transit demand, and therefore the transit resources required to provide service, prior to full build -out will differ from the transit demand at full project build -out. For example, during the first few Newhall Ranch DEIR and Speci/Ic Plan October 28, 1996 Page 12 years of construction, the number of transit trips generated by Newhall Ranch residents may be relatively low, but a large percentage of trips will be to and from destinations within the City of Santa Clarita. In later years, as community -supporting services such as shopping centers, schools, and parks are constructed in Newhall Ranch, there may be less of a need for services which formerly connected Newhall Ranch residents to such facilities in the City of Santa Clarita, and more need for trips between destinations within the Newhall Ranch project. However, at full -buildout of the project, the City of Santa Clarita will still provide for regional consumer needs, thus transit service between the City and Newhall Ranch will remain necessary. In order to more accurately anticipate the geographic distribution of transit trips, the DEIR should address project phasing. This will enable agencies, such as MTA and Los Angeles County, and in turn the local providers (Santa Clarita Transit and Metrolink) to plan for potential public transit service expansion to the project area. In the absence of phasing information, the full -buildout scenario was evaluated in order to estimate the future transit needs of the proposed project. The Traffic / Access section of the DEIR states that "...actual transit impacts to transit services will be evaluated at the subdivision map level as development occurs within.'the Specific Plan site. At this detailed level... transit operators can assess the capacity and demand of transit services" (page 4.8-81). While some of the decisions regarding exact routing, frequency of service (headway), and bus stop locations can be made closer to project construction, there are other longer-term decisions which greatly affect the ability to provide transit" service to and through the Specific Plan area (such as the layout of the road network) which must be made prior to the subdivision map stage. For this reason, it is necessary at this level of project review to provide an estimate of future transit needs. As proposed, Newhall Ranch is planned to contain 24,680 dwelling units and 5,720,000 square feet of retail, office and industrial development. Commercial centers, which cover 90.7 gross acres of the project area, are to be located near major highways (page 4.8-25). It is anticipated that residential areas will be accessed off the major roadways by many smaller residential -scale streets. It is likely that any public transit service in the Newhall Ranch project would be provided along the main thoroughfares, such as Potrero Canyon Road, Magic Mountain Parkway, Commerce Center Drive, and Long Canyon Road. However, it is important that good'pedestrian access between the residences and these major roadways be provided ` in order for residents to have satisfactory. access to transit stops located on the major roadways. The proposed project is estimated to generate 387,000 ADT's. Multiplying this number by an occupancy factor of 1.4 converts the figure to 541,000 ADT person trips, of.which 3.5% (or 18,963 ADT person trips) will become trips assigned to transit, per Metropolitan Transit Authority guidelines. Using a representative peak hour factor of 10 percent, the DEIR estimated that this would yield approximately 1900 peak hour transit trips for each peak hour to be potentially generated by the Newhall Ranch Specific Plan (page 4.8-81). Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 13 Although these figures from the DEIR do not identify transit trip origins and destinations,. or describe how the transit demand will be distributed throughout the day, they do help us to make estimates regarding resource requirements. Just to accommodate the 1900 transit trips per peak -time hour generated by the Newhall Ranch project, Santa Clarita Transit's fleet would need to be expanded by approximately 48 buses (1900.peak-hour transit trips divided by 40, which is the average number of passengers per transit vehicle, equals 48 buses required). The hourly cost to provide such service, which does not include equipment cost, would be approximately $42 per hour in 1996 dollars. The costs identified above also do not take into account the cost of roadway improvements needed to ensure that Santa Clarita Transit's currently -operating routes are not impacted by the Newhall Ranch project. For example, without roadway capacity expansion, the routes currently operated along Valencia Boulevard,. Magic Mountain Parkway, The Old Road, Newhall Ranch Road, and SR -126, would be negatively impacted by the additional automobile traffic added to the roadways as a result of the Newhall Ranch project. Such routes would be slowed down, and public transit riders throughout the rest of Santa Clarita Transit's service area would experience a decrease in the level of service. While the issue of roadway capacity has been discussed above, it is raised again here to note that the level of service concept applies not only to roadway networks, but also to the transit