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HomeMy WebLinkAbout1998-01-13 - AGENDA REPORTS - NEWHALL RANCH DEV PROJ (2)CITY OF SANTA CLARITA AGENDA REPORT UNFINISHED BUSINESS City Manager Approval: X&5�� Item to be presented b3/,/ 1VIayor Heidt DATE: January 13, 1998 SUBJECT: POTENTIAL APPEAL OF DEVELOPMENT PROJECT DEPARTMENT: Planning & Building Services RECOMMENDED ACTION THE NEWHALL RANCH Discuss a potential appeal of the Los Angeles County Regional Planning Commission's approval of a Conditional Use Permit and Tentative Parcel Map relating to the Newhall Ranch development project, and direct staff accordingly. On December 17, 1997, the Los Angeles County Regional Planning Commission held its final hearing on the Newhall Ranch development project. At that hearing, the Regional Planning Commission took the following actions: Approved a Conditional Use Permit to allow for development within a Significant Ecological Area. 2. Approved a Tentative Parcel Map to allow for the subdivision of three. existing lots into a total of 30 lots. Certified the portion of the Final EIR that relates to the Conditional Use Permit and Tentative Parcel Map applications. 4. Recommended to the Board of Supervisors approval of a General Plan Amendment and Zone Change to redesignate 11,963 acres of land (approximately 19 square miles). 5. Recommended to the Board of Supervisors certification of the Final EIR that relates to the General Plan Amendment and Zone Change. The actions to approve the Conditional Use Permit and Tentative Parcel Map and to certify the Final EIR relating to the Conditional Use Permit and Tentative Parcel Map are final unless appealed to the Board of Supervisors. The Ventura County Board of Supervisors filed an appeal of the Tentative Parcel Map due to concerns related to potential impacts to Ventura County. Ventura County did not file an appeal of the Conditional Use Permit approval. The General Plan Amendment and Zone Change have not been approved and the Final EIR for those applications has not been certified. The Regional Planning Commission made recommendations to the Board of Supervisors; however, only the Board can approve these actions. If the Board of Supervisors does not approve the General Plan Amendment and Zone Change, then the Conditional Use Permit and Tentative Parcel Maps approved by the Regional Planning Commission will become void. According to Los Angeles County Department of Regional Planning staff, the period to Me an appeal of both the Conditional Use Permit and Tentative Parcel Map will expire on Wednesday, January 14,1998. However, because the Tentative Parcel Map has been appealed by Ventura County, Los Angeles County staff has indicated that they will place both the Conditional Use Permit and Tentative Parcel Map before the Board of Supervisors for their consideration along with the approval of the General Plan Amendment and Zone Change. Therefore, the City will have another opportunity to comment on all of these applications prior to the Board of Supervisors final actions. A date for this hearing has not been set; however, the earliest date would be in February, 1998. ALTERNATIVE ACTIONS There are no alternative actions as identified by staff. FISCAL IMPACT None by this action. 1. Summary of City of Santa Clarita Issues 2. Copies of previous correspondence is available in the City Clerk's reading file 9 A cd\council \newha11.ap1 SUMMARY OF CITY OF SANTA CLARITA ISSUES IN REGARD TO THE NEWHALL RANCH PROJECT January 1998* ISSUE STATUS Build Newhall Ranch according to the City's Hillside standards are county standards development standards and are close to the City's standards; remaining standards will be reviewed during future subdivisions Santa Clara River and high country A conservation and recreation easement dedication to a public agency will be granted to the County of Los Angeles which will maintain public oversight; land will be dedicated to the Center for Natural Lands Management; timing of dedication and Center for Natural Lands Management remain outstanding issues Bank Stabilization alternatives Newhall Ranch has agreed to add Specific Plan language which will allow alternatives such as buried bank stabilization Non -motorized transportation alternatives The Specific Plan allows for a variety of non -motorized transportation alternatives such as trails; language has been added to encourage new transportation technologies Metrolink line restoration Metrolink right-of-way will be offered for dedication with each subdivision Future transit needs financing Gasoline and Proposition A and C sales taxes generated by the project will provide. surplus revenues; however, these revenues do not necessarily return to the Santa Clarita Valley Solid waste recycling Standards have been incorporated in the Specific Plan to require future subdividers to provide adequately sized, accessible and convenient areas for collecting and loading recyclables Describe the financing, maintenance and The Fiscal Impact analysis indicates that staffing of public parks there would be surplus tax revenues available for park recreation funding; however, these revenues do not necessarily, return to the Santa Clarita Valley Tie the project's trail system into the Santa Pedestrian and bicycle access will be Susana Mountains from the Santa Clara provided; the applicant is opposed to River equestrian access because of the presence of endangered species and sensitive habitats Directly connect the project's trail system Newhall Ranch has agreed that the missing and the City's trail system segment will be precisely located, and trail right-of-way will be designated when the underlying property is developed Additional issues have been identified (see June 1997 list in the reading file) which will require additional review at the time each Newhall Ranch subdivision is proposed in the future This is only a summary of the main issues the City has raised. Copies of previous correspondence containing complete issue and status descriptions has been placed in the City Clerk's reading file. JJL:lep advance\nwhlrnchyl City Manager Approval Item to be presented by: NEW BUSINESS DATE: JULY 8, 1997 SUBJECT: NEWHALL RANCH PROJECT UPDATE DEPARTMENT: Community Development On June 11, 1997, the Los Angeles County Regional Planning Commission continued the meeting schedule for the Newhall Ranch project to the date of July 28, 1997. Although the public testimony portion of the hearing was technically closed on April 4,1997, -the Regional Planning Commission left open the option to call upon individuals whom they would like to question regarding the proposal. The July 28, 1997 meeting will be held to further discuss the Newhall Ranch Specific Plan and to open up the public testimony portion of the project discussing the Draft Development Agreement. Los Angeles County planning staff and the Newhall Ranch Company have made the following changes to the project: Elimination of the 15 Estate lots from the High Country, totaling a reduction of 30 units (15 dwelling units and 15 second units). Dedication of the High Country at the 3000th building permit issuance in Potrero Valley Village, or at the mid -point of Newhall Ranch development; whichever occurs first. A requirement for environmental analysis and a conditional use permit if construction of a road in the Salt Creek Canyon Wildlife corridor is later proposed. Agreement to include public agency oversight for the High Country by granting an easement to Los Angeles County for conservation of resources, public access, and recreation, consistent with the proposed Resource Management Plan. Agreement to grant an easement to Los Angeles County for both the conservation of resources and for public access and recreation within the River Corridor consistent with the Resource Management Plan. The addition of an equestrian trail to the Regional River Trail along the north side of the Santa Clara River. Withdrawal of the proposed deletion of Pico Canyon Road from the County Master Plan of Highways, with a stipulation that the Specific Plan will not be conditioned to construct or fund any offsite portion of that highway. A commitment to seek Caltrans approval and funding to construct a traffic signal at the intersection of State Route 126 and Chiquito Canyon Road, along with first construction at that intersection ( in response to the concerns of the Val Verde community). Agreement to withdraw the proposal to reorganize and annex the Riverwood Village to the Newhall School District (at the request of the Castaic Union School District and Town Council). Reduction of development in the San Martinez Grande area by 5.6 acres, thereby eliminating 190 Medium residential dwelling units. Reduction of development between State Route 126 and the River corridor by 304 dwelling units, and 39,000 square feet of commercial area. The combination of two neighborhood parks, along with the addition of ten acres to the combined park site, adjacent to the Santa Clara River to create one larger community park site. A total of 867 residential units, along with 39,000 square feet of commercial area, have been removed from the Newhall Ranch Specific Plan proposal. Attached is Newhall Ranch's response to the issues the City raised in its April 1, 1997 letter to Regional Planning Commissioner Sadie Clark. Staff has reviewed the attached status report and has found it factually accurate. Receive the information presented and provide staff direction with regard to the future tracking of and/or position on the Newhall Ranch project. Newhall Ranch Company Status Report of City Issues GAC:JDR:lep counci1\arnrprg2.idr SUMMARY OF CITY OF SANTA CLARITA ISSUES IN REGARD TO THE NEWHALL RANCH As of June 27, 1997 1. Build Newhall Ranch according to the City's development standards. Resolved: 10side/Ridgeline standards are similar to City's and are much higher than County grading ordinance minimums. Bicycle trails are provided adjacent to all highways, which meets standard in draft City. Circulation Plan Continuing City to review Oak Banking Program, proposed in Section 4.3.4 of Review: the Development Agreement. Newhall Ranch Company states the program would result in planting of oaks many years in advance of any tree removals, and would provide 5:1 replacement for any heritage tree removals. Future City will comment on conformance with other City standards when Subdivision subdivisions are proposed in Newhall Ranch. Issue: 2. Resolved: A comprehensive (152 page) discussion of the project's conformity with policies of each of the above General Plans is provided in Appendix 2 of the DEIR and Chapter 7 of the Specific Plan Newhall Ranch meets County policies for location of new development: e.g., proximity to infrastructure, employment, shopping, regional highways. Fiscal Impact Analysis for project indicates the project pays for the services it requires and generates a surplus of revenues to the County and the City. SCAG projections for LA County indicate 3 million person increase by 2015. State -Department of Finance projections are similar, indicating 4 million person increase by 2020. Increase in households would require 25,900 housing units annually to 2015 Countywide, and nearly 30,000 annually between 2015 and 2020. Newhall Ranch meets only one year's housing needs in all of L. A County. Not Resolved: Size of project is still an issue. A total 867 housing units have been removed to resolve specific issues such as preserving riparian vegetation and mesic meadow, improving views of River. A complete, Est of project changes to date is being prepared for the County Planning Commission and will be reviewed by City. City staff will evaluate the public benefits provided by the project, as listed in the Development Agreement (See Section 2.1). 3. Santa Clara River and High Country 11 dedicate to the Santa Monica Mountains Conservancy or other Southern California agency and 2) dedicate upon Specific Plan approval. Resolved: An easement for the conservation of resources, public access and recreation in the High Country will be granted to Los Angeles County, which resolves the issue of ensuring that a local public agency will have oversight for this area. Continuing Center for Natural Lands Management was recommended by and Review: manages land for The Nature Conservancy and others. Newhall Ranch Company to provide additional background information and references and will set meeting with Executive Director, Sherry Teresa Not Resolved: Original proposal was to dedicate the High Country after recordation of the Visitor Center. NRC has made revised offer to dedicate Ffigh Country at mid -point of Newhall Ranch development, or sooner if Potrero Valley Village development has reached 3,OOOth residential