route network. Section 4.10 - Air Quality • The DEIR states that the project is air quality friendly, even though the impacts to air quality will be unavoidably significant. While the DEIR addresses the project design standards leading to "less of a significant air quality impact" throughout many sections of the document, the DEIR should provide specific examples of such within the Air Quality Section of the report. For example, the DEIR could expand upon page 4.10-21, when discussing the concentration of development within core area, about how trails systems will link the commercial and residential areas. This area could also include the number of jobs that will be created by the project, and what types of jobs will be created. As was stated above, these may be addressed in other sections of the DEIR, but should be provided in the Air Quality Section in order to create a more comprehensive document that the average reader can understand. • Page 4.10-25 discusses the Specific Plan's Mobility System which will aid in the reduction of emissions, and references emission reduction efficiencies in the SCAQMD's CEQA Air Quality Handbook. The DEIR should explain how the project's mobility system accomplishes a reduction in noxious air emissions, instead of just claiming that the mobility system does such. The lay person may not be familiar with land use / design / rail impacts, or the use of park-and-ride lots. The DEIR should explain these aspects of the project and expand upon their beneficial impacts. Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 14 • Page 4:10-31 states that the proposed Specific Plan is consistent with the AQMP and that is does not jeopardize attainment of the air quality standards predicted in the AQMP "...because the Specific Plan is consistent with the goals, objectives, and assumptions outlined in the AQMP." The DEIR should provide the goals, objectives and assumptions of the AQMP, and should address exactly how the project is consistent with these goals, objectives, and assumptions. • Mitigation M .a ire: The -project proponent should ensure that future subdividers (or the project proponent) provide electric vehicle charging stations at future park-and-ride lot(s), at commercial centers, and at industrial buildings. Future residences should also be equipped to handle, where appropriate, electric vehicle charging outlets within interior garages. • Mitigation Measure: The project proponent should pay, or ensure the payment of, the project's pro -rata share for transit service to and from the project site. Section 4.12 - Wastewater Disposal • After reviewing the Wastewater Disposal section, it appears that the construction of the proposed wastewater treatment plan, identified in the DEIR as the water reclamation plant (WRP), is a necessary infrastructure component to provide adequate service for the specific plan buildout. The analysis of the capacity demands appears to be reasonable, and it would make sense for the project proponent to bear the costs of providing, this needed infrastructure to exclusively serve the project. The DEER also indicated that new County initiated connection fees would he utilized to finance the proposed WRP. Details should be provided concerning the way the project will be financed and how any related reimbursement mechanisms will work. Will the County be paying for initial construction and start-up costs, or will that be financed up front by the Newhall Land and Farming Company? Will these fees be collected only from the new residents of Newhall Ranch for reimbursement to the initial financing entity? Will any other Santa Clarita Valley resident outside of the Newhall Ranch project be impacted by the financing of the WRP? • It is encouraging to see that the development of a reclaimed water system is included as a part of the WRP function; the City would support this for on-site irrigation where the level of water quality is acceptable and meets established State standards. $owever, we are sensitive to the issue of reclaimed water development on a valley -wide basis. The DEIR should address this issue, and the issue that the Castaic Lake Water Agency and the Newhall County Water District are currently researching and preparing their own reclaimed water plans. These issues should be addressed in the DEER relative to these agencies (and any other agencies considering the development of a reclaimed water system for the Santa Clarita Valley) in terms of the comprehensive development, distribution, and use of reclaimed water for the Santa Clarita Valley. Newhall Ranch DEIR and Specifc Plan October 28, 1996 Page 15 As a publicly owned or privately owned service provider, the WRP has the potential to provide service downstream to properties in the County of Ventura. This issue should be addressed in the DEER. This is a relevant question to us because the DEIR has identified a "tributary area" of the proposed WRP, and anticipates requests for annexation to the proposed new Sanitation District for service (DMS Buildout Scenario, page 4.12-9). Additionally, the DMS Buildout Scenario. should address valley -wide impacts due to the comprehensive nature of the County's DMS methodology. Two scenarios are analyzed in the DEER: One for buildout under the County Sanitation