building permit. Dedication would be delayed for period in which unsuccessful lawsuits hold up project development. Successful lawsuits would not extend dedication time. 4. Describe Proposed changes to SEA 23 Resolved: Newhall Ranch Company provided information that total open space along the River includes the adjusted SEA and adjacent Open Area The combined area contains 155 more acres of sensitive habitat types than did the original SEA boundary. River Corridor Plan requires temporary removal of 41 acres of riparian vegetation, which would be replaced. Future Corps of Engineers 404 permits and Fish and Game permits are required prior to development. Newhall Ranch Company will provide map illustrating SEA changes as part of the Final EIR. 5. Discuss alternatives for bank stabilization of the River. Future Newhall Ranch Company has agreed that other types of bank Subdivision stabilization would be acceptable if approved for the Newhall Issue: Ranch portions of the River by the County of L.A.; if the alterative would provide a superior appearance to ungrouted rip -rap; and if the alternative was proven to be cost effective in terns of construction and maintenance costs. Specifications for bank stabilization would be approved prior to construction of individual subdivisions. This language will be added to Specific Plan if acceptable to the County. 6. Ensure that future developers will provide for non -motorized modes of transportation at future subdivision stages Resolved: The Specific Plan reduces vehicle trips in several ways: it provides an extensive trail system (approximately 50 miles in length); dedicates or reserves Metrolink line and station site. (see below); provides bus pull -ins on highways in locations determined by the transit -provider, and provides standards under which home occupations (home based businesses) can occur. Newhall Ranch Company has also agreed to add the following language to Section 2.4 Transit of the Specific Plan: "Developers of future subdivisions in the Specific Plan are encouraged to consider provisions for new transportation technologies which are cost effective and for which there is sufficient consumer demand." 7. The applicant should be responsible for restoration of the Metrolink line. Resolved: As requested by the City Council, the Development Agreement Provides that Newhall Ranch subdivisions which contain a portion of the Metrolink right-of-way and station site shall be conditioned to offer the dedication of that portion of the right-of-way and/or station site to MTA for a period of 6 months following approval of the tentative subdivision map. If dedication is accepted, MTA must landscape and maintain the dedicated area. If MTA does not.accept dedication at the time of subdivision, MTA would be given right of first refusal to purchase the right-of-way and station site at appraised fair market value for the term of the Development Agreement. , 8. Address the financing of future transit need for the Project at buildout. Resolved: The Fiscal Impact Analysis in the DEIR substantiates that gasoline taxes and Proposition A and C Sales taxes generated by the project would provide a surplus of tax revenues beyond expenses to serve the project, from which the County could provide transit to the project. Not Resolved: County General Fund revenues do not necessarily return to the Santa Clarita Valley. The City continues to seek assurance from the County that the City will not have to subsidize transit service in Newhall Ranch 9. Provide assurance that Newhall Ranch will require future subdividers to incorporate residential design standards to accommodate solid waste recycling efforts. Continuing The Newhall Ranch DEIR contains mitigation measures which Discussion: require applicants for future multi -family, commercial and industrial subdivisions to provide adequately sized, accessible and convenient areas for collecting and loading recyclable materials; to meet all future state and county regulations and procedures for the use, collection and disposal of solid and hazardous wastes; and to provide educational/instructional materials to the first -purchaser of each residential unit. Not Resolved: In addition, City staff is drafting a policy oriented statement on solid waste which Newhall Ranch Company will consider for inclusion in the Specific Plan 10. Describe the financing, maintenance and staffing of Public Parks. Resolved: The pmject will more than meet its 199 acre Quimby park Obligation through the dedication of 334 acres of land for community and neighborhood parks and provision of park improvements under the Development Agreement totaling S 12.3 million dollars. (Unexpended dollars will be increased annually according to the Consumer Price Index.) As discussed in the Development Agreement, the project provides a total 2,482 acres of Quimby credit. Continuing City staff is continuing discussions with Newhall Ranch Company Discussion: regarding specific park improvements. Not Resolved: While the project Fiscal Impact Analysis indicates that there would be surplus tax revenues available which could fund recreation programs for Newhall Ranch residents, there is no guarantee that the County would provide such programs. The City staff continues to seek such assurances from the County. 11. Tie the oroiect's trail system into the Santa Susan* Mountains from the Santa Clara River. Resolved: Pedestrian and bicycle access will be provided from the regional Santa Clara River trail across the River (on the Potrero Valley Road bridge) and on Community and Local trails to the High Country. - Trails in the High Country would be built by Newhall Ranch Company. Newhall Ranch Company agrees to consult with the City and other appropriate public agencies regarding the design of trails to assure appropriate connections to the Santa CMta Woodlands Park. Not Resolved: Newhall Ranch Company and the project biologist are opposed to equestrian access from the regional River Trail to the High Country because of the presence of endangered species and sensitive habitats in the River. However, the Specific Plan permits an equestrian trail head to be sited at the Visitor Center at the entrance to the High Country. Additionally, equestrian access could be provided from the Pico. Canyon Trail through Grave Canyon (in the lower elevations of the High Country), from which equestrians could access other High Country trails which would provide connections to trails in the Santa CMta Woodlands Park. 12. Directly connect the nroiect's trail system and the City's trail system Resolved: Newhall Land has agreed that segments of the regional River Trail on their property between I-5 and Newhall Ranch will be precisely located, and trail right-of-way will be designated when the underlying property is subdivided. 13. Discuss the effects of Proposition 218 on the proieet. and the effects of Newhall Ranch on Henry Mayo Newhall Memorial Hospital Resolved: The effects of Proposition 218, to the extent currently known; will be included in the Final EIR and will be reviewed by City staff. Proposition 218 effects on Newhall Ranch would not reduce the tax surplus to the City, and the County will continue to receive a significant surplus. Newhall Ranch Company indicates that coordination between the Hospital and the Company has occurred and that the Hospital is confident that locations for possible health care facility expansion can be provided within the Specific Plan area if desired in the future. 14. The following issues have been identified as requiring additional review at the time each Newhall Ranch subdivision is proposed in the future: • Project compliance with all applicable NPDES Permit requirements. • Traffic performance evaluations at each subdivision stage. • Proper phasing and financing for transit service to the site. • Environmental review and public notification for any construction near the Salt Creek corridor. • Proper landform grading techniques. • Project compliance with, and incorporation of, Best Management Practices. • Minimization of non -point source pollutants throughout the Newhall Ranch site. • Individual Stormwater Pollution Prevention Programs for subdivisions, where appropriate. • Designs accommodating transit service to all future development sites. • The development of a major sports center for community tournaments/league play. • Teen programs and anti -gang programs for the residents of Newhall Ranch. • The inclusion of air quality mitigation measures at all stages of development. City Of Santa Clarita 23920 Valencia Blvd. Phone Suite 300 (805) 259-2489 Santa Clarita Fax Califomia 91355-2196 (805) 259-8125 April 1, 1997 Mrs. Sadie Clark, Chairperson Regional Planning Commission Los Angeles County 320 W. Temple Street Los Angeles, CA 90012 Re: Newhall Ranch Specific Plan Dear Mrs. Clark: On February 18, 1997, the City of Santa Clarita presented Resolution No. 97-8 to the Regional Planning Commission. This Resolution addressed the outstanding concerns the City has regarding the Newhall Ranch Specific Plan. Since that time, City staff has met with regional planning staff, and with the representatives of the Newhall Ranch plan, in order to more thoroughly discuss the City's concerns. Below is a list of concerns that still remain: • builct Newh II Kanch according to the City's development standards. The Newhall Ranch Company has attempted to design the project with oak tree standards, hillside and ridgeline standards, and highway standards that more closely resemble the standards of the City of Santa Clarita. Nevertheless, the City will still be reviewing all future subdivisions and developments for compliance with City standards. • Provide iustification for the amendments to the Los Angels County General Plan and the Rana Clarita Valley Area Plan, The Newhall Ranch Company has stated that the projected population increase, the accessibility to the site; the dedication of nine square miles of open space atno cost to the public, and the development of needed infrastructure are justifications for a County General Plan Amendment. However, the City feels that the SCAG population projections are very high, and that the infrastructure being constructed in conjunction with.this project specifically serves the residents of Newhall Ranch; they do not constitute an overall public benefit. Furthermore, the dedication of open space that is not accessible for many years, and parks that are not staffed, funded, and/or programmed are not a benefit to the Santa Clarita Valley. PRINTED ON RECYCLED PAPER Dedicate immediately upon approval of the Specific Plan The Santa Clara River corridor and Santa Susan^ Mountains to the Sana Monica Mountains Conservancy or other similar public agency based in the Southern California Leen Newhall Ranch has responded by granting an easement to Los Angeles County over the Santa Susana Mountains High Country when the 4,000th building permit is obtained within Potrero Valley Village. However, this response does not address the dedication of the Santa Clara River Corridor, nor does it specifically address the timing for dedication of the High Country. Due to the lack of project phasing information, the City cannot determine or even estimate.the length of time that could lapse between a pending project approval and issuance of the 4,000th building permit in Potrero Valley Village. ■ Biota Section of the D .IR, The response from Newhall Ranch has been that the Significant Ecological Area is being refined, and yet the language used to describe the changes has not been presented in layman's terms. It could still appear that riparian habitat is being removed from the River Corridor SEA. The City has asked that a comprehensive graphic be included in the Response to Comments that will address this issue. Discuss alternatives for bank stabilization of the Santa Clara River and 3yhy the use of ungrouted rip -rap is the pr fe rablp option Discuss with Fish and Game. The Newhall Ranch Company has stated that ungrouted rip -rap is more acceptable in biotic and aesthetic terms than concrete bank stabilization, and has been approved by Los Angeles County for safety. The City, however, is requesting that the developer incorporate flexibility in the Specific Plan for other means of bank stabilization. Technology is changing rapidly: some Southern California communities are incorporating soil cement for bank stabilization efforts. Additionally, the portion of Santa Clara River that traverses the Newhall Ranch property is large: some sections of the River may work best with ungrouted rip -rap, others with soil cement or concrete stabilization. Another recent trend also includes burying bank stabilization efforts with soil, and then planting this area