Districts of Los Angeles County under their proposed SCVJSS facilities expansion; and, one for cumulative buildout under the land use designations for both the County's Santa Clarita Valley Area Plan and the City of Santa Clarita General Plan. The SCVJSS facilities' proposed expansion is based upon SCAG population projections for the year 2015. This scenario addresses future needs exclusive of the Newhall Ranch Specific Plan. Because the Newhall Ranch Specific Plan has defined parameters for development intensity, we feel that this scenario can be adjusted to include the additional service demand created by this project. Cumulative buildout scenarios that address both County and City General Plans seem to be the most conservative approach in identifying the most intense service demand. The City prefers this scenario to assess cumulative impacts because it tends to consider planning and development activities in both the City and the County, thereby being a comprehensive method assessing the Santa Clarita Valley as a whole (instead of segmenting community growth). Section 4.15 - Solid Waste The project, as proposed, would produce a maximum of 53,524 tons of solid waste annually upon buildout. Currently, the City spent five years educating the public on alternatives to land filling, and initiated a progressive curbside recycling program. These efforts, though, have resulted in the diversion of only 30 tons of solid waste per year., The project, with its mitigation factors listed in the DEIR, could cause diversion efforts on a Santa Clarita Valley -wide basis to go backwards. It is recommended that the DEIR discuss and take a leadership role in determin;ng how the project's solid waste will be handled. The DEIR should address innovative solid waste planning, as opposed to reiterating the fact that the project will comply with Los Angeles County standards for waste management. The City greatly encourages developers to incorporate innovative concepts for solid waste diversion efforts in their proposals, as opposed to relying on existing landfill capacities and/or future landfill expansions to handle a project's solid waste. Furthermore, community outcry on the issue of landfilling is strong. Thus, the DEIR should address a worst-case scenario in which no expansions and/or new construction of facilities are approved. The DEIR should specifically discuss how the project would dispose of or reduce the solid waste generated by the Newhall Ranch Specific Plan if no expansions and/or construction of landfill facilities occurs over the next 25 years. Newhall Ranch DEIR and Specif c Plan October 28, 1996 Page 16 • Mitigation Measure: All future'subdividers should incorporate residential design standards which accommodate solid waste and recycling efforts. Such designs should be incorporated into interior living space as well as residential street design. • Mitigation Men s,r .: The project proponent should incorporate standards for composting and material recovery facilities within specified zoning designations throughout the project site. Section.4.20 - Parks, Recreation, and Trails • The parkland dedication requirement as identified in the DEIR totals 202-235 acres of parkland. This number -was derived by using 3.17 persons per single family dwelling unit. The City of Santa Clarity Unified Development Code (UDC) uses 3.588 persons per single family dwelling unit, which would change the parkland range to approximately 230-250 acres of required parkland. The Newhall Ranch project proposes to fulfill parkland, requirements by providing 12 neighborhood parks, three community parks, trails, open space, and high country and river corridor special management areas. The total Quimby credit requested by the developer applying the Los Angeles County Quimby approach for this project is 2,472 acres, far above the actual amount of required parkland. Preservation of open space, significant ecological areas, and the Santa Clara River corridor is consistent with the City of Santa Clarita's General Plan and would generally be supported. However, applying the City's UDC requirements for parkland dedication, the developer would receive 30 percent credit towards Quimby requirements for the private facilities provided. At a total requirement of 230 acres, §0,percent credit would be about 70 acres for a remaining balance of 160 acres. Neighborhood and community parks with active uses total about 113 acres, leaving approximately 47 acres yet to be credited -towards Quimby requirements. Approximately 125 acres of community. parks and a lake, which the DEIR suggests should receive credit, are considered passive and are located in restricted areas such as utility easements. There. does not appear do be any major sports center which would accommodate community tournaments or league play. With the addition of approximately 70,000 people, there: would be demand for organized youth and adult baseball, softball, football, soccer, and/or other league sports. There is minimal discussion in the DEIR related to the operations and maintenance of the public parks or the commitment of the County to provide these services. Currently, the County is downsizing its park and recreation program, and is turning many park facilities over to local governments