with native habitat. These options should be investigated. Ensure that f tare developers will provide for non-motori2 d modes of transportation a ,tare subdivision stag a This should, at present, in 1 ud the incornoration of Electric Vehicle Charpj_ng stations. Newhall Ranch has not responded to this request. The City is very aware that technology changes rapidly, and is not asking that the developer be specifically tied down to requiring Electric Vehicle charging stations at each future subdivision stage. What we are asking is that, for an innovative project of this size, alternative fuel vehicles, EV charging stations, and other future technologies be encouraged by the Newhall Ranch Company in order to help reduce the project's air quality impacts. The applicantshould be r cnonaible for the restoration of tha DJetro ink ling, as opposed to solely reserving right-of-way.Grant funds have been identified by the Ventura Cn_unty Transportation Commission. and the applicant ghould work with VCTC to secure the necessary funding for restoration of the rail lim..Newhall Ranch has stated that they are making a financial commitment by agreeing to reserve right-of-way, as the right-of-way creates a "fix" on the property.which affects the design of future land uses, highways, trails, utilities and the like. However, the City feels that a project which will generate approximately 72,000 new residents should contribute more than just right-of- way for a rail line: a commitment to restoring the MetroLink line, in cooperation with the County of Los Angeles, will benefit the project's trip reduction efforts, will reduce the project's air quality impacts, will provide the County with CMP credits, and will serve as an overall public benefit for the project. Addresq the financing of future transitneed for the project at full h ,ild-o , The Newhall Ranch Company has stated that Proposition A and C Sales Tax, and gasoline taxes,supplemented by farebox revenues will pay for transit services. Also, the Company stated that the surplus revenue generated to the County by the Newhall Ranch project, will help pay for services. However, the County General Fund revenues do not necessarily return to the Santa Clarita. Valley.. The City is seeking assurance that future transit service to the Newhall Ranch site will not have to be subsidized by the City of Santa Clarita taxpayers. Establish specific measures that the project will take to red , / isnose of solid waste. assuming that no new construction or expansion of existing lands will occur- Additionally. providassurance that Newhall an h will r q, ,vire future subdividers to incorporate residential d inn standards to accommodate solid waste/recyclingeffortg. This issue has not been addressed to the City's satisfaction. The Newhall Ranch Company is still reiterating their commitment to meeting the minimum County requirements with regard to handling solid waste. Describp the financing- maintenance and staffing of public parks. Currently, the Newhall Ranch Company has stated that park maintenance, staffing and programs are expected to be funded by the County, and that the project's surplus money to the County could be .used . for staffing and programs. However, there is no guarantee that the project's revenues provided to the County's General Fund will return to the Santa Clarita Valley. As the developer has stated before, they are not a governmental agency, and thus do not have control over the distribution of funds. The City provides extensive parks and recreationprograms, is bound by agreement with the County which preclude the City from charging non-resident fees, and cannot adequately address the needs of additional population. Furthermore, the County does not currently fiord any recreation programs in the Santa Clarita Valley. The City is doubtful that revenues generated by the Newhall Ranch project.will return to the Santa Clarita Valley for parks and recreation services. Tie the project's rail system into the S nta S,san^ Mountains from the Santa Clara River- The developer has stated that an equestrian connection between the High Country and the River trail is problematic, as the horses would need to traverse the Santa Clara River bottom. Newhall Ranch has not included public recreation within the River bottom due to the presence of endangered species and sensitive habitats, and has stated that the Project Biologist is opposed to encouraging access within the River. However, the presence of an equestrian trail along the Santa Clara River, and the presence of equestrian trails in the Santa Susana Mountains High Country (which the developer agrees to tie in to the Pico Canyon Trail) should. be connected in order to provide a usable, logical regional trail system. Directly connect the project's trail system and the it3's trail system. The City is requesting that the gaps existing between the Newhall Ranch project and the City of Santa Clarita be "filled -in" in order to provide for direct access and a, once again, logical trail system. The Newhall Land and Farming Company owns the properties that comprise these gaps. However, the applicant has stated that filling inthe missing trail linkages will hinder all future development of the properties containing such areas. Two additional issues remain, including the effects of Proposition 218 on the project, and the effects of Newhall Ranch on Henry Mayo Newhall Memorial Hospital; these issues need to be covered in further detail. The Newhall Ranch Company has assured the City that these concerns will be covered more thoroughly in the Response to Comments. The above issues do not constitute a complete list of concerns. Resolution 97-8, the original City letter dated October 28, 1996, and the verbal testimony provided by City Councilmembers Heidt and Majic represent our views and issues with the Newhall Ranch project. Along with the aforementioned items, the City continues to request that specific questions and concerns be addressed at future subdivision stages, including, but not limited to, the following.- Project ollowing: Project compliance with all applicable NPDES Permit requirements; Traffic performance evaluations at each subdivision stage; Proper phasing and financing for transit service. to the site; Environmental review and public notification for any construction near the Salt Creek corridor; Proper landform grading techniques; Project compliance with, and incorporation of, Best Management Practices; Minimization of non -point source pollutants throughout the Newhall Ranch site; Individual Stormwater Pollution Prevention Programs for subdivisions, where appropriate; • Designs accommodating transit service to all future development sites; • The development of a major sports center for community tournaments/league play; • Teen programs and Anti -Gang programs for the residents of Newhall Ranch; • And the inclusion of air, quality mitigation measures at all stages of development. The developers of Newhall Ranch, along with the Los Angeles County regional planning staff, have been very accommodating and open to suggestion thus far. However, the City still feels that the above issues are important for the well- being of the Santa Clarita Valley. A project as large and innovative as the Newhall Ranch project should be responsible for more than just minimum standards: uncontrolled growth and urban sprawl have extremely detrimental effects on communities in Southern California. The Santa Clarita Valley currently has a shortage of infrastructure, such as adequate sewers, roads, mass transit, schools, fire, Sheriff facilities, libraries, parks, recreational programs, and youth and adult services. This project, without appropriate mitigation, will worsen our current infrastructure shortages. Please take the City's concerns into consideration prior to forwarding a recommendation to the Lo Angeles County Board of Supervisors. We should all be working together for etter Santa Clarita Valley. Thank you very much for your time �o i tion in this matter. Sincerely, cc: Michael Antonovich, Board of Supervisors City of Santa Clarita Councilmembers City of Santa Clarita Planning Commissioners George Caravalho, City Manager, City of Santa Clarita James Harter, Newhall Ranch Company Lee Stark, Community Studies Kerwin Chih, Impact Analysis Frank Menses, Impact Analysis Dave Vanatta, Planning Deputy Kenneth Pulskamp, Assistant City Manager, City of Santa Clarita Impact Sciences Van Stephens, FORMA current\nrreso.jdr RESOLUTION No. 97.8 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CLARITA, REQUESTING. THE LOS ANGELES COUNTY REGIONAL PLANNING COMMISSION WITHHOLD APPROVAL OF THE NEWHALL RANCH SPECIFIC PLAN UNTIL SUCH TIME AS ISSUES RAISED BY THE CITY OF SANTA CLARITA HAVE BEEN RESOLVED THE CITY COUNCIL OF THE CITY OF SANTA CLARITA DOES HEREBY RESOLVE AS FOLLOWS: SECTION 1. The City Council does hereby make the following findings of fact: a. The Los Angeles County Regional Planning Commission is currently considering action to approve the Newhall Ranch Specific Plan (Project). b. This Project is a large planned community with approximately 25,000 residential units located within the Santa Clarita Valley, outside the current _ City of Santa Clarita boundary. C. This Project is located within the geographic area included in the City of Santa Clarita General Plan and is designated RE (Residential Estate), RVL (Residential Very Low), and BP (Business Park). d. The City has reviewed this Project and the Draft Environmental Impact Report (DEIR) and has submitted written comments to the Los Angeles County Department of Regional Planning in a letter dated October 28, 1996. e. Councilmember Jan Heidt testified on behalf of the City of Santa Clarita City Council at the Los Angeles County Regional Planning Commission November 6, 1996 public hearing f. The City Council has discussed the City's position regarding this project at the City Council Study Sessions on November 5, 1996 and January 7, 1997. g. The Santa Clarita Valley has a shortage of infrastructure such as sewers, roads, mass transit, schools, fee, Sheriff facilities, libraries, parks, recreational programs, and youth and adult services. This Project, without appropriate mitigations, would worsen the current infrastructure shortages. h. It is generally understood that urban sprawl has had, and will continue to have, a detrimental effect on urban and rural communities in California This Project, not adequately mitigated, may have a detrimental effect on the Santa Clarita Valley and the City of Santa Clarita. L The City has discussed its areas of concern with the Project applicant on several occasions and has made little progress toward resolving the issues raised by, the City. Dedicate, immediately upon approval of the Specific Plan, the Santa Clara River corridor and Santa Susana Mountains to the the Santa Monica Mountains Conservancy or other similar public agency based in the Southern California region. Incorporate landform grading techniques in all hillside areas, as opposed to designing the project with typical grading practices. In addition to using this grading technique, the hillsides should be planted with native slope materials. Address and incorporate the standards of the revised municipal stormwater NPDES permit into the evaluation of potential water quality impacts for the project. This 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 feel that the revised Permit should be addressed prior to certification of the final EIR. • Specification of criteria for the "Santa Clara River Corridor Concept" that good surface runoff water quality be maintained through prevention or minimization of non -point source pollutants. 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. • The description of the functions of water quality basins throughout the Specific Plan area. The DEIR stated that sixteen water quality basins are located throughout the project site. The DEIR should also describe how they will maintain good surface water quality, and if they will be used to provide data for program monitoring. • The update and expansion of Best Management Practices in the DEIR. Pollution preventionlreduction activities should also be incorporated in the Specific Planus an ongoing community program. • The preparation and approval of a Stormwater Pollution Prevention Program for the project. • Furthering the description of the project's use of reclaimed water, expanding upon the possibility of integrating the Newhall Ranch reclaimed water system with other existing and future Santa Clarita Valley reclaimed water systems. • Describe the proposed changes to the Santa Clara River Significant Ecological Area. If it is the case that the area being removed from this SEA is