to maintain and operate. These issues should be addressed in the DEIR. • A point of clarification would be appreciated on page 4.20-1. The DEIR states that the current deficit in planning area #35, which includes Newhall Ranch, is 246.6 acres of parkland. Page 4.20-26 states that the project provides 2,472 Newhall Rauh DEIR and Specillc Plan October 28, 1996 Page 17 acres. of creditable parkland for a surplus of 2,266 acres over identified requirements. Page 4.20-33 states under Cumulative Impact that "The existing parkland deficit of 246.6 acres would remain." Regarding the Newhall Ranch Master Trails Plan, the Plan includes the regional river trail, community trails, pathways, local trails, and unimproved trails. The Regional Santa Clara River Trail spans from. the San Gabriel Mountains to the east, west to the Pacific Ocean in Oxnard. The City of Santa Clarita has developed a portion of this trail which would also traverse through the Newhall Ranch project. The DEER addresses the Santa Clara River Trail as it related to bicycles and pedestrians, however, it does not address the equestrian element. Equestrian use is part of the multi -use system that is the Santa Clara River Regional Trail, and needs to be included in the planning of this project. The Newhall Ranch project proposes to include approximately 6,000 acres of open space area accessible to the public. These include.the High Country Special Management Area, Santa Clara River Corridor, open area, golf course, and a lake. The operations and maintenance of these areas can be addressed through homeowners associations, maintenance districts, and private and/or public agencies. Restrictions -on the use of open space within the Newhall Ranch project should be further described in the DEIR. As it stands right now, the City is not convinced that dedicating the High Country SMA and the River Corridor SMA to the Center for Natural Lands Management provides for the best public use of these areas. To provide the greatest public use of the areas, access should be encouraged to the greatest�extent possible. The City of Santa Clarita currently provides extensive parks and recreation programs which are open to all residents of the Santa Clarita Valley. The existing fee scale does not discriminate between City residents and residents of the unincorporated area. Additionally, the City is currently bound by agreements with the County of Los Angeles which preclude the City from charging "non-resident" fees for services provided by the City in City parks, and in County parks under long-term lease to the City. Many residents of the unincorporated areas of Stevenson Ranch, Castaic, Val Verde, North Valencia, Saugus and Agua Dulce participate in these programs. Due to ongoing budget and funding deficits experienced by the. County of Los Angeles, several community parks in the unincorporated areas have been closed because funds for their operation and maintenance are unavailable. Additionally, this does not address the fact that the County does not currently fund any recreation programs in the Santa Clarita Valley. The project proponent has indicated that private funding of parks and recreation services may be funded privately by future residents of the project. While the City encourages such innovations, this does not preclude the need for publicly funded facilities and programs. Based on current experience and project trends, the City must anticipate serving the future residents of the Newhall Ranch project as well. Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 18 The City, and the Santa Clarita Valley by extension, currently experiences a severe deficit of park facilities. Existing facilities and programs are strained to over -capacity; many recreation programs often have long waiting lists of people who wish to participate. The addition of approximately 70,000 people generated by this project will seriously affect the City's ability to provide recreation programs to all who request them, let alone enhance such services. • The DEIR should identify any proposed recreation and cultural arts programming and staffing to fulfill community needs at the public park sites within the project. As stated above, the City of Santa Clarita currently serves numerous residents of the adjacent unincorporated areas at no additional cost to the County, but at increased, and unfunded cost to City residents. Effectively, this means that City residents are subsidizing, through property tax payments, the recreational activities of non -City residents. • Mitigation Measure: The project proponent should include equestrian trails along the Santa Clara River Corridor outside the river bottom wherever possible, and should tie into the High Country Special Management Area to Pico Canyon Trail. • Mi i2ation M ac „p: Rest stops, scenic overlooks, staging areas, etc., are amenities that the project proponent should locate along the regional trail corridor. • Mitigation Measure.: The project proponent should provide for, or ensure Provisions for, a direct connection from the project's trails system to the City's trails system, to the satisfaction of the City of Saata Clarita. • Mitieation M .ac it .: The project proponent should fund, or ensure provisions for funding, for City programs to