being eliminated because it does not contain the sensitive habitat that a true Significant Ecological Area contains, then that should be clearly stated in the Biota Section of the DEIR. • Expand the project's traffic report to include: An expansion of the Specific Plan Trip Components to show the percent of Specific Plan trip -ends into the existing boundary of the.City of Santa Clarita, including fluctuations of these trip -ends over the years; The analysis of traffic impacts at different phases of project construction; Further analysis of the traffic impacts caused by the potential deletion of Pico Canyon Road from the Master Plan of Highways. The DEER shows no impact on Lyons Avenue, McBean Parkway, Valencia Boulevard, Magic Mountain Parkway, • Ensure that future developers will provide for non -motorized modes of transportation at future subdivision stages. This should, at present, include the incorporation of Electric Vehicle Charging Stations. • Resolve and specifically describe the financing and/or reimbursement plan for the Water Reclamation Plant. • Establish specific measures that the project will take to reduce/dispose of solid waste, assuming that no new construction or expansion of existing landfills will occur. • Provide assurance that the developer will require future subdividers to incorporate residential design standards to accommodate solid wastetrecycling efforts. It is not enough to just reiterate the fact that Newhall Ranch will meet the minimum County requirements with regard to handling solid waste. • Incorporate standards for composting and material recovery facilities throughout the project site. • Provide for the addition of active parkland to the project site. Using City standards, the developer would receive 30 percent credit towards Quimby requirements for private facilities. At a total requirement of 230 acres of parkland, 30 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. A major sports center should be added to the project which would accommodate community tournaments or league play. Currently, there are no plans for such a facility. Describe the financing and staffing of public parks. Who will maintain the parks? Who will pay for the maintenance? What recreation programs/staff will be provided by the applicant? As of right now, The City provides extensive parks and recreation programs which are open to all residents of the Santa Clarita Valley. Additionally, the City is bound. by agreements with the County which preclude the City from charging non- resident fees. Many of the residents we serve live in Stevenson Ranch, Val Verde, North Valencia, Saugus, and Agua Dulce. The County does not currently fund any recreation programs in the Santa Clarita Valley,.and the City's Parks & Recreation services cannot adequately address the needs of an additional population such as that of Newhall Ranch. Publicly funded programs must be identified an funded for this project. Describe the funding and staffing of additional programs. Programs such as teen Anti - Gang programs, should be incorporated into the Newhall Ranch project. Include equestrian trails along the Santa Clara River corridor. The Regional Santa Clara River Trail spans from the San Gabriel Mountains to the east, west to the pacific Ocean in Oxnard. The City 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 relates to bicycles and pedestrians, but does not address the equestrian element. Tie the project's trail system into the Santa Susana Mountains to Pico Canyon Trail. The applicant has stated that topography dictates this as an impossible task, but the City is not convinced that this is so. The massive size of this project should be able to somehow provide a route across the site to Pico Canyon Trail. 1927 PASSED, APPROVED AND ADOPTED this 14 day of January Gam:- •7 i MAYOR AT: /� j ,� CI CLERg'- III STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES ) CITY OF SANTA CLARITA ) I, annrnp raraaal nn , City Clerk of the City of Santa Clarita, do hereby certify that the foregoing Resolution was duly adopted by the City Council of the City of Santa Clarita at a regular meeting thereof, held on the 14 day of January , 1997 by the following vote of the Council: AYES: NOES: ABSENT: mundAres97-8.1ep COUNCILMEMBERS: COUNCILMEMBERS: COUNCILMEM 3ERS: Heidt, Klaiic/ Darcy, Boyer, Smyth R=.I None City of Santa Clarita 23920 Valencia Blvd. Suite 300 Santa Clanta California 91355.2198 October 28, 1996 Phone (805) 259-2489 Fax (805)259-8125 Mr. James Hard Director of Regional Planning County of Los Angeles 320 West Temple Street Los Angeles, CA 90012 nPr,,,' RE: CITY RESPONSE TO THE DRAFT ENVIRONMENTAL IMPACT REPORT ("DEIR") AND SPECIFIC PLAN FOR THE NEWHALL RANCH PROJECT Attention: Kerwin Chih, Impact Analysis Section Dear Mr. Hartl: 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. 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 moat 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. PRIMED 001 IIECM1111 PMEI1 .Newhall Ranch DEIR and Specife 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 Plan 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 Clarity 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 Clarita Valley-, The promotion of compatible land use policy and development standards in the Santa Clarita 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 Raneh DEIR and Specific Plan October28, 1996 Page 1 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 mariner. 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. • Aland 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 Specifc plan October 28, 1996 Page 4 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 stopsandtheir 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.'to 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, 1998 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 Specific 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 Specife 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 DEER 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 feel that 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 SPeceflc 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 ungrouted 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. • Mitl98tien_MMefl8ure: 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 EIR 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 DEDZ 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 Pfan 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. Mitigation Measure; 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 respect 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 I external summary of averagedailytrip-ends for the Specific Plan is as follows: NetvWl Ranch DEIR and Specifu pian Occobv 28, 1996 Page 10 Specific Plan Trip Components SPECIFIC PLAN 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 SR4W. 