be provided or facilitated by the applicant in anticipation of the project's residents' future use of City Recreation services. Section 4.16 - Education Educating the youth in our community is of vital importance in ensuring a Prosperous future for the Santa Clarita Valley. The.DEIR for the Newhall Ranch Specific Plan has adequately mitigated school impacts within the Newhall School District, however, has not adequately addressed the project's school impacts within the William S. Hart High School District or the Castaic Union School District. ' Regarding developer fees imposed to provide for adequate school funding, Government Code Sections 65995 and 65996 apply specifically to development projects which are not legislative in nature. Since the approval of the Newhall Ranch Specific Plan requires legislative actions, the Courts have held that local governments do have the authority to deny a land use application (which require a legislative action) on the basis of the adequacy of available school facilities, or to phase the development of projects: A "Valley -Wide Joint Fee Resolution" was adopted by the Los Angeles County Board of Supervisors, the Newhall Ranch DEIR and Specific Plan October28, 1996 Page 19 City Council of the City of Santa Clarita, and the William S. Hart Union High, Sulphur Springs Union, Castaic Union, Newhall, and Saugus Union School Districts in 1991 establishing a fixed fee in excess of the State statutory fee in order to mitigate the effects of growth on school capacity throughout the Santa Clarita Valley. However, in late 1995 the Newhall School District, William S. Hart Union High School District, Castaic Union School District, and Saugus Union School District all withdrew from the Valley -Wide Joint Fee Resolution, thus rendering it ineffectual. The DEIR states that the Valley -Wide Joint Fee Resolution applies to legislative actions, and yet the Resolution has been dissolved, and the Courts have upheld decisions [Mira Development Corp. v. City of San Diego, 205, Cal. App. 3d 1201, 1217 (1988)] that the prohibition of a City to levee fees in excess of the State statutory school fee is not -binding where a general plan amendment or rezoning is requested. The City suggests that the developer willingly provide for full mitigation of school impact on the Newhall School District, the William S. Hart Union High School District, and the Castaic Union School District, possibly with a provision for reimbursement of funds at the time that State school funding is made available. • Regarding the specific impacts of the Newhall Ranch project on local schools, the DEIR analyzes two different methodologiesfor determining possible effects. One includes the School Districts' Methodology, and the other includes Los Angeles County DMS Methodology. The DEIR tends to favor the Los Angeles County DMS Methodology, which states a lesser impact to the local schools than the School Districts' Methodology. Due to the importance of educating our youth, and the years of direct experience that the school districts have over Los Angeles County, it is suggested that the DEIR base the project's impacts on the School Districts' Methodology. As of this moment, the impact of the project on the local school districts. is considered to be unavoidably significant by the William S. Hart Union School District and the Castaic Union School District. Full mitigation for the project's impacts on schools should be based on the School Districts' methodology. • The DEIR should, in some manner, address the phasing for development of school facilities. The DEIR does not discuss the timing for development of the five elementary schools, junior high, and high school, thus it is anticipated that the City will be negatively affected by the buildout of the project in the short- term, or until the facilities are developed and operational, however long that may be. Specific mitigation for school impacts should be addressed in relation to the phasing of the project, as well as the mechanism being proposed for the implementation of school.facility development. Section 4.17 Police Services • The City of Santa Clarita presently, and for the foreseeable future, contracts with the County of Los Angeles for Sheriff services. It is anticipated that the development of the Newhall Ranch Specific Plan, with a residential population of up to 70,000 people, will affect both response times and performance standards in the incorporated and unincorporated areas of the Santa Clarita Valley. At this time, the City is inclined to recommend that the Newhall Newhall Ranch DEIR and Specific Plan October 28, 1996 Page 20 Ranch Specific Plan include a fully staffed Sheriff station within the Specific Plan boundary. This would ensure an adequate response time for all emergencies within and around the Specific Plan site, without a decrease in service to the City and the existing developments within the unincorporated area. The addition of 70,000 residents along with commercial'/ industrial developments will have a major effect on the level of police services currently provided in the Santa Clarita Valley. In the population range of 100,000 to 200,000 persons, the City of Santa Clarita currently stands as the fifth safest city Nation-wide. The outstanding