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.nL peak& .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 1l 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 Althoff 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 Bch, Particularly prior to full build -out. As stated in the DEIR, even at full buildout, only 35% of the 387,000 average daily trips (ADTe) generated in the Specific Plan area will also terminate in the Specific Plan area (page 4.8-31). Althoff 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 Ranch residents will be dependent an schools, retailers, banks, churches, and other facilities located outside the new Community. Accordingly, Newhall Ranch residents will need adequate means of trai spoiting themselves between the two communities. Thus, roadways which connect the two communities, such as Magic Mountain Parkway, Pico Canyon Road, Valencia Boulevard, and S1:1-126 / 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 requited 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 Specific Plan October 28, 1996 Pa,¢e 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 -build -nut scenario was evaluated in order to estimate the future transit needs of the proposed project. The Traffic I 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 coves 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, sucli 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 ADrs. 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 Speciftc 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 Clarity 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 qty 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 DEER, 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 QualityHandbook The DEER 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 Meas =: 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. • INlitieation Men sure: 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 DEIR also indicated that new County initiated connection fees would be 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.. However, 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 DEIR,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 Clarity Valley. Newhall Ranch DEM and Specific plan October 28, 1996 Page 13 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 DEM. This is a relevant question to us because the DEM 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 demind. 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 DEM could cause diversion efforts on a Santa Clarity Valley -wide basis to go backwards. It is recommended that the DEIR discuss and take a leadership role in determining how the project's solid waste will be handled The DEER 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 DEM 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 Specific plan October 28, 1996 Page 16 • biitiPation*V aa„ra: 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. • i igntion Measure: 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 Rivercorridor is consistent with the City of Santa Clarity'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, b 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 (135, which includes Newhall Ranch, is 246.6 acres of parkland: Page 4.20 -19 -states that the project provides 2,472 Newhall Ranch DEIR and SpeciJu Plan October 28, 1996 Page 11 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 DEIR 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 tainclude 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 Ague Duke 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 finding 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 firnded 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 Clarity 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 DEER 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 Clarity 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 Mans: 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. • Mitigation Mansura: Rest stops, scenic overlooks, staging areas, etc., are amenities that the project proponent should locate along the regional trail corridor. • Mitigation M as gra: 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 Santa Clarity • ligation M asnra: 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 Vewhall Ranch DEIR and Specific plan October 28, 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)1 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 methodologies for 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 DEER 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 ofschool.facility development. Section 4.17 • Police Servicer 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 70,000people, will affect both response tines and performance standards in the incorporated and unincorporated area of the Santa Clarita Valley. At this time,* the City is inclined to recommend that the Newhall 4 YewWl 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 safe, 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 curtently 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 Measure: The Newhall Ranch Specific Plan should provide for a My -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 4.18 - 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 financed by the developer, with the funding of applicable staff being guaranteed by the County of Los Angeles. Newhall Ranch DEIR and Spec,j,e pian 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 shquld 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 Ranch 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, Ken kamp Assistant City Manager KP:JL:JDR:Iep cc: Lee Stark, Community Studies Kerwin Chih, Impact Analysis Frank Menses, 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 Clarita Planning Commissioners James Harter, Newhall Ranch Company Impact Sciences Vag Stephens, Forma advance\spacpian.jdr