service that our officers provide is one of the major draws for both residents and businesses to the Santa Clarita Valley. The addition of a fully -staffed Sheriff station on the Newhall Ranch site will serve to provide excellent community service to the. future residents of Newhall Ranch, as well as to the City, and will help us maintain our distinctive reputation as a We, clean community. • In addition to the request for a fully-staffed Sheriff station, the City recommends that a traffic or similar analysis demonstrating emergency routes for public safety and emergency evacuation routes for the public should be addressed in the DEIR. • Because the Newhall Ranch Specific Plan is not currently proposing the development of a Sheriff station, the DEIR should analyze the potential for increased cost to City-provided Sheriff services, at currently contracted levels, for traffic control and crime prevention in the City and its immediate environs. Once again, due to the fact that the DEIR does not address phasing for. the project, and does not discuss the mechanism proposed that would trigger the employment of additional Sheriff personnel, the City is anticipating that the project will negatively affect the services currently provided within the Santa Clarita Valley. • Mitigation MPaa,T The Newhall Ranch Specific Plan should provide for a fully-staffed Sheriff Station-within the boundary of the Specific Plan site. Section 4.18 • Fire Services and Hazards • A correction needs to be made to the DEIR in the summary section of Section 4.15 - Fire Services and Hazards. The first paragraph states that, "One additional station (Fire Station 126) is in the design stage of development, and will be located at the intersection of Mc Bean Boulevard and Magic Mountain Parkway." It is the City's understanding that the Los Angeles County Fire Department has rejected this location as a possibility for the development of a fire station, and that the Fire Department is investigating and/or has located a different location for the future station. • Due to the lack of information regarding project phasing in the DEIR, the City is requesting that a minimum of one Fire Station be constructed and operational prior to the approval of any development projects related to the Specific Plan- The construction of such Fire Station should be fiinanced by the developer, with the funding of applicable staff being guaranteed by the County of Los Angeles. Newhall Ranch DEIR and Specific plan October 28, 1996 Page 21 The City and the County, in the unincorporated areas in the Santa Clarita Valley, currently collect a .developer fee of $0.1884 per square foot on new development for the fire district protection program. This fee is based on Fire Department budget, in which monies are accumulated for future acquisition, construction, improvement, and equipment needs of fire station facilities, but not for ongoing operations and maintenance.. We request that the DEIR address the manner in which allocations from the project's funding will be dispersed during the buildout of the project. Furthermore, the DEIR should address whether the project will affect the rate the City pays for Fire Services when capital equipment needs and personnel costs for the project area are calculated to serve the new urbanized area. Henry Mayo Newhall Memorial Hospital and ancillary facilities presently provide hospital services to the residents of the Santa Clarita Valley and environs. The DEIR should address potential impacts to this and other hospital and emergency care facilities existing in the Santa Clarita Valley, with respect to the anticipated buildout of the 1990 Santa Clarita Valley Areawide plan as amended, to include the Newhall Ranch Specific Plan. Various transportation routes and travel time to the hospital should also be identified in the DEIR. Newhall Rauh DEIR and Specific Plan October 28, 1996 Page 22 Thank you again for the opportunity to review the Draft Environmental Impact Report and Specific Plan for the Newhall Ranch Project, and for your consideration of our requests. As we understand, the official comment period has been extended to December 5, 1996, and we wish to thank you again for doing so; we hope that the additional time will prove useful.to all interested parties. The City will likely provide additional comments and mitigation measures in response to any additional or new information that is provided to us, and we submit this early request that any future comments by the City based on this additional information also be included in and.addressed by the DEIR. If you have any questions, or require clarification of anything requested in this letter, please contact either Jeffrey Lambert, Planning Manager, or Jennifer Reid, Assistant Planner II of the Community Development Department, at (805)255-4330. Sincerely, 4neltp Assistant City Manager KP:JL:JDR:lep cc: Lee Stark, Community Studies Kerwin Chili, Impact Analysis Frank Meneses, Impact Analysis Michael Antonovich, Board of Supervisors. Dave Vannatta, Planning Deputy George Caravalho, City Manager, City of Santa Clarita City of Santa Clarita Councilmembers City of Santa Clarity Planning Commissioners James Harter, Newhall Ranch Company Impact Sciences Van Stephens, Forma advance\epecplanjdr